Zeylo Privacy Policy

Effective Date: April 25, 2025

Welcome to Zeylo! This Privacy Policy explains how the Zeylo team ("Zeylo", "we", "us", or "our") collects, uses, shares, and protects your personal data in relation to our mobile application, website, and services (collectively, the "Service"). This policy also describes your rights regarding your personal data under applicable law, including the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region ("PDPO").

This Privacy Policy applies to all visitors, users, and others who access the Service ("Users"). By using our Service, you understand and agree that we are providing a platform for you to post content, including videos, photos, comments and other materials ("User Content"), to the Service and to share User Content publicly or with other users. Please read this policy carefully.

1. Information We Collect (Personal Data)

We collect the following types of information, which may include personal data:

• Information you provide us directly:
  • Account Information: Your username, password, and email address when you register.
  • Profile Information: Information you provide for your user profile (e.g., name, picture, phone number, bio). Providing additional profile information is optional.
  • User Content: Videos, photos, comments, messages, and other materials you post or transmit through the Service.
  • Communications: Records of communications between you and Zeylo (e.g., support requests, feedback).
• Information collected automatically:
  • Usage Information: Details of how you use the Service, such as interaction with content, features used, frequency and duration of activities.
  • Log File Information: Automatically recorded information including IP address, browser type, device type, operating system, referring/exit pages, timestamps, and clickstream data.
  • Device Information: Device identifiers (like UDID, advertising ID), device attributes (like OS version, hardware model), and network information.
  • Location Information: We may collect general location information (e.g., based on IP address) or more specific location if you grant permission (e.g., via device GPS).
  • Cookies and Similar Technologies: We use cookies, pixels, local storage, and similar technologies to operate and personalize the Service, analyze usage, and for advertising purposes. You can control cookies through your browser settings.
• Information from Third Parties:
  • We may receive information about you from third-party services if you link them to your Zeylo account (e.g., logging in via another platform).

2. How We Use Your Information (Purpose of Collection)

We use the information we collect for the following purposes:

• To provide, operate, maintain, and improve the Service.
• To personalize your experience (e.g., suggesting content or features).
• To allow you to create and manage your account and User Content.
• To facilitate communication between users (where applicable).
• To communicate with you, including sending service-related notices, updates, security alerts, and support messages. You generally cannot opt-out of essential service communications.
• To understand usage trends and preferences, and develop new features.
• To detect, prevent, and address technical issues, fraud, or security concerns.
• To enforce our Terms of Service and other policies.
• To comply with legal obligations under Hong Kong law or respond to lawful requests from authorities.
• For marketing and promotional purposes (where permitted by law and with your consent if required).
• To provide measurement and analytics services (often using aggregated or anonymized data).

3. Sharing and Disclosure of Your Information

We do not sell your personal data. We may share your information in the following circumstances:

• With Other Users: Your profile information and User Content you post are visible to other users according to your settings and the nature of the Service.
• Service Providers: We share information with third-party vendors, consultants, and other service providers who perform services on our behalf (e.g., hosting, data analytics, payment processing, customer support). These providers are contractually obligated to protect your data and use it only for the purposes we specify.
• Affiliates: We may share information within our corporate group for operational purposes.
• Business Transfers: In connection with a merger, sale of assets, financing, or acquisition of all or a portion of our business, your information may be transferred as part of that transaction, subject to confidentiality agreements.
• Legal Requirements: We may disclose your information if required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is reasonably necessary to (a) comply with a legal obligation; (b) protect the safety of any person; (c) address fraud, security, or technical issues; or (d) protect Zeylo's rights or property.
• With Your Consent: We may share your information for other purposes if you provide your explicit consent.
• Aggregated or Anonymized Data: We may share data that has been aggregated or anonymized, so it cannot reasonably be used to identify you, for various purposes including analytics or reporting.

4. Data Storage and International Transfer

Your information collected through the Service may be stored and processed in **Hong Kong**, the United States, or any other country in which Zeylo, its Affiliates, or Service Providers maintain facilities. By using the Service, you consent to the transfer of information to countries outside of your country of residence, including Hong Kong and the U.S., which may have different data protection rules than your country. We will take appropriate steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

5. Data Security

We implement reasonable administrative, technical, and physical security measures designed to protect the security of information transmitted through the Service. However, no system is completely secure, and we cannot guarantee the absolute security of your information.

6. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements). When we no longer need your personal data, we will securely delete or anonymize it.

7. Your Rights and Choices (PDPO Compliance)

Under the PDPO and depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right to Access: You have the right to request access to the personal data we hold about you.
• Right to Correction: You have the right to request correction of inaccurate personal data we hold about you. You can often update your profile information directly within the app settings.
• Account Deletion: You can request the deletion of your account and associated personal data, subject to certain exceptions (e.g., legal obligations).
• Opt-out of Marketing: You can opt-out of receiving promotional communications from us by following the unsubscribe instructions in those communications or by contacting us.

To exercise these rights, please contact us using the details below. We may need to verify your identity before processing your request.

8. Children's Privacy - Age Restriction

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we become aware that we have inadvertently collected personal data from a child under 18, we will take steps to delete such information promptly. If you believe we might have any information from or about a child under 18, please contact us.

9. Third-Party Links

The Service may contain links to other websites or services not operated or controlled by Zeylo. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party service before providing any information to them.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated policy within the Service, sending an email, or through other appropriate communication channels. We encourage you to review this policy periodically. Your continued use of the Service after the effective date of the updated policy constitutes your acceptance of the changes.

11. Contact Us (Data Protection Officer)

If you have any questions, comments, or concerns about this Privacy Policy or our data practices, or if you wish to exercise your rights under the PDPO, please contact us at:

Email: [email protected]

While we may not have a formally appointed Data Protection Officer unless legally required, inquiries regarding data protection can be directed to this email address.