ZOLLO — PRIVACY POLICY

Last updated: 13 August 2026

This Privacy Policy explains how the Zollo mobile application ("Zollo", "the
app", "we", "us") collects, uses, and protects your information. By creating
an account and using Zollo you agree to the practices described below.

Zollo is a messaging and calling application. It lets you exchange text
messages, photos, videos, voice messages, files and stickers, and make voice
and video calls with other Zollo users.


1. INFORMATION WE COLLECT

1.1 Information you provide
- Account credentials. You create an account with a username and a password
  that you choose. Other users can find and reach you by your username. Zollo
  does not require or collect your phone number, and there is no SMS
  verification.
- Profile information. A display name and an optional profile photo that you
  choose.
- Message content. Text, photos, videos, voice messages, files and stickers
  you send or receive. This content is delivered to your chat recipients and
  stored only as needed to deliver it.

1.2 Information collected with your permission
- Camera and microphone. Used for video and voice calls and to record voice
  and video messages, only while you are using those features.
- Photo library. Used so you can choose photos and videos to send, and to save
  received media to your device, only when you initiate those actions.

1.3 Information collected automatically
- Device identifiers and advertising identifier (IDFA). Used to deliver and
  measure advertising (see Section 4).
- Technical and usage data. Basic diagnostic and usage information used to
  operate, secure and improve the app.


2. HOW WE USE YOUR INFORMATION

We use the information above to:
- create and secure your account;
- deliver your messages, calls and media to the people you communicate with;
- send push notifications about incoming messages and calls;
- display advertising that keeps the app's core features free (see Section 4);
- operate, maintain, troubleshoot and improve the service;
- comply with legal obligations and prevent abuse.

We do not sell your personal information.


3. PUSH NOTIFICATIONS

Zollo sends push notifications to alert you about new messages and incoming
calls. You can disable notifications at any time in your device settings.


4. ADVERTISING AND TRACKING

Zollo shows advertising provided by Google AdMob to support free use of the
app. To deliver and measure ads, Google may use your device's advertising
identifier (IDFA) and related data.

On iOS, before any tracking takes place, Zollo asks for your permission through
Apple's App Tracking Transparency prompt. If you decline, Zollo does not track
you across other companies' apps and websites, and any ads shown are
non-personalised.

Advertising is provided by Google. Google's handling of advertising data is
described in Google's Privacy Policy (https://policies.google.com/privacy) and
in "How Google uses information from sites or apps that use our services"
(https://policies.google.com/technologies/partner-sites).

You can manage or reset your advertising identifier and limit ad tracking in
your iOS Settings (Settings > Privacy & Security > Tracking, and Settings >
Privacy & Security > Apple Advertising).


5. THIRD-PARTY SERVICES

Zollo relies on the following third-party services, which may process limited
data on our behalf:
- Google AdMob — advertising.
- Google Firebase Cloud Messaging — delivery of push notifications.

Each provider processes data under its own privacy terms. We share with them
only what is necessary to provide their function.


6. DATA RETENTION

We keep your account information for as long as your account exists. Message
content is retained only as needed to deliver it to recipients and to provide
the service. When you delete your account, your account data is removed from
our servers as described in Section 7.


7. DELETING YOUR DATA AND ACCOUNT

You can delete your account directly in the app: open Profile and choose
"Delete account". This permanently removes your account, profile photo and your
messages from our servers and cannot be undone.
Copies already delivered to other users' devices remain on those devices, as
is normal for messaging apps.


8. DATA SECURITY

We use industry-standard measures, including encrypted (HTTPS/TLS) connections
between the app and our servers, to protect your information. No method of
transmission or storage is completely secure, but we work to protect your data
against unauthorised access.


9. CHILDREN

Zollo is not directed to children under the age of 13 (or the minimum age
required in your country), and we do not knowingly collect personal
information from them. If you believe a child has provided us with personal
information, please contact us so we can remove it.


10. YOUR RIGHTS

Depending on where you live, you may have the right to access, correct, or
delete your personal information, to object to or restrict certain processing,
and to data portability. You can exercise the deletion right in-app (Section 7)
or contact us using the details below for other requests.


11. INTERNATIONAL TRANSFERS

Your information may be processed and stored on servers located outside your
country of residence. Where required, we take steps to ensure your information
receives an adequate level of protection.


12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will update the "Last
updated" date above and, where appropriate, notify you within the app.


13. CONTACT US

If you have questions about this Privacy Policy or your data, contact us at:

    Email: support@fug.com.ua