This Privacy Policy explains how Zenera App Limited (“the Company”,“we”, “us”, or “our”) collects, processes, and protects your personal data in accordance withthe UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. We are regulated by the Information Commissioner’s Office(ICO). By using the App you acknowledge this Policy. If you prefer not to sharepersonal data, you may use guest mode as described below.
1. Data Controller
The Company is the Data Controller of personal data processed through the App.
2. Our Data Platform (Firebase)
The App is built and operated on Google Firebase. Personal data processed via the App is stored and processed within Firebase subject to Google’s Data Processing and Security Terms, privacy documentation, and platform certifications.
(a) Firebase provides core safeguards, including storage, encryption in transit and at rest, access control, logging, and transfer mechanisms.
(b) We rely on these platform controls and configure our use of Firebase inline with privacy by design and data minimisation principles.
3. Modes of Use and Consent
You can use the App in two ways:
(a) Guest Mode (no persistent personal data):
(i) No account is required and we do not persist personal data.
(ii) Only minimal technical data necessary to provide the session is processed briefly and not retained longer than needed.
(iii) Certain features (i.e., verified rewards and personalised offers) are not available in guest mode.
(b) Registered / Opt-in Mode:
(i) If you register or enable optional features, we will request clear, granular consent for each optional category.
(ii) You may withdraw consent at any time in settings or by contacting us.Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
4. Information Collected
We collect only what is necessary. Categories include:
(a) Required for Registered Accounts (contractual necessity):
(i) Email address
(ii) First and last name
(iii) Age verification status (i.e., confirmation that you are 18+ for restricted offers). We do not require or store date of birth.(d) Payment handling: In-app purchases are processed by the relevant app store as an independent controller; we do not collect or store payment card details.
(b) Optional, Consent-Based Data (collected only if you opt in):
(i) Approximate area/region to personalise nearby offers and vendor recommendations.
(ii) In-app usage metrics such as productive cycles completed, time spent in sections of the App, and visits to vendor reward pages.
(iii) Optional profile details (i.e., gender) to improve relevance.
(c) Not Collected:
(i) We do not collect data outside the App and do not access your device’s Screen Time API.
5. Purpose of Processing and Legal Bases
Personal data is processed for the following purposes and legal bases:
(a) Operate and provide the App (account creation, authentication, core features) — Contract.
(b) Verify eligibility for age-restricted offers — Legal obligation and/or Contract.
(c) Enable reward redemption and vendor fulfilment (including fraud-prevention checks) — Contract and Legitimate interests.
(d) Personalise content and improve services (location, usage, optional profile data) — Consent.
(e) Marketing communications (where enabled) — Consent (you can opt out at any time).
(f) Compliance with applicable law — Legal obligation. If you withdraw consent, you can continue using the App; some features may be limited. Withdrawal does not affect the lawfulness of processing already performed. We may produce aggregated and anonymised insights that do not identify you to improve the App and inform vendor partners about general trends.
6. Data Sharing
We do not sell personal data. We share limited data strictly where necessary:
(a) Service Providers (Firebase): Processing and storage are carried out on our behalf by Google Firebase under data processing terms.
(b) Vendors (reward fulfilment): We share only what is necessary to complete a redemption, typically confirmation of redemption and, where required, age eligibility. In certain flows, your registered email may be shared with the vendor solely to complete fulfilment, and only with your explicit opt-in.
(c) App Stores /Payment Platforms: Handle payments as independent controllers under their own terms and privacy notices.
(d) Legal Authorities: Where disclosure is required by law or legal process.
7. International Transfers
Where Firebase processes data outside the UnitedKingdom, transfers rely on recognised safeguards and related platform measures.We aim to use UK or EU regions where feasible.
8. Data Retention
Data is retained only as long as necessary for the purposes set out above or to meet legal requirements.
(a) Upon account deletion, associated personal data are deleted or anonymised within a reasonable period, taking account of standard backup and audit cycles.
(b) Aggregated and anonymised information that does not identify you may be retained for service improvement.
9. Security Security and compliance controls (including encryption in transit and at rest, access management, monitoring, and logging) are provided by Firebase in accordance with its platform terms and certifications.We use the service with configurations intended to apply these controls.
10. Your Rights (UKGDPR)
Under the UK GDPR, you may:
(a) request access to your personal data;
(b) request rectification or erasure;
(c) request restriction of processing or object to processing;
(d) request data portability;
(e) withdraw consent for optional processing at any time.
Requests can be made to support@zenera.app. You also have the right to lodge a complaint with the ICO. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
11. Children
The App is not directed to children under 13. Certain offers require users to be 18 or over and may involve verification.
12. Changes to this Policy
We may update this Policy to reflect changes in theApp, the platform, or the law. The latest version will be available in-App. We will notify you of material changes where required.
13. Contact
Zenera App Limited
Email: support@zenera.app
Effective Date: 1st Nov 2025
Last updated: 1st Nov 2025
