Privacy Policy

Updated: 05/20/2025

This Privacy Policy ("Policy") governs how your personal information is collected, used, and protected when using the Zocia Application ("App"). The purpose of this Privacy Policy is to inform you about how App uses your personal data.

1. Definitions

In these Terms of Service, the following terms have the meanings set forth below:

• Application: Refers to the App mobile application, which can be downloaded from the Apple App Store and other official platforms.
• Terms of Service (TOS): Refers to the present Terms of Service.
• Member: A registered user of the Application, including both free and premium subscribers.
• Imitation Content: Any video or post created and published by Members that features voice, facial expressions, actions, or performance styles intended to imitate a specific individual, character, or aesthetic.
• Guess the Imitation: An interactive feature that allows Members to view Imitation Content and identify the person, character, or style being imitated, including through polls or other interactive tools.
• Like: An engagement action—represented by a special icon (such as a shining star or animated heart)—used to express strong appreciation or interest in another Member’s Imitation Content.
• Community Square: A public space within the Application where Members may publish Imitation Content, comment, like, participate in interactions, and discover trending or popular imitation performances.
• Chat: A private messaging function that enables Members to communicate via text, images, or voice after a mutual interaction occurs (e.g., through following or liking).
• Recommendation Feed: A personalized discovery section that suggests Imitation Content and other Members based on a user’s activity, preferences, and profile details.
• Profile Information: Details that Members provide about themselves, including nickname, interests, imitation specialties (e.g., voice, character, style), and profile photos. Members may modify this information or adjust privacy settings at any time.
• Services: All features—free or paid—provided by the Application to enable Members to create, share, explore, and interact with Imitation Content and with other Members.
• App Premium: A subscription tier that grants access to enhanced features, such as visibility into who liked your content, unlimited likes, performance analytics, and an ad-free experience.
• Account: A Member’s personal area within the Application, accessible upon registration and login, containing profile details, published content, interactions, and settings. Each Member is limited to a single Account.

2. Data Controller

App is extremely concerned about the protection of your personal data and respect for your privacy. The purpose of this privacy policy (along with our Terms of Service and any other document it refers to) is to inform you on the way we process the personal data you share with us and that we collect when you use the Application and Services. Please read this document carefully to better understand how we process your personal data, and to know your rights.

This Privacy Policy applies to all Services published by App that you use (with the exception of services supplied and operated by third parties, in which case, their privacy policy will apply).

3. Information We Collect

App collects and processes your personal data when you use the App application or communicate with App. This information may be provided directly by you or collected automatically.

Mandatory Data

• Identification Data: Such as username, and the phone number or email address you provided during registration (depending on your registration method).
• App Usage Data: Your activities and usage records within the App application.
• Technical Device Data: Including phone model, operating system version, device identifiers, and other technical information.
• Geolocation Data: Device location information, used to enhance service experience and functionality.
• In-App Communication Data: Messages and voice messages you send and receive within the application.
• Customer Service Data: Reports, requests, and related records submitted to App customer support.
• Purchase and Payment Information: Billing and transaction data related to purchases made within the App application.
• Biometric Data: Fingerprints, facial recognition, or other biometric data used for identity verification (only with your consent).

Optional Data

• Professional and Educational Background
• Interests and Lifestyle Information
• Member Characteristics
• Contact Information (Email address and/or phone number)

3.1 Data You Share Directly

When you use our Services, you share information with us, some of which may be used to identify you. When you communicate this information, you accept that some of the data will be visible to the other Members of the Application, and therefore made public on the Application.

3.1.1 Registration Data

Information Required for Registration: App offers two convenient registration methods: Quick Login and Apple ID Login. Users can register and access the service without filling in any additional information.

1. Quick Login: The system automatically recognizes the user’s identity through their phone number or device information, allowing access to the app without manually entering any personal details.
2. Apple ID Login: When users choose to log in with Apple ID, the relevant platform provides App with necessary data to simplify the registration process. By selecting Apple ID Login, users agree to share this data with App.

After registration, the system will automatically assign a default nickname and avatar to the user. Uploading a face photo or providing other personal information is not required. Users may modify their nickname and avatar at any time, but this is optional.

Optional information to complete your profile: You may add additional information to improve your profile. This information is optional, shared at your own discretion, and is your sole responsibility. This includes professional career, education, interests, habits, and a profile description. App does not encourage Members to share sensitive data (as defined by GDPR) but if a Member decides to share such information, it is deemed to have been clearly made public.

3.1.2 Data Relating to Interactions with App

When you contact customer support, report issues, or participate in surveys, App collects data such as the date/time of the report, nature of the report, and data relating to the reported user. Proof of identity may be requested for safety/confidentiality reasons.

3.2 Data We Collect Automatically

• Activity Data (Private): Registration date, login dates, online/offline status, interactions with Members, number of transactions, notifications received, etc.
• Geographical Positions: Collected with your express consent to allow App to identify crossing points with other Members. You may withdraw consent at any time by disabling geolocation.
• Messages: Sent and stored on App servers to provide the Service. Strictly private and only accessible to involved Members, except in cases of judicial requests.
• Technical Data: IP, mobile ID, application version, telephone version, OS, crashes, advertisement ID.
• Transaction Data: App does not collect banking data. Only technical data (e.g., transaction number) is exchanged with Apple/App Store to validate transactions. App retains a history of purchases but not payment method details.

4. How Do We Use Your Data?

4.1 Supply of Services and Features

To create and manage your Account, manage subscriptions, store messages, and send service-related notifications.

Legal Basis: Execution of the contract.

4.2 Suggest Members Based on Locations

To recommend content based on geographical location and activity.

Legal Basis: Consent (for location); Performance of a Contract (for personalization); Legitimate Interest (for relevant recommendations).

4.3 Improving and Optimizing Services

For statistical studies, satisfaction surveys, usage analysis, and providing advice on profile photos.

Legal Basis: Legitimate interest.

4.4 Guaranteeing Security

To detect or prevent security breaches and fraudulent behavior.

Legal Basis: Legitimate interest.

4.5 Preventing Illegal Activities & Ensuring Trust

To analyze reports, manage inappropriate behavior (warnings, bans), handle data rights requests, detect fraud, ensure content quality, and enhance platform security.

Legal Basis: Legitimate Interest.

4.6 Providing Help and Technical Support

To respond to support requests.

Legal Basis: Legitimate interest.

5. Exercising Your Rights Over Your Data

Every Member has the right to access, rectify, portability, removal, objection, limitation, and guidelines for data after death.

• Right to Access: Request data pertaining to you (excluding third-party privacy).
• Right to Correct: Demand correction of inaccurate or incomplete data.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Contest/Object: Object to data use for canvassing or processing based on legitimate interest.
• Right to Delete: Demand removal of data or delete your Account via the Application.
• Right to Limitation: Request temporary suspension of processing.
• Post-Mortem Guidelines: Set guidelines for data retention/deletion after death.

To exercise these rights, please contact us via email. Proof of identity may be requested.

6. How Long Will We Keep Your Data?

• Active Accounts: For the length of registration plus 24 months of inactivity. After 24 months of inactivity, the Account is deleted, and data is retained for another year before permanent destruction or anonymization.
• Banned Accounts: Retained in an active database for 24 months to prevent re-registration, then archived for one more year before deletion/anonymization.
• Deleted Accounts: Deleted from the Application immediately, but data is kept in a separate archive for one year to comply with host obligations.
• Marketing Data: Email/phone may be retained for 1 year after 24 months of inactivity for prospecting, unless the account was explicitly deleted by the user.

7. Personal Data of Minors

App shall not collect data from minors. If a minor fraudulently claims to be an adult, parents should contact App to request data deletion. App commits to deleting such data as soon as possible.

8. Contact

If you have any questions regarding this privacy policy or requests concerning your personal data, please contact us by sending an e-mail to:

Email: [email protected]