Privacy Policy for Zefo

Last Updated: January 8, 2026

Contact: For questions regarding this Privacy Policy, please contact us at support@zefoapp.com.

This Privacy Policy applies to the Zefo mobile application (the "App") provided by Zefo Team (the "Company", "we", "us", or "our"), and governs the collection, use, and disclosure of personal information of users ("you" or "your") who access and use the App. This App is distributed globally excluding the People's Republic of China, and is intended for users who are 18 years of age or older.

1. Scope of Application & User Eligibility

1.1 This Privacy Policy applies to all users accessing the App from regions worldwide except the People's Republic of China. By using the App, you confirm that you are at least 18 years old and have the legal capacity to enter into binding agreements.

1.2 If you are under 18 years of age, you are prohibited from using the App. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that a user under 18 has provided us with personal information, we will take steps to delete such information as soon as possible.

2. Compliance with Data Protection Laws (Including GDPR)

2.1 We comply with applicable data protection laws and regulations, including the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA), United Kingdom, and Switzerland.

2.2 For users covered by GDPR, you have the following rights regarding your personal data:

2.3 To exercise your GDPR rights, please contact us at support@zefoapp.com with sufficient details to identify your request. We will respond to your request within the time limits required by applicable law (typically 1 month, extendable by 2 months in complex cases).

3. Collection and Use of Personal Information

3.1 Information You Provide Voluntarily:

3.2 Automatically Collected Information:

3.3 Purpose of Use:

4. User-Generated Content (UGC) Policy

4.1 Definition of UGC: UGC refers to any content (including but not limited to text, images, photos, videos, audio, comments, and links) that you create, post, upload, share, or transmit through the App.

4.2 Ownership of UGC: You retain ownership of the intellectual property rights in your UGC (subject to applicable law). By posting UGC on the App, you grant us a non-exclusive, worldwide, royalty-free, sublicensable, and transferable license to use, reproduce, modify, adapt, publish, distribute, display, and translate your UGC for the purpose of operating, promoting, and improving the App, and providing the App's services to you and other users.

4.3 Prohibited UGC Content: You are strictly prohibited from posting, uploading, sharing, or transmitting any UGC that:

4.4 UGC Moderation: We reserve the right (but not the obligation) to monitor, review, and remove any UGC that violates this Policy or our Terms of Service, at our sole discretion and without prior notice. We may also suspend or terminate your account if you repeatedly post prohibited UGC.

4.5 Reporting UGC: If you encounter UGC that violates this Policy, please report it to us at support@zefoapp.com with details (e.g., content description, post link, date) so we can investigate and take appropriate action.

5. Disclosure of Personal Information

5.1 We will not sell your personal information to third parties for commercial purposes.

5.2 We may disclose your personal information in the following circumstances:

6. In-App Purchase (IAP) Data Privacy

6.1 All in-app purchase transactions are processed directly by Apple App Store, in accordance with Apple's privacy practices and payment security standards. We do not collect, store, or process your payment card information, CVV, or other sensitive payment details.

6.2 We only receive limited transaction data from Apple (e.g., transaction ID, purchase date, item purchased, Apple ID anonymized identifier) to verify purchases, fulfill orders, and provide customer support for in-app purchases.

6.3 Refunds for in-app purchases are handled in accordance with Apple's App Store refund policy. We do not process refunds directly, but we may assist you in providing necessary information to Apple for refund requests.

6.4 We may use in-app purchase data to improve our products and services, but such data will be anonymized and aggregated to ensure your personal information is not identifiable.

7. Data Security

7.1 We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7.2 You are responsible for maintaining the confidentiality of your account credentials (e.g., password) and for all activities that occur under your account. Please notify us immediately at support@zefoapp.com if you suspect any unauthorized access to your account.

7.3 For in-app purchase-related data, we additionaly implement fraud detection measures to protect against unauthorized transactions and account compromise.

8. Data Retention

8.1 We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal obligations, resolve disputes, and enforce our agreements.

8.2 In-app purchase transaction data is retained for the period required by applicable tax and accounting laws (typically 7 years) or until you request deletion (subject to legal requirements).

8.3 When your personal information is no longer needed, we will delete or anonymize it in accordance with applicable law.

9. Third-Party Services

9.1 The App may contain links to third-party websites or services that are not owned or controlled by us. We are not responsible for the privacy practices or content of such third-party services.

9.2 Apple App Store is a third-party service provider for in-app purchases. Their privacy policy governs the processing of your payment information, and we encourage you to review Apple's Privacy Policy (https://www.apple.com/legal/privacy/en-ww/).

9.3 We encourage you to review the privacy policies of any third-party services you access through the App.

10. Changes to This Privacy Policy

10.1 We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated Policy on the App, sending you a notification, or other reasonable means, prior to the effective date of the changes.

10.2 If we make changes to the in-app purchase data processing practices, we will provide additional notice to affected users as required by applicable law.

10.3 Your continued use of the App after the effective date of the updated Policy constitutes your acceptance of the changes.

11. Additional Information

11.1 This App offers in-app purchase features, including but not limited to premium content, subscriptions, and virtual items. All in-app purchases are subject to Apple's App Store Guidelines and this Privacy Policy.

11.2 If you have any questions, concerns, or requests regarding this Privacy Policy, our data practices, or in-app purchase privacy, please contact us at: support@zefoapp.com.