ZChat Privacy Policy

By using ZChat, you acknowledge that you have read and understand the information in this Policy.

1. Introduction

Aureus Z, Inc. ("we", "us", "our") respects your privacy and we are committed to protecting any of your Personal Data we process. Aureus Z, Inc. owns and operates a microblogging application ("ZChat" or "the App") and desktop application (available at bapu.app; each a "Site"; the App and Sites, collectively, "ZChat") that run on the Authenticated Transfer Protocol ("AT Protocol"). Your use of ZChat is subject to this privacy Policy ("Policy") as well as the ZChat Terms of Service, Bapu Community Guidelines, and Copyright Policy.

This Policy explains what we do with our users’ Personal Data. It also explains how we handle Personal Data in the context of our relationships with other businesses.

We process your Personal Data when you use ZChat and to provide the services that we offer via ZChat (the "Services"). We are a "data controller" of the Personal Data that we process in connection with the Services. This means that we decide why and how we process Personal Data about you.

If you have any questions about this Policy or our processing of your Personal Data, please see Section 18, Contact Us, for contact information.

We may update this Privacy Notice from time to time. We will post these changes on the Site or in the App. We may also send you other notifications about these updates.

2. What is Personal Data?

"Personal Data" is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.

We may also collect data that is not associated or linked with you or that cannot be used to identify you, like deidentified, aggregated or anonymised information. This is not Personal Data and is not subject to this Policy.

3. Informing us of changes

Please keep us informed if your Personal Data changes at any point during your relationship with us so we can keep our records accurate and current. Update your Personal Data in the App or on the Site.

4. Applicability of this Policy

This Policy is separate from our Terms of Service and our Bapu Community Guidelines, that also govern your use of ZChat.

5. Third-party Services

ZChat and the Services may include links to third-party websites, plug-ins, applications, services, products, and technology (“Third-party Services”). Clicking on links to and using Third-party Services may allow third parties to collect or share your Personal Data. We are not responsible for the content, security or privacy practices of those Third-party Services and this Policy does not apply to your use of Third-party Services. You should consider the privacy and cookie policies / notices of those third parties to find out how your Personal Data may be used.

6. If you do not want to provide Personal Data

We need to collect certain Personal Data to give you access to ZChat or to specific features and functionalities of ZChat, in accordance with our agreements with you. Applicable laws also require us to process certain Personal Data about you. If you do not want to provide Personal Data we request, we may not be able to provide you with access to the ZChat app or to specific features and functions of ZChat.

7. Updates to this Policy

We may update this Policy from time to time, and any updates will be effective when we post the revised Policy on ZChat. We will use reasonable efforts to notify you of any material updates to this Policy, by sending you a message in the App or on the Site, or at the email address you provide to us.

You should review this Privacy Notice every time you access a ZChat App Service.

8. Personal Data We Collect

We process, or our third-party providers may process for us, different kinds of Personal Data:

Personal Data you provide

• Account Creation. We collect information like email address, phone number, images you associate with your profile, birth date and username when you create a ZChat account.
• Your Communications with Us. We may collect personal information, like your name, email address, or phone number when you contact us.
• Your Posts. ZChat is a microblogging service that lets you post content and comment on other users' posts. We collect your posts. Your posts and comments are public, so exercise care when deciding what to share.
• Your Direct Messages. We store and process your direct messages so you can communicate directly with other users on ZChat. These are unencrypted and can be accessed for Trust & Safety purposes.
• Job Applications. If you apply to work with us, we collect any personal information you provide with your application.
• Payment Information. When you make a purchase, a third party service provider that handles payments for us will receive the payment information you provide, including your payment card information.
• Account Recovery. If you lose control of your account for some reason and need to recover it, we may ask you to provide information that helps us confirm your identity.

Personal Data We Collect Automatically

• Usage Information. When you use ZChat, we collect certain information automatically, including your Internet protocol (IP) address (which can be used to derive your general location), user settings, cookie identifiers, mobile carrier, other unique identifiers, browser or device information, and Internet service provider (ISP). We may also collect personal information about your use of ZChat, including the posts you view on ZChat, the links you click within ZChat, and the frequency and duration of your activities.
• Cookies (and Other Technologies). We and third parties that provide content or other functionality on ZChat may use cookies, pixel tags, and other technologies ("Tracking Technologies") to automatically collect information. See Section 9, Cookies, for more information.

Personal Data We Collect from Other Sources

• Third Parties, generally. We may collect personal information from third parties. For example, you may direct a developer application or other third-party social networking application to share personal information with us or you may live in a jurisdiction that requires age verification and we will collect information from a third-party provider telling us whether you meet certain age requirements.
• Third Party Age or Identity Verification. Where required by law, ZChat may use third-party services to verify that you are old enough to access certain features or content. This verification may involve one or more of the following methods, depending on your jurisdiction and availability:
  • Government ID Verification: Uploading an image of a government-issued ID, which is checked for authenticity.
  • Facial Age Estimation: Uploading a selfie or real-time facial scan used to estimate age via machine learning technology.
  • Payment Card Verification: Providing a valid payment card to confirm age through a nominal transaction or validation check.
  • Knowledge-Based Verification (KBV): Answering questions based on public records to confirm identity and age.
  • Social Vouching: A verified adult vouches for the user's age using their own verified account or identity.
  • Mobile Phone Verification: Using a phone number linked to a mobile carrier account to infer your age.
  • Email Based Age Inference: Using publicly available data about an existing email account to infer your age.

You will be able to choose from among available jurisdiction-specific options based on your preference. We do not retain any biometric data or facial images provided to third-party age verification vendors.

9. Cookies

We use cookies and other Tracking Technologies to collect certain information automatically. Tracking Technologies allow a website to recognize your device and can serve several purposes: to ensure that the website takes the user’s preferences into account by storing language preferences, to collect statistical data and adapt the content. Tracking Technologies can help provide you with a good experience when you browse websites and also help improve website functionality.

• Strictly Necessary Cookies. Some cookies are strictly necessary to make our ZChat Services available to you. We cannot provide you with our ZChat Services without this type of cookie.
• Analytical or Performance Cookies. We may also use cookies for website analytics purposes in order to operate, maintain and improve our ZChat Services. We may use our own analytics cookies or use third-party analytics providers.

You can block cookies by setting your internet browser to block some or all cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of the Sites and ZChat. You can change your browser settings to block or notify you when you receive a cookie, delete cookies or browse our Sites using your browser’s anonymous usage setting.

Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of cookies or similar Tracking Technologies which store information on your device, you should change your browser settings accordingly. Where required by applicable law, you will be asked to consent to certain cookies and similar Tracking Technologies before we use or install them on your computer or other device.

10. How We Use Personal Data

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

The list below indicates the purposes for which we collect and process your Personal Data. Some of the above grounds for processing will overlap and there may be several grounds which justify the processing of a single category of Personal Data.

To Provide Our Services. We use personal information to fulfill our contract with you and provide ZChat and the Services, such as:

• Managing your account;
• Providing access to certain areas, functionalities, and features of the ZChat Services;
• Answering support requests; and
• Communicating with you about your account, activities on the ZChat Services, and policy changes.

For Administrative Purposes. We use personal information for various administrative purposes, such as:

• Pursuing our legitimate interests like direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and taking appropriate actions against malicious actors;
• Measuring interest in, and engagement with ZChat and with Services;
• Creating de-identified and/or aggregated information;
• Carrying out analytics;
• Improving, upgrading, or enhancing ZChat and Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Sharing information with third parties as needed to provide ZChat and Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

For Marketing. We may use personal information to provide you with marketing. If you have any questions about our marketing practices, you may contact us using the information provided below. You can opt-out from receiving marketing communications from us by using the unsubscribe link at the bottom of each e-mail.

With Your Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

Other Purposes. We also use your personal information for other purposes as requested by you, as permitted by applicable law, or where we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Legal Bases for Processing. For explanations of our legal bases for processing in jurisdictions where this disclosure is required, see Section 15, Supplemental Notice for Certain Jurisdictions, below.

11. How We Share your Personal Data

Sharing to Provide ZChat and Services

• Your Posts and Public Profile. ZChat is a decentralized microblogging service where most user activity is public by design. This includes your posts, profile, likes, following, and blocks.
• Other Users You Share or Interact With. ZChat may allow you to share personal information, messages, or interact with other users.
• Third-party Services You Share or Interact With. ZChat may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use Third-party Services. If you do, the information you share will be subject to any Third-Party Service's privacy policy. For example, if you request that we share your personal information with a developer application or payment processor, we may facilitate the request.
• Service Providers. We may share Personal Data with our third-party service providers and vendors. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services. We use Cloudflare for traffic routing, security, and performance monitoring. Cloudflare may process technical data including IP addresses and browser information as a data processor on our behalf.
• Business Partners. We may share Personal Data with our business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Sharing to Protect Us or Others. We may access, preserve, and disclose any information we store if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement, regulatory, or national security requests and legal process, like a court order or subpoena; (ii) protect your, our, or others' rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation or prosecution of suspected or actual illegal activity.

Sharing with other Aureus Z Companies. We may share with parent or subsidiary companies to coordinate and manage our business, in accordance with the purposes set out in this Policy. These recipients will process Personal Data in the same way as set out in this Policy.

Sharing to obtain Professional Services. We may share Personal Data with our legal advisors, bankers, auditors, accountants, consultants, and insurers. Our professional advisors will process Personal Data as necessary to provide their services to us.

Sharing in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be processed as part of such a transaction.

12. International data transfers

We may transfer, process, and store all personal information we collect anywhere in the world. Different countries have different data protection laws.

If we transfer personal information from the European Economic Area, Switzerland, Brazil and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, we will do so (i) using appropriate safeguards; (ii) based on safeguards like the European Commission-approved, UK Government-approved, or Brazil’s Data Protection Authority Standard Contractual Clauses or Addenda; or (iii) otherwise in accordance with applicable data protection laws.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

13. Your Privacy Choices and Rights

Your Privacy Choices. The privacy choices you have about your Personal Data information are determined by applicable law and are described below.

• Email Communications. If you receive a marketing email from us, you may opt out by using the unsubscribe link at the bottom of such email. You will continue to receive transaction-related, non-promotional emails related to ZChat. You will not be opted out of those communications.
• Mobile Devices. We may send you push notifications through our App when you enable them. You may opt out from receiving these push notifications by changing the settings on your mobile device. We may collect precise location-based information via the App, but only if you permit us to do so. You may opt out of this collection by changing the settings on your mobile device.
• "Do Not Track". Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we currently do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, as there is no consistent industry standard for compliance.

Your Privacy Rights. Depending on what laws apply to your Personal Data, you may have the right to:

• Request Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (also known as the "right of data portability");
• Request Correction of your personal information where it is inaccurate, incomplete, or outdated. We may provide self-service tools for you to update your personal information;
• Request Deletion, Anonymization or Blocking of personal information including when processing is based on your consent, or when processing is unnecessary, excessive or noncompliant (also known as the "right to be forgotten");
• Request to Opt-Out of Certain Processing Activities if we engage in certain data processing activities that give you a right of opt-out under applicable privacy laws;
• Request Restriction of or Object to our processing of your personal information;
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal;
• Be Informed about third parties with which your personal information has been shared; and
• Request the Review of Decisions Taken Exclusively Based on Automated Processing if these decisions could affect your rights under applicable data protection laws.

Please contact us using the information in Section 18, Contact Us, if you would like to exercise any of these rights. We will process your requests in accordance with applicable laws. Before fulfilling your request, we may ask you to provide information to verify your identity. There are exceptions and limitations to each of these rights, and while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. Some laws may allow you to appeal our decision if we decline to process your request.

14. Retention of Personal Data

We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Backups are encrypted and retained on a rolling 30-day cycle, after which they are permanently and securely deleted.

15. Supplemental Notice for Certain Jurisdictions

If you live in a jurisdiction that requires specific disclosures about our legal bases for processing or other rights, these notices apply to you.

European Union / United Kingdom

Legal Bases for Processing: We rely on the following legal bases to process your personal information:

• Legitimate Interest: We process your personal information when we or a third party have a legitimate interest that is not overridden by your interests or fundamental rights and freedoms.
• Consent: In some cases, Aureus Z, Inc. may also rely on your consent to process your personal information.
• Compliance with our Legal Obligations: Aureus Z, Inc. may process your personal information to comply with our legal obligations, such as tax, labor, and accounting requirements.

Data Protection Officer: Aureus Z, Inc. has appointed a Data Protection Officer (DPO). You may contact our DPO at: [DPO_NAME], [DPO_ADDRESS], [DPO_EMAIL].

Data Protection Representative: Aureus Z, Inc. has appointed a Data Protection Representative (DPR) for both the UK and EU.

• You may contact our EU Representative at: [EU_DPR_NAME], [EU_DPR_ADDRESS], [EU_DPR_EMAIL].
• You may contact our UK Representative at: [UK_DPR_NAME], [UK_DPR_ADDRESS], [UK_DPR_EMAIL].

Brazil LGPD

This Supplemental Notice for Brazil's General Data Protection Law (Law No. 13.709/2018 – the "LGPD") only applies to our processing of personal data that is subject to the LGPD. For purposes of the LGPD, personal information means any information relating to an identified or identifiable individual.

If you are a user of ZChat App Services in Brazil, the below additional terms: (a) are incorporated into this Privacy Notice; (b) apply to your use of the ZChat App Services, and (c) supersede and control over any conflicts in the rest of the Privacy Notice to the extent of any inconsistency.

Legal bases. We guarantee that the processing of personal information subject to the LGPD by us will be always carried out in accordance with one of the legal bases that include: (1) your consent; (2) compliance with legal or regulatory obligations; (3) execution of a contract with you; (4) to exercise our rights in contracts or judicial, administrative or arbitral proceedings; (5) the protection of your – or third parties' – life and physical safety; (6) our legitimate interests; (7) credit protection; (8) prevention of fraud and the safety of the data subject in processes of identification and authentication.

Data Subject's Rights. In addition to the rights outlined in section 13 of this Privacy Notice, for purposes of the LGPD you also have the right to:

• Obtain confirmation that we process your personal information. In response to this request, we will inform you whether we process your personal information or not. Please note that, if you are a user, we necessarily process your personal information.
• Obtain information about the possibility of not providing your consent and the respective consequences. When consent is used as a legal basis for the processing of your personal information, you have the right to be informed about the possibility of not providing consent and the consequences of refusal.

16. Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.

17. Children's Personal Information

The ZChat App Services are not directed to children under 13 (or other age as required by local law outside of the United States). We do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us using the information provided below.

18. Contact Us

If you have any questions about this Privacy Policy, please contact us at contact@bapu.app.