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Privacy Notice

Zulachat Privacy Notice (this “Notice”)

  • Introduction

Last modified [May 2026]

This Notice describes how we will collect, use, share and otherwise process your personal data in connection with your use of the “Zulachat” website (at https://zulachat.com), applications and related services (“Zulachat”).

Zulachat is not intended for children and we do not knowingly collect data relating to children.

Please read this Notice carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

We are Zula Technologies Limited, a company registered in Gibraltar under company number 124660 and with registered office at Suite 5, 39 Irish Town, Gibraltar GX11 1AA. In this Notice, Zula Technologies Ltd is referred to as “we”, “us” and “our”.

You can contact us at hello@zulachat.com.

As we are based outside of the UK, we have appointed Asserson Law Firm as our UK representative under the UK GDPR. You can contact our representative using the details below:

  • Full name of legal entity: Asserson Law Offices LLP
  • Name or title of contact person: Simon Weinberg
  • Email address: notifications@asserson.co.uk.
  • Postal address: Zula Technologies Limited, c/o Head of Data Protection, Asserson, Churchill House, 137-139 Brent Street, London, NW4 4DJ

You have the right to make a complaint at any time to us, the Information Commissioner's Office (ICO), being the UK regulator for data protection issues, and any other regulator for data protection from time to time.

Changes to this Notice and your duty to inform us of changes

We keep this Notice under regular review.

This version was last updated on 1st of May 2026. It may change and, if it does, those changes will be posted on this page and notified to you by push notification OR by email OR when you next use Zulachat. You may be required to read and acknowledge the changes to continue to use Zulachat.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. Please use the functionality in your Zulachat account to update your details.

Third party links and sites

Zulachat may, from time to time, contain links to and from the websites and applications of third parties, such as payment processors and social media pages. Please note that these websites and applications (and any services accessible through them) are controlled by those third parties and are not covered by this Notice. You should review their own privacy notices to understand how they use your personal data before you submit any personal data to these websites or applications, or use these services.

  • The data we collect about you

We collect, use, store and transfer different kinds of personal data about you. To make it easier for you to use this Notice, we group these into the following categories:

Identity Data

First name, last name and date of birth.

Contact Data

First name, last name, contact address, email address, your communication preferences and copies of the communications between you and us.

Profile Data

Your email address, username and password, and any information you add to your profile within Zulachat (including background information and photographs).

Device Data

The type of device you use, your unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, IP address and time zone setting.

Content Data

Information that you store or generate in Zulachat, being photos, videos and associated metadata, and messages.

Usage Data

Logs and detail of your use of Zulachat, being the dates and times on which you download, access and update Zulachat, any error or debugging information, and the content that you upload or access, comments you make, in-app transactions you undertake, rewards you earn, and the actions we and you take in relation to them and Cookies Data.

Security Data

Information we collect about your use of Zulachat in order to ensure your and our other users' safety and security, being Usage Data, certain Cookies Data and the information provided to us by our payment processing provider.

Cookies Data

The information collected through the cookies and similar technologies listed in our Cookie Notice.

Direct Marketing Data

Your direct marketing preferences, consents for receiving direct marketing from us and/or our third parties and the history of the direct marketing communications we have sent to you.

Social Media Data

Your social media account information that you share with us when creating or linking your Zulachat account.

Feedback Data

Your feedback and survey responses.

Program Data

Information about the prize pool programs you enter with us, being your program history, the applicable terms and conditions, content uploads and views, and rewards earnt.

We do not intentionally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). If you share any content through Zulachat that contains, refers to or otherwise shows special categories of personal data, you acknowledge that in doing so you will make that data available to the general public, and you do so at your own volition.

We may process data relating to criminal offences in monitoring the use of Zulachat for security purposes, and where we suspect you may have committed a crime, such as attempting to make a fraudulent purchase or claim, receive a fraudulent payout, or circumvent Zulachat’s security. In such circumstances we will provide that information to law enforcement authorities and/or use it to establish, exercise or defend a legal claim. According to the type of activity and purpose, we will rely on legitimate interests (protecting our business, employees and other users) and legal obligation (where required by legal, judicial or law enforcement to disclose or process that information) for such processing.

  • How is your personal data collected?

We collect your personal data in the following way:

  • Registration. We collect your Identity Data, Contact Data and Profile Data when you register your account with us.
  • Communications. We collect Content Data when you communicate with us. If you contact us through Zulachat, we also collect Device Data and Cookies Data to operate our chat function and respond to your messages. If the communication relates to an error or problem you are having with Zulachat, we will also collect Usage Data for diagnosis and improvement.
  • Information you generate when using Zulachat. Each time you access and use Zulachat, we collect Content Data, Device Data, Cookies Data and Usage Data. We collect Content Data where you upload it to Zulachat or interact with the content available on Zulachat. We collect Device Data, Cookies Data and Usage Data by automatically collecting it when you use the app, including through cookies and other similar technologies. Please see our Cookie Notice for further details.
  • Information we collect through monitoring the use of Zulachat. Each time you access and use Zulachat we collect information about that access and use, being Device Data, Content Data, Cookies Data and Usage Data.
  • Direct Marketing. We collect and record Direct Marketing Data when we add you to our marketing database, you request to change your direct marketing preferences, or you interact with our direct marketing communications.
  • Social Media Data. We collect Social Media Data when you choose to connect your social media account to your Zulachat account.
  • Information we receive from third parties and publicly available sources. We will receive personal data about you from the third parties and public sources, being [Device and Cookies Data from the following parties:

analytics providers [being PostHog] based in the United States;

advertising networks [such as Meta Platforms, Inc] based in [the United States]; and

search information providers [being Google LLC based in the United States]

Cookies

We use cookies (small files placed on your device) and other tracking technologies on Zulachat and in our direct marketing emails to improve your experience and our development of Zulachat. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Notice.

  • How we use your personal data

We will only use your personal data when we have a lawful basis to do so. Our lawful basis for each purpose for which we use your personal data is specified below. Most commonly we will use your personal data in the following circumstances:

  • Consent. Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by accessing you Zulachat account, using our cookie banner or contacting us.
  • Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.
  • Legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Recognised legitimate interests. We may sometimes use your personal data because we (or a third party) have a recognised legitimate interest (“RLI”). These are different to legitimate interests. RLIs apply where there are public interest reasons for processing (such as preventing or detecting crime, safeguarding individuals, responding to emergencies, supporting national or public security or defence, or sharing information with public bodies when they confirm it is necessary for their official functions). RLIs are legally recognised within data protection law. Where we rely on an RLI, we will ensure the use is strictly necessary and only use or share the minimum data required.
  • Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.

Use of personal data:

Delivery and improvement of Zulachat and purchases

Purpose or activity

Type of personal data

Lawful basis for processing

To permit you to install Zulachat and register you as a new user

Identity

Contact

Profile

Device

Social Media

Performance of a contract

To take steps towards providing you with services at your request, to process and fulfil in-app purchases and deliver services to you, including managing payments and sending you service communications

Identity

Contact

Usage

Device

Content

Program

Performance of a contract

Enforce our terms and conditions, including to collect money owed to us

Identity

Legitimate interests (to recover debts due to us)

Use of personal data:

Account management and profiling

Purpose or activity

Type of personal data

Lawful basis for processing

Combining the information we collect about you into a single user account profile

Identity

Contact

Profile

Direct marketing

Legitimate Interests (to publicise and grow our business)

Use of personal data:

Direct marketing

Purpose or activity

Type of personal data

Lawful basis for processing

To send you direct marketing communications via email, text and/or push notification

Contact

Device

Direct Marketing

Consent

Unless we can rely on the soft opt-in and you have not opted out, in which case we rely on Legitimate Interest (to publicise and grow our business)

Use of personal data:

Troubleshooting, improvement and security

Purpose or activity

Type of personal data

Lawful basis for processing

To administer, monitor and improve our business and Zulachat, including troubleshooting, data analysis and system testing

Identity

Contact

Device

Usage

Security

Feedback

Legitimate interests (for running our business, provision of administration and IT services, network security, maintaining the security of Zulachat, providing a secure service to users and preventing fraudulent and other misuse of Zulachat)

Applying security measures to our processing of your personal data, including processing in connection with Zulachat

All personal data under this Notice

Legal obligation (applying appropriate technical and organisational measures under Article 32 of the UK GDPR and other applicable data protection laws)

Otherwise monitoring use of Zulachat and deploying appropriate security measures

Contact

Security

Legitimate interests (running our business, provision of administration and IT services, network security, maintaining the security of Zulachat, providing a secure service to users and preventing fraudulent and other misuse of Zulachat)

Use of personal data:

Rights and obligations

Purpose or activity

Type of personal data

Lawful basis for processing

To comply with our other legal obligations, including compliance with tax legislation, judicial, law enforcement and government authorities' requests

All personal data under this Notice

Complying with our legal obligation

Recognised legitimate interests

Use of personal data:

Cookies and personalisation

Purpose or activity

Type of personal data

Lawful basis for processing

To deploy and process personal data collected via Cookies that are strictly necessary, as set out in our Cookie Notice

Cookies

Legitimate interests (delivering and securing Zulachat)

To deploy and process personal data collected via Cookies that are not strictly necessary, as set out in our Cookie Notice

Cookies

Consent

Use of personal data:

Other communications

Purpose or activity

Type of personal data

Lawful basis for processing

To notify you of changes to Zulachat, your purchases and our terms and conditions for ongoing contracts

Contact

For ongoing or prospective contracts, Performance of a contract

Otherwise, Legitimate interests (in servicing our users and prospective users)

To notify you of updates to this Notice

Contact

Legal obligation (to inform you of our processing under Articles 13 and 14 of the UK GDPR)

To respond to your requests to exercise your rights under this Notice

As relevant to your request

Legal obligation (complying with data subject requests under Chapter 3 of the UK GDPR)

To enable you to participate in a prize pool program (where applicable)

Contact

Direct Marketing

Program

Legitimate interests (in growing and publicising our business)

Unless you have previously opted out, where we will rely on Consent

Performance of a contract (once you have entered)

To ask you to complete a survey and process your response

Contact

Feedback

Legitimate interests (to analyse how users use Zulachat and to develop Zulachat and grow our business)

Unless you have previously opted out, where we will rely on Consent

To otherwise respond to your enquiries, fulfil your requests and to contact you where necessary

As relevant to your enquiry or request

Legitimate interests (service our users and prospective users)

Use of personal data:

Personal data sharing

Purpose or activity

Type of personal data

Lawful basis for processing

Share personal data with our third-party providers for purposes not otherwise set out above (see paragraph ‎5 below)

Contact

Feedback

Social Media Handles

Legitimate interests (for the purpose relevant to the recipient, as set out at "Disclosures of your personal data”)

Automated decision making and profiling

We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

  • Disclosures of your personal data

We may share your personal data with the following external third parties:

  • Your Appstore provider and mobile network operator to allow you to install Zulachat.
  • Service providers, acting as processors, based in Gibraltar, the United States and Romania who provide IT and system administration services, hosting services for Zulachat, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.
  • Our professional advisors acting as controllers based in Gibraltar, Israel and Romania including lawyers, auditors, insurers and consultants who provide legal, accounting, insurance and other services.
  • Your service providers that you have appointed and we need to contact to fulfil your requests, such as your banking or payment card provider to process your transactions.
  • Third party partners where you have expressly subscribed to receive marketing from or with them.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.
  • HM Revenue and Customs, regulators, law enforcement, public authorities or other third parties acting as controllers based in the UK and elsewhere, where necessary to exercise our rights or comply with a legal obligation.

You also acknowledge that, where you create a profile within, and add content to, Zulachat, other users within Zulachat will have access to, and be able to view, your profile and that content.

  • International transfers

Whenever we transfer your personal data out of the UK, the EEA or Gibraltar, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers located outside the UK, the EEA or Gibraltar, we use specific contracts approved by the UK which give personal data the same protection it has in the UK, EEA and Gibraltar.

Please contact hello@zulachat.com if you want further information on the specific mechanism used by us when transferring your personal data out of the UK, the EEA or Gibraltar.

  • Data security

All information you provide to us is stored on our secure servers and located in the United States and Romania. Any payment transactions carried out by us or our chosen third-party provider of payment processing services, [SideShift], will be encrypted using [Secured Sockets Layer (SSL) technology]. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Zulachat, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to protect your personal data from loss, unauthorised use or access.

We have put in place procedures to detect and respond to personal data breaches and notify you and any applicable regulator when we are legally required to do so.

  • Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

In some circumstances you can ask us to delete your data: see paragraph ‎9 below for further information.

Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you do not use Zulachat for a period of 12 months, then we will treat the account as expired and will delete your personal data.

  • Your legal rights

You have the following rights under data protection laws in relation to your personal data.

  • Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
  • Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us.)
  • Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we need to erase your personal data to comply with law. (In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.)
  • Objection. Object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
  • Restriction. Request that we restrict or suspend our processing of your personal data:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Data portability. Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract.
  • Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Complain to us. If you are unhappy with how we process your personal data, please contact us first using the details below so that we have the chance to put it right. Under the UK GDPR, you may also have the right to make a complaint to us, which can be made via support@zulachat.com. We will deal with all complaints in line with our complaints procedure, including to keep you informed about the progress and outcome of your complaint.
  • Complain to the data protection regulator. If you are unhappy with how we process your personal data, we ask that you contact us first, as described above so that we have the chance to put it right. However, you also have the right to make a complaint to the ICO in the UK, and any other data protection regulator at any time.

You can exercise any of these rights at any time by contacting us at support@zulachat.com.