Privacy Policy

Effective as of August 21, 2026.

Tradehub LLC ("Zennbot", "we", "us" or "our") provides Zennbot, an automated trading app together with related educational content, tools and community (accessible from zennbot.com, its subdomains and related apps). This Privacy Policy describes how we process personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities and other activities described in this Privacy Policy (collectively, the "Service").

Notice to European users: Please see the Notice to European users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe", and "European" should be understood accordingly) below.

Personal information we collect

Information you provide to us

Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, email address, phone number, and billing and mailing addresses.
• Demographic data, such as your city, state, country of residence, and postal code.
• Profile data, such as the username and password that you may set to establish an online account on the Service, your preferences, and any other information that you add to your account profile.
• Communications data based on our exchanges with you, including when you contact us through the Service, by email, via our community channels, social media, or otherwise.
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers, subscription details and transaction history.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Payment data needed to complete transactions, including payment card information. Payment card information is collected and processed directly by our payment processor (see How we share your personal information below); we do not store your full payment card details on our own systems.
• User-generated content and input data, such as trading strategies, presets, configurations, comments, questions, messages, reviews, testimonials, images, videos and other content or information that you generate, transmit, or otherwise make available on the Service or in our community channels, as well as associated metadata.
• Promotion data, including information you share when you enter a competition, promotion or complete a survey.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources

We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as social media platforms and other publicly available sources.
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Third-party services, such as Discord, that you use to join our community or otherwise link to your use of the Service. This data may include your username and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
• Business transaction partners, in connection with an actual or prospective business transaction such as a merger, acquisition, sale of assets, or similar transaction.

Automatic data collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access.
• Communication interaction data, such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) — we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section and our Cookie Notice below.

Tracking & other technologies

Cookies and other technologies. Some of our automatic data collection is facilitated by cookies and other technologies. For more information, see our Cookie Notice below. The specific tracking technologies we use on the website include:

• Meta Pixel: Provided by Meta Platforms. It allows us to measure the effectiveness of our advertising, track conversions (such as signups) and build advertising audiences. The Meta Pixel may set cookies and collects usage data such as the pages you visit, your IP address and browser information. For more information, see Meta's Privacy Policy at https://www.facebook.com/privacy/policy and manage your ad preferences at https://www.facebook.com/adpreferences.
• Google Tag Manager: Provided by Google. It loads measurement and marketing tags on the website, including tags used to measure advertising conversions. These tags may set cookies and collect usage data such as the pages you visit, your IP address and browser information. For more information, see Google's Privacy Policy at https://policies.google.com/privacy and manage your ad settings at https://adssettings.google.com.
• Senja: We embed testimonial widgets provided by Senja. When these widgets load, Senja may receive usage data such as your IP address and browser information.
• First-party marketing cookies: We may set first-party cookies for purposes such as attributing your visit or signup to the marketing campaign that brought you to the website. These cookies are not shared with third parties for their own purposes.

AI technologies. We use service providers, such as CodeRabbit, that employ artificial intelligence technologies to operate AI assistant features of the Service and to help us build and maintain the Service. These providers may process personal information contained in requests handled by the AI assistant or in development data (such as logs and diagnostic data) to facilitate the provision of the Service. We require these providers to maintain appropriate data protection safeguards.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section of our Cookie Notice.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations

We may use your personal information to:

• provide the Service;
• enable security features of the Service;
• establish and maintain your user account on the Service;
• process your orders and payments, and perform our contract with you, including the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events, promotions or contests in which you participate; and
• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization

We may use your personal information to understand your needs and interests, personalize your experience with the Service and our Service-related communications, and remember your selections and preferences as you navigate webpages.

Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For more information on analytics, see our Cookie Notice.

Marketing and advertising

We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications, such as news, special offers and product updates, and may personalize these messages based on your needs and interests. You may opt out of our marketing communications as described in the Your choices section below and in our Anti-Spam Policy.
• Interest-based advertising and attribution. We, our service providers, and third-party advertising partners (such as Meta and Google) may use cookies and other technologies to collect information about your interaction with the Service, our communications and other online services over time, and use that information to measure the effectiveness of our marketing campaigns, attribute signups to the correct campaign, and serve online ads that we or they think will interest you. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice.

Events, promotions and contests

We may use your personal information to administer promotions and contests, communicate with you about promotions or contests in which you participate, and contact or market to you after collecting your personal information at an event.

Compliance and protection

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Aggregated, de-identified and/or anonymized data

We may create aggregated, de-identified and/or anonymized data from your personal information and that of other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including analyzing and improving the Service and promoting our business.

Further uses

In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which the information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer time periods. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection). We never sell, rent or share your contact information with third parties for their own marketing purposes.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business. We currently share personal data with the following providers ("subprocessors"), each of which processes data on our behalf and only receives the data necessary for its purpose:

• Stripe (Stripe, Inc., USA) — payment processing. Receives your name, email address, billing address and payment details. Stripe may use your payment data in accordance with its privacy policy at https://stripe.com/privacy. We do not store your full payment card details on our own systems.
• GoHighLevel (HighLevel Inc., USA) — customer relationship management, signup forms, and email and SMS communications. Receives your name, email address, phone number and communication preferences.
• Sentry (Functional Software, Inc., USA) — error monitoring and diagnostics. Error reports may contain personal information such as your IP address, device and browser information and account identifiers.
• CodeRabbit (CodeRabbit, Inc., USA) — development and code review tooling used to build and maintain the Service, and AI assistant features of the Service. May process personal information related to customers that is contained in development data (such as logs and diagnostic data) or in requests handled by the AI assistant.
• Slack (Slack Technologies, LLC, USA) — internal support and operational notifications. Messages may contain personal information related to your account and support requests.
• Discord (Discord Inc., USA) — community access. Receives your Discord username only.
• Meta (Meta Platforms) — advertising and conversion tracking via the Meta Pixel. Receives usage and tracking data such as pages visited, IP address and cookie identifiers.
• Google (Google LLC) — tag management, analytics and advertising measurement via Google Tag Manager. Receives usage and tracking data such as pages visited, IP address and cookie identifiers.
• Senja (Senja) — testimonial widgets embedded on the website. Receives usage data such as your IP address and browser information when the widgets load.
• Cloudflare (Cloudflare, Inc., USA) — website hosting, content delivery and security. Processes IP addresses and request logs of all visitors.

These providers are only permitted to process your personal data for the purposes described above and are bound by their own privacy and data protection obligations. We may update this list from time to time as our providers change; the current list is always available on this page.

Advertising partners. Third-party advertising companies (such as Meta and Google) for the interest-based advertising and attribution purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions or with whom we jointly offer products or services.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above, including to comply with a legal obligation, protect and defend our rights or property, prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of users of the Service or the public, or protect against legal liability.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in, or financing of, Tradehub LLC, or the sale, transfer or merger of all or part of our business, assets or shares), and to an acquirer, successor, or assignee of Tradehub LLC as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership. We will provide notice before your personal data becomes subject to a different privacy policy.

Other users and the public. Content that you post in the public channels of our community (such as our Discord server), reviews and testimonials you provide, and other user-generated content you choose to make public may be visible to other users of the Service and the public. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Marketing communications

When you create an account or sign up through a form on the website, you agree that we may send you marketing emails about the Service, such as news, special offers and product updates. You can withdraw this consent and opt out of marketing communications at any time, free of charge, by using the unsubscribe link included in every marketing email or by contacting us at support@zennbot.com. Opting out does not affect transactional or service emails (such as billing, security and service notifications), which we may continue to send as necessary to provide the Service. We never sell, rent or share your contact information with third parties for their own marketing purposes — see also our Anti-Spam Policy.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe and certain U.S. states can find additional information about their rights below.

• Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
• Opt-out of communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at support@zennbot.com. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Cookies and other technologies. For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Notice.
• Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
• Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals.
• Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
• Linked third-party platforms. If you choose to connect to the Service through a third-party platform such as Discord, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
• Delete your account. If you wish to request to close your account or delete your personal information, please contact us at support@zennbot.com.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United Arab Emirates and use service providers that operate in the United States and other countries. Your personal information may be transferred to the United Arab Emirates, the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Several of our subprocessors listed above are located in the United States or other countries outside the European Economic Area. Where we transfer personal data of European residents to such countries, we rely on safeguards recognized under the GDPR, such as adequacy decisions (including the EU-U.S. Data Privacy Framework, where the provider is certified) or standard contractual clauses. Users in Europe should read the important information provided in the Notice to European users section about transfer of personal information outside of Europe.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service, and, where appropriate, via email and/or a prominent notice on the Service prior to the change becoming effective. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy related right that may be available to you, please contact us via one of the methods listed below. We will respond to your request within one month. We may ask you to verify your identity before acting on your request.

• Email: support@zennbot.com
• Mail: Tradehub LLC, Business Centre, Sharjah Publishing City Free Zone, Sharjah, United Arab Emirates

Cookie Notice

This Cookie Notice explains how Tradehub LLC ("Zennbot", "we", "us" or "our") uses cookies and similar technologies in connection with the zennbot.com website and any other website that we own or control and which posts or links to this Cookie Notice (collectively, the "Sites").

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience.

Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).

We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third-party cookies, which are served by service providers or business partners on our Sites, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third-party cookies can be used for a variety of purposes, including site analytics, advertising, and social media features.

What types of cookies and similar tracking technologies do we use on the Sites?

On the Sites, we use cookies and other tracking technologies in the categories described in the table below.

Other technologies

In addition to cookies, our Sites may use other technologies, such as pixel tags, to collect information automatically.

Browser web storage. We may use browser web storage (including via HTML5), also known as locally stored objects ("LSOs"), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. Your web browser may provide functionality to clear your browser web storage.

Web beacons. We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and in our HTML formatted emails to track the actions of users on our Sites and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Sites, so that we can manage our content more effectively.

Your choices

Your options for controlling what information cookies and similar technologies collect about you include:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
• Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
• Third-party opt-out options. You can opt out of interest-based advertising by Meta at https://www.facebook.com/adpreferences and by Google at https://adssettings.google.com.
• Industry association opt-outs. You may opt out of receiving interest-based advertising on websites through members of the Network Advertising Initiative at https://optout.networkadvertising.org or the Digital Advertising Alliance at https://optout.aboutads.info. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms linked above.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

If you choose to opt out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed. You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

For more information about how we collect, use and share your information, see the Privacy Policy above. Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes. If you have any questions about this Cookie Notice, please contact us by email at support@zennbot.com.

Notice to European users

General

Where this Notice to European users applies. The information provided in this "Notice to European users" section applies only to individuals in the United Kingdom and the European Economic Area (i.e., "Europe" as defined at the top of this Privacy Policy).

Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" (as defined in the GDPR) — i.e., information about individuals from which they are either directly identified or can be identified.

Controller. Tradehub LLC is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU General Data Protection Regulation and the so-called 'UK GDPR' (as and where applicable, the "GDPR")). See the How to contact us section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below.

• Where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity").
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests").
• Where we need to comply with a legal or regulatory obligation ("Compliance with Law").
• Where we have your specific consent to carry out the processing for the purpose in question ("Consent").

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information — for more information on these purposes and the data types involved, see How we use your personal information.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for compliance and protection purposes. To determine the appropriate retention period, we consider the factors described in the Retention section above.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide us with any sensitive personal information when you use the Service, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling which produces legal or similarly significant effects.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information where there is no good reason for us continuing to process it — you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
• Object. Object to our processing of your personal information where we are relying on Legitimate Interests — you also have the right to object where we are processing your personal information for direct marketing purposes.
• Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising these rights. You may submit these requests by email to support@zennbot.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. We will respond to your request within one month. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information); if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your right to lodge a complaint with your supervisory authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. For users in the European Economic Area, the contact information for the data protection regulator in your place of residence can be found here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. For users in the UK, the contact information for the UK data protection regulator is: The Information Commissioner's Office, Water Lane, Wycliffe House, Wilmslow — Cheshire SK9 5AF; Tel. +44 303 123 1113; Website: https://ico.org.uk.

Data processing outside Europe

We are a company based in the United Arab Emirates and many of our service providers, advisers, partners or other recipients of data are based in the United States. This means that, if you use the Service, your personal information will necessarily be accessed and processed outside Europe. It may also be provided to recipients in other countries outside Europe.

It is important to note that neither the United Arab Emirates nor the United States is the subject of a general 'adequacy decision' under the GDPR — basically, this means that these countries' legal regimes are not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

• Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time). This includes transfers to U.S. providers that are certified under the EU-U.S. Data Privacy Framework.
• Transfers to territories without an adequacy decision. We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection. However, in these cases, we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe — for example, standard-form contracts approved by relevant authorities for this purpose (standard contractual clauses); or, in limited circumstances, we may rely on an exception, or 'derogation', which permits us to transfer your personal information to such country despite the absence of an 'adequacy decision' or 'appropriate safeguards' — for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at support@zennbot.com.

Notice to users in the United States

We are based in the United Arab Emirates and do not direct the Service specifically at residents of the United States. Except as otherwise provided, this section applies only to residents of U.S. states, and only to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the "State Privacy Laws").

This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. To verify your identity, we may ask you to confirm information associated with your account, such as the email address you used to sign up and recent account activity.

For purposes of this section, the term "Personal Information" has the meaning given to "personal data", "personal information" or other similar terms and "Sensitive Personal Information" has the meaning given to "sensitive personal information," "sensitive data", or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws.

Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.

• Information. You can request information about how we have collected and used your Personal Information, including the categories of Personal Information collected, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with which we share Personal Information.
• Access. You can request a copy of the Personal Information that we have collected about you.
• Appeal. You can appeal our denial of any request validly submitted.
• Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of targeted advertising. We may process Personal Information (such as cookie identifiers, device data and online activity data) for targeted advertising purposes through our advertising partners. You can opt out of such processing as described below.
• Profiling/automated decision-making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.
• Sales of personal data. We do not sell your Personal Information for money.
• Sensitive Personal Information. We do not intentionally collect or process Sensitive Personal Information, and we do not process Sensitive Personal Information for the purpose of inferring characteristics about consumers.
• Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your right to opt-out of the "sale" or "sharing" of your Personal Information. While we do not sell personal information for money, like many companies, we use services that help deliver interest-based ads to you as described above. The State Privacy Laws may classify our use of some of these services as "selling" or "sharing" your Personal Information with the advertising partners that provide the services. You can submit requests to opt-out of tracking for targeted advertising purposes or other sales of Personal Information via email to support@zennbot.com, and you can limit the associated tracking through the Meta and Google preference pages and the browser controls described in our Cookie Notice.

Exercising other state privacy rights. You may submit requests to exercise any of the other state privacy rights listed above via email to support@zennbot.com. We will respond to your request within the time required by applicable law.

Verification of identity; authorized agents. We may need to verify your identity in order to process your access, appeal, correction, or deletion requests and reserve the right to confirm your residency. Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf, such as by requiring a copy of a valid power of attorney or written and signed permission from you.

Information practices. We collect the categories of Personal Information described in the Personal information we collect section, from the sources and for the business and commercial purposes described in this Privacy Policy. We disclose these categories to the service providers listed in the How we share your personal information section for the business purposes described there; the only categories that may be "shared" for cross-context behavioral advertising are identifiers, device data and internet activity data collected via the Meta Pixel and Google Tag Manager. The criteria for deciding how long to retain Personal Information are described in the Retention section. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Shine the Light law. Under California's Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to support@zennbot.com with the statement "Shine the Light Request", your first and last name and mailing address, and certification that you are a California resident.

Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email support@zennbot.com.