Zing Inc. (“Zing,” “we,” “our,” and/or “us”) is committed to protecting the privacy and personal information of individuals who use our platform. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information from users of the Zing Platform.

Zing operates a two-sided workforce optimization platform for the restaurant and hospitality industry, connecting qualified hospitality workers (“Teammates”) with restaurant and hospitality businesses (“Spots”) for shift-based work opportunities. Zing is a technology marketplace — we are not an employer of record, a staffing agency, or a temporary help agency.

This Privacy Policy applies to all users of the Zing Platform, including our website at zingwithus.com, our progressive web application (PWA) for Spots, our mobile applications for Teammates, and any related services (collectively, the “Zing Platform”).

By using the Zing Platform, you consent to the collection, use, and disclosure of your Personal Information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Zing Platform or provide us with your personally identifiable information.

2. Governing Law and Regulatory Framework

Zing is incorporated in Canada and operates primarily in Ontario. Our collection, use, and disclosure of Personal Information is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, Ontario provincial legislation.

We adhere to the ten fair information principles set out in PIPEDA: accountability, identifying purposes, consent, limiting collection, limiting use, disclosure, and retention, accuracy, safeguards, openness, individual access, and challenging compliance.

3. Definitions

In this Privacy Policy, the following terms have the meanings set out below:

Term	Definition
“Teammate”	An individual registered on the Zing Platform who provides or seeks to provide hospitality services at Spots through the platform. Teammates are not employees of Zing.
“Spot”	A restaurant, hotel, event venue, catering company, or other hospitality business registered on the Zing Platform that posts shift opportunities and engages Teammates.

“Spot User”	An individual who manages shifts and interacts with the Zing Platform on behalf of a Spot.
“ZingCard”	A Teammate’s living profile on the Zing Platform, containing Personal Information, work history, certifications, preferences, the Zings rating, shift history, and other platform-generated data.
“Zings Rating”	A proprietary composite rating reflecting a Teammate’s assessed performance across multiple dimensions, generated from onboarding data, post-shift reviews, and platform activity.
“Personal Information”	Information about an identifiable individual. This includes any information that, alone or in combination with other information, can be used to identify an individual.
“User”	Any individual who accesses or uses the Zing Platform, including Teammates, Spot Users, and visitors.
“de-identified”	All identifying details (names, employers, dates, locations, voice, and image data) are removed so that no reasonable person could identify you.

4. Information We Collect

We collect Personal Information from Teammates, Spots, and Spot Users through the following channels: information you provide directly, information generated through platform use, and information from third-party sources.

4.1 Information Collected from Teammates

4.1.1 Onboarding Information (ZingCard Profile Builder)

When a Teammate creates a ZingCard profile through our 3-step onboarding process, we collect:

Personal identifiers: Full name, email address, phone number, profile photograph
- Work history: Previous and current employers (workplace names), roles held (from

Zing’s 26-role classification), dates of employment, current employment status

Certifications: Industry certifications (e.g., Smart Serve, Food Handler), culinary/hospitality education credentials, general education background
- Work preferences: Preferred work areas (ranked, up to 3), availability preferences, geographic preferences
- Languages spoken: Including but not limited to English, French, Spanish, Turkish, Urdu, Bengali, and others
- Personal details: “Fun facts about you” and other optional self-description fields

4.1.2 Identity Verification

To verify Teammate identity during onboarding, we collect:

A digital image of a government-issued photo identification document
- The type of identification provided
- Name as it appears on the identification document, for verification against the profile

4.1.3 Work Authorization Declaration

Teammates are required to self-declare whether or not they are legally authorized to work in Canada. Zing does not collect or store work permit documents, immigration documents, or Social Insurance Numbers.

4.1.4 Platform-Generated Information

Through Teammate use of the Zing Platform and participation in shifts, we generate and store:

Zings Rating: A composite rating based on assessed performance across six dimensions (Technical Skill, Presentation, Smile/Warmth, Communication, Motivation, and Adaptability), supplemented by post-shift review data from Spots
- Reliability Events: Records of late clock-ins, no-shows, early departures, last-minute

cancellations, and other operational events that affect the Teammate’s reliability profile

Shift History: Dates, Spots worked at, roles performed, hours worked, and shift outcomes
- Post-Shift Reviews: Reviews and ratings provided by Spots about the Teammate’s

performance

Physical Condition Eligibility: A binary (yes/no) eligibility indicator for shift fitness. This is not a health assessment and no underlying health information is collected or stored.

4.1.5 Financial Information

Where applicable, we collect payment information necessary to process referral bonuses or other payments owed to the Teammate. Payment processing is handled by third-party providers; Zing does not store full credit card or bank account numbers on our servers.

4.1.6 ZingPath Assessment Data

During onboarding to the Zing Platform, Teammates complete a ZingPath assessment, a psychometric profiling tool based on a personality framework. ZingPath collects self-reported responses to personality trait questions and generates a personality profile used to inform role recommendations and matching.

4.1.7 ZingLens Interview Data

ZingLens is Zing’s artificial intelligence powered assessment tool. During the onboarding interview, an interviewer scores the Teammate’s responses across six dimensions: Technical Skill, Presentation, Smile/Warmth, Communication, Motivation, and Adaptability.

A separate consent form (the “ZingLens Consent Form”) will be provided to the Teammate before the interview. The interview may be recorded on audio and video, capturing the Teammate’s voice, facial expressions, physical appearance, body language, and verbal response, if the Teammate provides their consent to such recording and collection. Recordings may be used to develop, train, and calibrate ZingLens, evaluate interview methodology, conduct quality assurance, and generate de-identified statistical reports. Recordings or de-identified data derived from them may be shared with third-party AI service providers (who are contractually prohibited from using the data to train their own models) if the Teammate provides their consent to such sharing. Declining to be recorded or to have the recording of their interviews or the de-identified data derived from their interviews shared with third-party AI service providers does not affect the Teammate’s interview, scores, onboarding or relationship with Zing.

Some of the scoring dimensions involve the collection of sensitive Personal Information: (a) Smile/Warmth evaluates friendliness and approachability observed through facial expressions and demeanor; (b) Presentation evaluates professional appearance as relevant to the hospitality industry; and (c) Communication evaluates clarity of expression and listening ability. We obtain Teammates’ express consent before assessing a Teammate on these dimensions.

4.2 Information Collected from Spots and Spot Users

4.2.1 Spot Onboarding Survey

When a Spot registers on the Zing Platform, we collect business information through our onboarding survey, which is also used for the Toronto Hospitality Staff Standard Index benchmarking program:

Operation type and business category
- Multi-location status
- Headcount per role (using Zing’s 26-role classification matrix)
- Current hiring sources and methods
- Perks and benefits offered to staff
- Training willingness and capacity
- Assessment dimension priorities

4.2.2 Spot User Personal Information

Individual Spot Users who manage shifts on the platform provide:

Full name and email address
- Role at the Spot

4.2.3 Platform-Generated Spot Information

Aggregate Spot rating from Teammate post-shift reviews
- Shift posting history, fill rates, and response times
- Retention and rehiring data
- Cancellation history and patterns

4.2.4 Financial Information

Billing information, payment history, and (in future) subscription tier details. Payment processing is handled by third-party providers.

4.3 Information Collected Automatically

When you use the Zing Platform, we automatically collect:

Device Information: IP address, device type, operating system, browser type, mobile device identifiers, and push notification tokens
Usage Information: Pages viewed, features used, actions taken within the platform, dates and times of access, and session duration
Location Information: With your permission, we may collect approximate or precise location data to facilitate shift matching and commute-based recommendations. You may disable location services through your device settings.
Cookies and Similar Technologies: We use cookies, tracking pixels, and similar technologies to understand platform usage and improve the user experience. See Section 11 for our Cookie Policy.

4.4 Information We Do Not Collect

Zing does not collect the following categories of information:

Biometric data (Zing does not use facial recognition or biometric matching for identity verification but certain assessment dimensions involve observation of facial expressions and presentation as described in this Policy)
Social Insurance Numbers (SIN) or tax identifiers from Teammates
Criminal background check results
Health information beyond the binary physical condition eligibility indicator
Immigration or work permit documents

5. How We Use Personal Information

We use Personal Information for the following purposes, which we identify at or before the time of collection:

5.1 Platform Operations

Completing Teammates’ onboarding on the Zing Platform
Matching Teammates with Spots based on skills, ratings, preferences, location, and availability
Generating and maintaining the ZingCard living profile
Calculating and updating the Zings Rating based on assessment data, post-shift reviews, and reliability events
Recording reliability events (late arrivals, no-shows, cancellations) to maintain platform integrity
Facilitating post-shift reviews from both Teammates and Spots
Managing shift scheduling, confirmations, and cancellations

5.2 Community Programs

Processing referral bonuses under the Teammate and Spot referral programs

5.3 Communications

Sending shift notifications, confirmations, and updates
Providing customer support
Sending platform announcements and feature updates
Marketing and promotional communications (with consent; you may opt out at any time)

5.4 Safety, Security, and Legal Compliance

Verifying Teammate identity during onboarding
Preventing fraud, abuse, and violations of our Terms of Service
Responding to legal requests and enforcing our agreements
Complying with applicable laws and regulations

5.5 Analytics and Improvement

Analyzing platform usage to improve features and user experience
Generating aggregate, de-identified industry benchmarking data (Toronto Hospitality Staff Standard Index)
Developing and refining our assessment and matching algorithms

6. The Zings Rating and Algorithmic Decision-Making

The Zings Rating is a central feature of the Zing Platform. Because it directly affects a Teammate’s visibility to Spots and access to shift opportunities, we are committed to transparency about how it works.

6.1 How the Zings Rating Is Generated

The Zings Rating is a composite score based on:

Post-shift reviews provided by Spots across six assessment dimensions: Technical Skill, Presentation, Smile/Warmth, Communication, Motivation, and Adaptability
Reliability indicators derived from platform activity, including punctuality, shift completion, and cancellation patterns
Shift history volume and recency

The Zings Rating uses five levels: Rookie, Rising Star, Pro, All-Star, GOAT.

6.2 Reliability Events

Zing records the following operational events that may affect a Teammate’s profile and

matching priority:

Late clock-ins (arrival after scheduled shift start time)
No-shows (failure to appear for a confirmed shift)
Early departures without prior arrangement
Cancellations within a defined window before shift start
Other operational events reported by Spots through post-shift reviews

Teammates are notified when a reliability event is recorded against their profile. Reliability events are retained for one year and are aged out after that period.

6.3 Right to Challenge and Dispute

Teammates have the right to:

View their complete Zings Rating breakdown and the data that contributes to it
Challenge any specific reliability event they believe was recorded in error (e.g., a late arrival caused by incorrect Spot-provided information)
Request a review of their overall Zings Rating if they believe it reflects systemic bias or inaccuracy
Receive a response to any dispute within ten business days Disputes may be submitted through the Zing Platform or by contacting us at privacy@zingwithus.com.

7. How We Share Personal Information

7.1 Between Teammates and Spots

When a Teammate and Spot are matched for a shift, or when a Spot is browsing available Teammates, the following information is shared:

Spot sees: Teammate’s ZingCard (name, photo, work history, certifications,

preferences, Zings Rating, shift history, reliability summary, fun facts)

Teammate sees: Spot name, location, role details, shift details, aggregate Spot rating from other Teammates

Post-shift reviews from Spots are reflected in the Teammate’s Zings Rating. Individual review content from Spots is not visible to Teammates; only the aggregate score is displayed.

7.2 ZingCard Visibility

The ZingCard is a shareable profile with a unique URL. The following visibility settings apply:

Authenticated Spot Users: Can view the full ZingCard when browsing or matching
Public URL: Teammates may share their ZingCard URL publicly (e.g., at job fairs, on social media). The publicly visible version may contain a subset of ZingCard data.
Privacy controls: Teammates can toggle visibility settings for their ZingCard.

7.3 Third-Party Service Providers

We share Personal Information with third-party service providers who assist us in operating the Zing Platform, including:

Payment processors (for shift payments and referral bonuses)
Cloud hosting and data storage providers
Analytics and performance monitoring services
Communication services (email, SMS, push notifications)
Identity verification providers (if applicable)

Your Personal Information may be stored, processed or otherwise used by us, our affiliates or our service providers, both inside and outside of Canada. As a result, that country’s courts, governments or law enforcement agencies could obtain disclosure of your information in accordance with that country’s laws. Whenever we hire other organizations to provide support services, they will be required to conform to our privacy standards and to allow us to audit them for compliance. All third-party service providers are contractually required to protect Personal Information and use it only for the purposes we specify.

7.4 Aggregate and De-Identified Data

We may share aggregate, de-identified data that cannot be used to identify any individual for purposes including industry benchmarking (Toronto Hospitality Staff Standard Index), academic research, and marketing materials. This data may include aggregate statistics about shift volumes, fill rates, role demand, and workforce trends.

7.5 Legal Requirements

We may disclose Personal Information where required by law, regulation, legal process, or governmental request, including to comply with a subpoena or court order, to protect the rights, property, or safety of Zing, our users, or the public, or to enforce our Terms of Service.

7.6 Business Transfers

In the event of a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, Personal Information may be transferred as part of that transaction. We will notify affected users of any change in ownership or control of their Personal Information.

8. Consent

8.1 How We Obtain Consent

We obtain consent for the collection, use, and disclosure of Personal Information as follows:

Express consent: For sensitive Personal Information (government ID images, location data), we obtain express, affirmative consent at the time of collection. Additionally, in connection with the ZingLens interview process, we obtain express consent for the collection of sensitive Personal Information as well as the recording of the interview and sharing such recording or de-identified data from such recording with third party AI service providers.
Implied consent: For information necessary to provide the services you have requested (e.g., profile data, shift matching), consent is implied through your use of the Zing Platform and acceptance of these terms.
Opt-in consent: For marketing and promotional communications, we obtain opt-in consent and provide a clear mechanism to withdraw consent at any time.

8.2 Withdrawal of Consent

You may withdraw your consent to the collection, use, or disclosure of your Personal Information at any time, subject to legal or contractual restrictions. To withdraw consent, contact us at privacy@zingwithus.com. Please note that withdrawing consent may affect your ability to use certain features of the Zing Platform.

9. Data Retention and Deletion

9.1 Retention Periods

We retain Personal Information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. The following retention periods apply unless we are required by law to retain the information for longer:

Data Category	Retention Period	Rationale
Active account profile data	Duration of account + 90 days	Necessary for platform services
ZingLens interview recordings	36 months from the date of the recording, the permanently deleted within 30 days	ZingLens calibration and development, per Zing Onboarding Consent Form
De-identified interview transcripts and interviewer scores	60 months from the date of the recording, then deleted or further anonymized	Ongoing AI development, per Zing Onboarding Consent Form
Zings Rating and assessment data	Duration of account + 12 months, after which it will be deleted or de-identified	Core platform function
Reliability events	12 months from the date of the event	Rolling window; aged out after period
Shift history	Operational information: Duration of account + 12 monthsTax-related information: 7 years from the date of the relevant shift	May be required for tax/legal compliance
Post-shift reviews (given and received)	Duration of account + 12 months	Linked to rating system
Government ID images	Deleted within 30 days of the date of successful identification verification	Deleted after successful verification
Payment and financial records	7 years from the date of the relevant transaction	CRA requirements
Communications and support records	24 months from the date of your last interaction with the Zing Platform	Dispute resolution
Aggregate/de-identified data	Indefinitely	Not Personal Information

9.2 Account Deletion

Teammates and Spot Users have the right to request deletion of their account and Personal Information at any time. To delete your account, contact us at privacy@zingwithus.com or use the account deletion feature within the Zing Platform.

Upon account deletion:

Immediately deleted: Profile information, fun facts, personal preferences, government ID images (if retained post-verification), contact information
Anonymized: Shift history and rating data may be retained in anonymized form (with all personally identifying information removed) for aggregate platform statistics
Retained for legal compliance: Financial records, tax-related information, and records necessary for legal compliance or pending disputes are retained for the legally required period and then deleted

The ZingCard and its unique URL become immediately inaccessible upon account deletion.

9.3 Data Portability

Upon request, we will provide you with a copy of your Personal Information in a commonly used, machine-readable format. Requests may be made by contacting privacy@zingwithus.com.

10. Data Security

We implement technical, administrative, and physical safeguards to protect Personal Information against unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption of Personal Information in transit and at rest
Access controls limiting access to Personal Information to authorized personnel on a need-to-know basis
Regular security assessments and monitoring
Secure data storage in compliance with industry standards
Employee and contractor training on data protection obligations

While we take reasonable steps to protect Personal Information, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

10.1 Breach Notification

In the event of a breach of security safeguards involving Personal Information that creates a real risk of significant harm to affected individuals, Zing will:

Notify the Office of the Privacy Commissioner of Canada (OPC) as soon as feasible
Notify affected individuals as soon as feasible, describing the nature of the breach, the Personal Information involved, steps we have taken, and steps the individual can take to reduce risk of harm
Notify any other organization or government institution that may be able to reduce the risk of harm
Maintain a record of all breaches of security safeguards for a minimum of 24 months

11. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Remember your login session and preferences
Understand how you use the Zing Platform
Improve platform performance and features
Deliver relevant communications

You can control cookies through your browser settings. Disabling cookies may affect your ability to use certain features of the Zing Platform.

12. Your Rights

Under PIPEDA and applicable law, you have the following rights regarding your Personal Information:

Access: You may request access to the Personal Information we hold about you, including the data underlying your Zings Rating
Correction: You may request correction of any inaccurate or incomplete Personal Information
Deletion: You may request deletion of your account and Personal Information, subject to the retention provisions in Section 9
Portability: You may request a copy of your Personal Information in a machine-readable format
Challenge ratings and reliability events: You may dispute any element of your Zings Rating or any recorded reliability event through the process described in Section 6.3
Withdraw consent: You may withdraw consent to the collection, use, or disclosure of your Personal Information at any time, subject to legal restrictions
Complaint: You may file a complaint with Zing’s Privacy Officer or with the Office of the

Privacy Commissioner of Canada

To exercise any of these rights, contact us at privacy@zingwithus.com.

13. Children’s Privacy

The Zing Platform is not directed to individuals under the age of 18. We do not knowingly collect Personal Information from anyone under 18. If we become aware that we have collected Personal Information from a minor, we will take steps to delete that information promptly. If you believe that a minor has provided us with Personal Information, please contact us at privacy@zingwithus.com.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Zing Platform, or applicable law. If we make material changes, we will notify you through the Zing Platform, by email, or by other appropriate means before the changes take effect. The “Last Updated” date at the top of this Privacy Policy indicates when it was most recently revised.

Your continued use of the Zing Platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should discontinue use of the Zing Platform and request account deletion.

For material changes that affect processing for which express consent was obtained (including changes to how recordings are used, how data is shared with third party AI service providers, or how assessment dimensions are scored), Zing will seek your express re-consent before the changes take effect.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your Personal Information, please contact:

Zing Inc.

Privacy Officer

Email: privacy@zingwithus.com Website: zingwithus.com

Mailing Address: 209 Southview Rd, Barrie, ON, L4N 3X6

You may also file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.