Privacy Policy

Effective date: July 7, 2026 · Last updated: July 7, 2026

This Privacy Policy explains how we collect, use, share, and protect personal data when you visit zaps.wtf, its subdomains, and any related content, features, and services (together, the "Service"). The data controller is:

1. Scope

This Policy covers the Zaps informational website and pre-release materials. When the Zaps application launches, additional or updated terms may apply and will be presented at that time. This Policy does not cover third-party services we link to, such as X (Twitter), Telegram, wallet software, or blockchain networks, which are governed by their own policies.

2. Data We Collect

• Usage and device data. When you visit the Service, our hosting and analytics providers process technical data such as IP address, approximate location derived from IP, browser and device type, operating system, referrer, pages viewed, and timestamps. This is collected through server logs and privacy-focused analytics.
• Data you send us. If you contact us (for example by email or Telegram), we receive the contact details and content you choose to share.
• Future application data. If you later connect an X account or link wallet addresses in the Zaps application, we will process your public X profile information and the public onchain activity of the linked addresses to provide the product's core features (call detection, attribution, scores, and leaderboards). We do not collect private keys and will never ask for them.

We do not knowingly collect special categories of personal data.

3. How We Use Data

• to operate, secure, and improve the Service;
• to measure aggregate usage and diagnose technical issues;
• to respond to your inquiries;
• to provide product features you request, such as reputation scoring and attribution, once the application is live;
• to comply with legal obligations and enforce our Terms of Service.

Where laws such as the EU or UK GDPR apply, our legal bases are: performance of a contract (providing the Service you request), legitimate interests (operating, securing, and improving the Service), consent where required (for example for non-essential cookies), and compliance with legal obligations.

4. Cookies and Similar Technologies

The Service uses only the minimum storage necessary for it to function and for privacy-respecting analytics. We do not run third-party advertising trackers. Where consent is legally required for any non-essential technology, we will request it.

5. Public Blockchain Data

Blockchain networks are public, decentralized systems that we do not control. Wallet addresses and transactions are visible to anyone and are immutable by design: they cannot be modified or deleted by us or by anyone else. When product features display or score onchain activity, they reflect data that is already public. Please consider this carefully before linking any address to an identity.

6. Sharing

We do not sell personal data. We share data only with:

• Service providers that host and operate the Service on our behalf (such as web hosting, content delivery, and analytics providers), bound by appropriate data protection obligations;
• Professional advisers and authorities where required to comply with law, enforce our rights, or protect the safety of any person;
• Corporate transactions, where data may be transferred as part of a merger, acquisition, or sale of assets, subject to this Policy.

7. International Transfers

We are established in the Republic of Panama and our providers may process data in other countries. Where required, we use appropriate safeguards for cross-border transfers, such as contractual data protection clauses.

8. Retention

We keep personal data only as long as necessary for the purposes above: server and analytics logs for short rotation periods, correspondence for as long as needed to handle the matter, and any future account data for as long as the account exists plus any period required by law. Public blockchain data is outside our control and persists indefinitely on the relevant network.

9. Security

We apply administrative, technical, and organizational measures appropriate to the risk, including encryption in transit, least-access principles, and reputable infrastructure providers. No system is completely secure; we cannot guarantee absolute security.

10. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or receive a copy of your personal data, to object to or restrict certain processing, to withdraw consent, and to lodge a complaint with a supervisory authority. To exercise any right, contact support@zeru.finance. We will respond within the period required by applicable law and may need to verify your identity. Note that data recorded on public blockchains cannot be erased by us.

11. Children

The Service is not directed at children and may not be used by anyone under 18. We do not knowingly collect data from children; if you believe a child has provided us data, contact us and we will delete it.

12. Changes to This Policy

We may update this Policy from time to time. The "Last updated" date above reflects the current version. Material changes will be flagged on the Service. Continued use after changes take effect constitutes acceptance.

13. Contact

Zeru Technologies Holdings Inc.
First Floor, Torre Advanced Building, Ricardo Arias Street, Republic of Panama
Registration number 155749616
support@zeru.finance