Introduction

Our Privacy Policy explains how we process and protect the data that you share with ZÜÜN (“We”, “Us”, “Our”). The terms “user” and “you” refer to an individual that uses ZÜÜN’s App, Website, Social Media (collectively “Products” and “Services” and “Products and Services”), or contacts us. ZÜÜN is a Product by Argento Technologies Limited – a company registered in the UK (124 Goswell Road, London, England, EC1V 7DP) which is responsible for processing personal data as described in our Privacy Policy. We are responsible for how your personal data is handled, as such we are the controller of your personal data under the GDPR.

Data We Process

Contact Data: Email, name, username, social media profile information, other contact details, the contents of messages or any other information that the user chooses to share with us.

Account Data: First name, last name, date of birth, gender, preferences, feedback. Communication Data: Email.

Financial Data: Transaction logs, user ID, username, name, and email.

Technical Data: Internet protocol (IP) address, device information, operating information, time zone, approximate location, error logs, diagnostic data, date and time.

Special Category: Health data through self-reported Check-Ins (sleep quality, mood, stress level, nutrition, movement level, activity tags), selfies and journal entries.

Purchase and Financial

Purchases made through Apple's in app purchase (IAP) process are solely subject to Apple's Privacy Policy and Terms and Conditions. Purchases made through Google's IAP process are solely subject to Google Play's Privacy Policy and Terms of Service. Apple and Google remain the controllers of your financial data. We are not liable for any IAPs. Refunds are managed directly with Apple's App Store here or Google's Google Play Store here. We use a third-party provider, RevenueCat, to process information about your subscription when a purchase is made. Data processed by RevenueCat are solely subject to their Privacy Policy.

Social Media

Our Social Media Providers share statistical and anonymised information with us about our Social Media Accounts. We and Meta, and we and LinkedIn are joint controllers of your personal data through our Social Media Accounts provided by Meta and LinkedIn respectively. The controller agreements can be found here (Meta) and here (LinkedIn).

AI Features

We provide an AI-powered feature to users on each subscription plan. By using our App you give us consent to share your Check-In Data for AI-generated analysis and insights (“AI-Insights”).

We only share the self-reported information from your Check-In about your sleep quality, mood, stress level, nutrition, movement level, activity tags, and the date of your Check-In with our third-party provider. We do not share Selfies, Journal Entries or any other Check-In Data, and we do not share your name, email, or other personal identifiers with our third-party provider. Our AI-Insights are powered by OpenAI. The portion of the Check-In Data detailed above is shared with OpenAI and processed by OpenAI. The Check-In Data is only used by OpenAI to provide the AI Feature to you. All content shared with OpenAI is subject to their privacy policies and security measures here. We do not use your content to train AI models.

You retain the right to cancel your subscription to our App if you do not agree to use our AI-Insights.

Selfies

Selfies are stored by a secure encrypted storage third-party provider and are delivered efficiently through Cloudflare. Data processed by Cloudflare are subject to their Privacy Policy.

Retention Period

We retain your personal data only for as long as necessary to fulfil the purposes described in our Privacy Policy, unless a longer retention period is required by law.

Account, Financial, Technical, Special Category: you can delete your data directly from your profile in the App, which is immediate, permanent and irreversible.

Alternatively, you can request for your Account, Technical and Special Category data to be anonymised after you close your account with our App. Data that is not deleted will be anonymised after 24 months of account closure. Error logs and diagnostic data may be retained for longer in an anonymised format to ensure technical stability and reliable Product and Service delivery to active customers.

Contact: retained for up to 18 months after the last interaction or until your inquiry is resolved, whichever is later. Social Media information is retained insofar the related post, account, or other interaction remains public or until it is deleted or its removal requested.

Communication: retained until you unsubscribe or retract consent, after which the related data will be deleted in 30 days.

Once the applicable retention period expires, personal data will either be deleted or anonymised.

Partners

We work with third-party providers to provide Product and Service development, hosting, maintenance, storage and backup. A list of our third-party providers can be found here.

Storage and Transfers

We take appropriate measures to ensure the safety and security of the data we process. We are based in the UK and rely on some third-party providers to deliver our app that are based outside of the UK. We take appropriate measures to ensure the protection of your data if it is transferred outside of the UK. In order to protect your data, we may use contractual clauses approved by the ICO to ensure it is protected up to the standard for UK GDPR.

How We Process Your Data

The table below outlines our justifications for how we process your data when you sign up to and use our Products and Services; we do not sell your data to any third- parties.

Purpose & Justification	Type of Data	Lawful Basis
To create, deliver and maintain reliable, usable and personalised Products and Services. To improve and to resolve any issues or bugs with our Products and Services.	Account, Financial, Technical, Special Category.	Contractual Necessity, Legitimate Interest, Consent (we rely on users consent to process special category data).
To maintain your account, subscription and ensure its reliable delivery.	Financial.	Contractual Necessity, Legitimate Interest.
To manage our relationship with users, manage user inquiries, provide information in response to users’ inquiries, and keep users informed with relevant information about our Products and Services.	Contact, Communication, Account.	Legitimate interest, Legal Obligation, Contractual Obligation, Consent.

Age Restrictions

Our App is not intended or directed to individuals under the age of eighteen (18) years. We do not knowingly collect personal data from children under 18 years of age. We rely on the accuracy and honesty of the date of birth you provide when signing up to our App, which prevents anyone younger than 18 years of age from creating an account with our App. However, if the law requires you to be older than 18 years of age to use our App, and in doing so for us to process your personal data, without the consent of your parent or guardian then you must acquire this minimum age before using our App.

User's Rights

General

You can access, download, correct, delete and change your personal information directly in our App from your profile page. Retention of your data is described in our retention period policy above. In our App, we provide guidance on how to manage notifications and camera access through your device’s system preferences.

For any personal data we collect that relies on your consent to process, you retain the right to not provide or withdraw your consent at any time. However, this does not affect the lawfulness of the consensual processing of your personal data before its withdrawal.

If you wish to not receive information from us, you can object at any time through the link provided in any email from us.

GDPR

To comply with UK data protection laws, you retain the right to:

Access: You can access and download the personal information we process about you in your profile page in our App.

Correction: If any of the personal information we collect and hold about you is incorrect, you can update it in your profile page in our App.

Erasure: You can delete your data in your profile page in our App as described in our Retention Period policy.

Object to Processing: You can withdraw any consent you have given us at any time. You can also object to processing information in certain circumstances by submitting your objection via email.

Data Portability: You can download the data we process in our App about you through your profile page in our App.

Withdraw Consent: You reserve the right to withdraw consent in cases where we rely on your consent to process your personal data. However, in some cases we may demonstrate we have a legitimate ground to process such data which may override your objection.

Rights in Respect to Automated Processing: While we do not use automated technologies to make decisions that may impact you, we do use Check-In Data to provide AI-Insights which can be used as recommendations.

Exceptions

We will not provide the following information:

• Information of a sensitive nature such as account passwords, emails, or anything of a similar sensitive nature.
• The information of other users and or employees as it infringes on their rights.
• To uphold the integrity and security of our app, server logs older than 30 days will not be shared.

Get in contact with us via email at support@zuun.app to exercise the described rights. You also reserve the right to complain to the data protection authority of your country about how we process your data, however we would appreciate the chance to deal with your concerns before you make a complaint. The contact details of the UK, EU and Switzerland can be found below:

UK: https://ico.org.uk

EU: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

CH: https://www.edoeb.admin.ch/en

Revisions

We may change this Privacy Policy from time to time. All changes will be posted on this page and, where required by law, will get your consent.

Contact Details

For any data and privacy or general inquiries contact support@zuun.app.