Privacy Policy for Zeva
Last Updated: February 3, 2026 | Effective Date: February 3, 2026
1. Introduction
This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal information by Zeva ("we", "us", "our"), a mobile application owned and operated by Zeva Park ("Company"). This Policy applies to all users of the Zeva application ("App") who are 18 years of age or older, and who access or use the App from locations worldwide excluding the People's Republic of China.
By accessing or using the Zeva App (including any in-app purchase features), you confirm that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Policy. If you do not agree with this Policy, you must immediately cease all use of the App.
2. Applicable Laws and Regulations
We adhere to all applicable global data protection and privacy laws, including but not limited to:
- General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) for users in the European Economic Area (EEA), United Kingdom, and Switzerland;
- California Consumer Privacy Act (CCPA/CPRA) for users in California, United States;
- Personal Information Protection and Electronic Documents Act (PIPEDA) for users in Canada;
- Australian Privacy Principles (APPs) under the Privacy Act 1988 for users in Australia;
- Apple App Store Review Guidelines (specifically regarding in-app purchase privacy and transparency);
- Other regional privacy laws applicable to users in jurisdictions where the App is distributed (excluding China).
2.1 GDPR Compliance for EEA Users
For users located in the EEA, we fully comply with all GDPR requirements, including the right to access, rectify, erase, restrict processing, data portability, and object to processing of your personal data (including purchase data). Detailed information about these rights is provided in Section 9 of this Policy.
Our legal basis for processing personal data under GDPR includes: (a) your consent for specific processing activities; (b) the performance of a contract with you (including processing purchase data); (c) compliance with legal obligations; and (d) our legitimate interests (where such interests do not override your fundamental rights and freedoms).
3. Information We Collect
3.1 Personal Information
We collect personal information that you voluntarily provide to us, or that is generated through your legitimate use of the App (including in-app purchases), including:
- Contact information (e.g., email address if you register an account, submit support requests, or opt-in to communications);
- Device information (e.g., device model, operating system version, unique device identifiers, IP address, language settings);
- Usage data (e.g., features used, interaction history, session duration, app settings, content viewed);
- User-generated content (as defined in Section 7 of this Policy);
- Communication data (e.g., messages sent/received within the App, interaction metadata, timestamps);
- Purchase-related data (e.g., in-app purchase IDs, product names, transaction dates, subscription status – no financial data).
3.2 Non-Personal Information
We collect anonymized, aggregated data that cannot be used to identify you individually, including:
- App performance metrics (e.g., crash reports, load times);
- Aggregated usage trends (e.g., most used features, geographic usage patterns in anonymized form);
- Aggregated purchase trends (e.g., most purchased items in anonymized form);
- Demographic data in aggregated form only (no individual user attributes).
4. How We Use Your Information
We use collected information solely for the following legitimate business purposes, and only to the extent necessary to fulfill these purposes:
- To provide, maintain, and improve the core functionality of the Zeva App (including in-app purchase features);
- To facilitate user-to-user interactions and community features within the App;
- To process and fulfill in-app purchases (e.g., activate premium features, manage subscriptions);
- To personalize your user experience and deliver relevant content (including premium content);
- To respond to your support requests, inquiries, and feedback (including purchase-related inquiries);
- To enforce our Terms of Service and this Privacy Policy;
- To comply with legal obligations and protect our rights, privacy, safety, or property (and that of our users);
- To analyze anonymized usage patterns to optimize App performance and user experience;
- To send important service notifications (e.g., App updates, security alerts, subscription renewals).
5. In-App Purchase (IAP) Privacy
5.1 Payment Processing
All in-app purchases (including one-time purchases, consumables, non-consumables, and subscriptions) are processed exclusively through the Apple App Store payment system. We do not collect, store, process, or have access to any of your financial information, including:
- Credit/debit card numbers;
- Billing addresses;
- Apple ID credentials;
- Payment authentication data (e.g., CVV codes, PINs);
- Bank account information.
Apple handles all payment processing, and their privacy policy applies to your payment information: https://www.apple.com/legal/privacy/en-ww/.
5.2 Purchase Data We Collect
We only collect non-financial purchase data provided by Apple to verify and manage your purchases, including:
- Unique purchase identifiers (provided by Apple);
- Names and descriptions of purchased products/subscriptions;
- Transaction dates and times;
- Subscription status (active, expired, canceled, renewed);
- Refund status (notified by Apple);
- Device identifiers associated with purchases (to enable purchase restoration).
5.3 Use of Purchase Data
We use purchase data solely to:
- Activate and maintain access to premium features, content, or subscriptions;
- Restore purchases if you reinstall the App or use it on another device linked to your Apple ID;
- Respond to your inquiries about purchases, refunds, or subscriptions;
- Comply with Apple's purchase verification and refund requirements;
- Prevent unauthorized access to premium features (e.g., fraud detection);
- Generate anonymized purchase analytics (no individual user data).
5.4 Subscription Management and Refunds
You can manage your subscriptions (e.g., cancel, renew, change plans) directly through your Apple ID settings (Settings > [Your Name] > Subscriptions). We do not have access to your Apple ID or subscription management controls.
All refund requests for in-app purchases are handled exclusively by Apple in accordance with their refund policy: https://support.apple.com/en-us/HT204084. We do not process or approve refunds directly, but we will revoke access to premium features/subscriptions if Apple processes a refund for your purchase.
5.5 Purchase Data Retention
We retain purchase data for the following periods:
- For one-time purchases: 2 years from the transaction date (to enable purchase restoration and comply with Apple's record-keeping requirements);
- For subscriptions: For the duration of the subscription plus 12 months after expiration/cancellation (to manage subscription status and respond to user inquiries).
6. Data Storage and Security
We store your personal information, purchase data, and UGC on secure servers protected by industry-standard security measures, including:
- End-to-end encryption for sensitive user communications;
- Transport Layer Security (TLS 1.3) for all data transmission;
- Access controls and authentication protocols to prevent unauthorized access;
- Regular security audits and vulnerability assessments;
- Encryption of stored purchase data (at rest).
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Policy, or as required by applicable law. When data is no longer needed, we securely delete or anonymize it using industry-standard methods to prevent recovery.
7. User-Generated Content (UGC)
7.1 Definition of UGC
User-Generated Content ("UGC") refers to any and all content that you create, submit, post, share, transmit, upload, or display through the Zeva App (including premium/paid sections), including but not limited to:
- Text content (messages, comments, profile descriptions, posts);
- Visual content (photos, videos, GIFs, images, screenshots);
- Audio content (voice messages, audio recordings);
- Any other media or materials uploaded or shared through the App's features (free or premium).
7.2 UGC Ownership and License
You retain full ownership of your UGC. By submitting UGC to the Zeva App (including premium/paid sections), you grant us a worldwide, non-exclusive, royalty-free, transferable license to use, reproduce, display, distribute, and store your UGC solely to:
- Transmit and display the UGC to other users as intended by you;
- Store the UGC for your access and use within the App;
- Moderate and enforce compliance with our content policies;
- Operate and maintain the App's core features (free and premium).
We do not claim ownership of your UGC and will not use your UGC for commercial purposes (e.g., advertising, third-party distribution) without your explicit written consent.
7.3 Prohibited UGC Content
You are strictly prohibited from creating, submitting, posting, or sharing any UGC (in any section of the App, including premium/paid features) that violates applicable laws, our Terms of Service, or this Policy. Prohibited content includes, but is not limited to:
- Sexually Explicit Content ("Yellow Content"): Any material containing pornography, adult content, sexually explicit images/videos, depictions of sexual acts, non-consensual sexual content, or nudity (excluding medical, educational, or artistic content with legitimate purpose);
- Distressing/Offensive Content: Content that is grossly violent, graphic, hateful, or causes significant discomfort, distress, or harm to other users (e.g., depictions of self-harm, suicide, physical violence, torture, death, or extreme gore);
- Gambling-Related Content: Content that promotes, facilitates, advertises, or links to gambling, betting, lotteries, online casinos, sports wagering, poker rooms, or any form of monetary gambling activity (including crypto gambling);
- Drug-Related Content: Content that promotes, facilitates, or depicts the use, sale, distribution, manufacturing, or procurement of illegal drugs, narcotics, controlled substances, prescription drugs (used without authorization), drug paraphernalia, or psychoactive substances;
- Political Content: Content that promotes political parties, political candidates, political campaigns, lobbying efforts, or controversial political issues that may incite unrest, division, hatred, or harm to individuals or groups;
- Discriminatory/Hateful Content: Content that is discriminatory, hateful, harassing, or abusive based on race, ethnicity, national origin, gender, gender identity, sexual orientation, religion, disability, age, socioeconomic status, or any other protected characteristic under applicable law;
- Illegal or Harmful Content: Content that promotes illegal activities, terrorism, hate crimes, violence against individuals or groups, human trafficking, or that violates third-party rights (copyright, trademark, privacy, publicity, or intellectual property rights);
- Fraudulent/Misleading Content: Content that is false, deceptive, misleading, or constitutes phishing, scams, identity theft, misinformation, or disinformation;
- Purchase Abuse Content: Content that promotes in-app purchase fraud, refund abuse, account sharing, or unauthorized access to premium features/subscriptions.
7.4 UGC Moderation and Enforcement
We reserve the right to review, moderate, screen, remove, or disable access to any UGC that violates this Policy or our Terms of Service (including UGC in premium/paid sections), at our sole discretion and without prior notice to you.
We may take disciplinary action against users who post prohibited UGC, including:
- Removal of the offending UGC;
- Temporary suspension of account features (including premium features);
- Permanent suspension or termination of your account (including revocation of premium features/subscriptions with no refund);
- Reporting of illegal activity to relevant law enforcement authorities.
We do not pre-screen all UGC (given the volume of user content), but we maintain a dedicated moderation team that responds to reports of violating content within 24 hours of receipt. We are not liable for any prohibited UGC posted by users, but we take reasonable steps to remove such content when identified.
For premium users, violation of UGC rules may result in permanent account suspension and forfeiture of all purchased features/subscriptions (no refunds will be provided).
8. Data Sharing and Disclosure
We do not sell, rent, lease, or trade your personal information (including purchase data) to third parties for commercial purposes. We may share your information only in the following limited circumstances:
- With your explicit, voluntary consent;
- To comply with legal obligations (e.g., court orders, subpoenas, regulatory requests);
- To protect our rights, privacy, safety, or property (and that of our users);
- With trusted service providers who assist us in operating the App (e.g., cloud hosting providers, analytics services), who are bound by strict confidentiality agreements and can only process data on our behalf;
- With Apple to verify in-app purchases, process subscription status updates, or comply with App Store policies (only non-financial purchase data);
- In connection with a merger, acquisition, or sale of all or a portion of our assets (we will notify you before your personal information is transferred and becomes subject to a different privacy policy).
9. User Rights (Including GDPR Rights)
For all users, and in full compliance with GDPR for EEA users, you have the following rights regarding your personal information (including purchase data):
- Right to Access: Request a complete copy of the personal information (including purchase data) we hold about you;
- Right to Rectification: Request correction of inaccurate, incomplete, or outdated personal information;
- Right to Erasure ("Right to be Forgotten"): Request deletion of your personal information (subject to legal retention requirements and Apple's purchase record rules);
- Right to Restrict Processing: Request that we stop processing your personal information (temporarily or permanently);
- Right to Data Portability: Request a copy of your personal information (including purchase history and UGC) in a structured, commonly used, machine-readable format;
- Right to Object: Object to processing of your personal information for legitimate business purposes (we will cease processing unless we can demonstrate compelling legitimate grounds);
- Right to Withdraw Consent: Withdraw any consent you have provided for data processing (where processing is based on consent).
To exercise any of these rights, please contact us at the email address provided in Section 11. We will respond to all valid requests within 30 days (or within the timeframe required by GDPR/other applicable laws) and will not charge you for complying with your request (unless the request is excessive or unfounded).
10. User Eligibility
The Zeva App (including in-app purchase features) is intended for use by individuals who are 18 years of age or older. We do not knowingly collect personal information from minors under the age of 18, and we do not process in-app purchases from minors.
If we become aware that we have collected personal information from a minor, we will immediately take steps to delete such information, terminate the minor's account, and coordinate with Apple to refund any unauthorized purchases. If you believe that we may have collected information from a minor, please contact us immediately at the email address provided below.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or App functionality (including in-app purchase features). We will notify you of any material changes by:
- Posting the updated Policy on the App with the new "Last Updated" date;
- Sending a notification to your registered email address (if applicable);
- Displaying a prominent notice within the App.
Your continued use of the Zeva App (including in-app purchase features) after any changes to this Policy constitutes your acceptance of the revised Policy.