Privacy Policy

Last updated: June 1, 2026

Plain-Language Summary

What this actually means for you:

Your AI team works for you — not for us. Your conversations, preferences, and everything your team learns about you stays in your account. We never use it to train AI models. We never aggregate it for company analytics. We never sell it.

We collect what we need to run the service (your email, billing info, and operational data like error rates). We do not run behavioral analytics or track how you use the app. Your personalization data — how your team knows you — is yours to view, edit, export, reset, or delete at any time.

You can view, control, or turn off personalization and adaptive learning in settings. You can export all your data. You can delete your account and we'll wipe everything within 30 days (backups within 1 year).

We use trusted third-party providers for AI inference, speech processing, payments (Stripe), and security (Cloudflare). We never use your data to train AI models, and under their commercial terms, neither do they (see Tier 5 for how this works on BYO Claude Code). Full list at zoeyos.com/legal/subprocessors.

Questions? legal@zoeyos.com. No lawyers needed — just ask.

1. Introduction

This Privacy Policy describes how Zoey OS, LLC ("Zoey OS," "we," "us," or "our") collects, uses, stores, and protects your personal information when you use our platform, desktop application, and related services (the "Services").

Availability — United States only (for now). Zoey OS is currently offered only to users located in the United States. Where this Policy references the EU General Data Protection Regulation (GDPR) or rights specific to the EU, EEA, United Kingdom, or Switzerland, those provisions are included for transparency and for future expansion — they apply only if and when we offer the Services in those regions.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy should be read together with our Terms of Service and Acceptable Use Policy.

Contact Information:

• Privacy inquiries: legal@zoeyos.com
• Abuse reports: support@zoeyos.com
• General support: support@zoeyos.com
• Zoey OS, LLC, 7901 4th St N, STE 300, St. Petersburg, FL 33702, United States

2. Our Data Collection Tiers

We organize data collection into clearly defined tiers, each with architectural enforcement preventing data from being used beyond its stated purpose.

Tier 1: Operational Telemetry (Always-On, Service-Required)

What it is: Data required to run and secure the service. No content access. No individual profiling.

Examples:

• Login/logout timestamps
• Error rates and crash reports
• System performance metrics (response latency, dispatch counts)
• Token consumption (for billing/cap enforcement)
• Voice connection status

Legal basis: Contractual necessity (required to provide the Service).

Retention: 90 days for performance data; 7 years for billing-related records (legal requirement).

Your control: Included in data export. Deleted with account deletion.

Tier 2: Aggregate Analytics — Not Currently Collected

What it is: Anonymized, aggregated usage patterns that could be used to improve the product (for example, overall feature-adoption rates across the user base).

Status: We do not currently collect behavioral or aggregate usage analytics in the desktop application. No analytics or event-tracking tooling runs in the app. If we introduce privacy-preserving, fully anonymized analytics in the future, we will update this Policy and provide any applicable opt-out controls before any such collection begins.

Tier 3: Account-Scoped Personalization (Default-On, Settings Toggle)

What it is: How you individually use the system, used to make YOUR experience better. Strictly contained within your account.

Examples:

• Communication style preferences
• Interest selections from onboarding
• Companion customizations
• Terminology preferences

Legal basis: Performance of contract (Art. 6(1)(b)) — remembering you and personalizing your experience is part of the Service you sign up for — together with legitimate interest (Art. 6(1)(f)) for ongoing refinement. This is not behavioral tracking and is never aggregated across users. You may still control or turn it off (see Your control).

Critical guarantee: This data is NEVER aggregated for company analytics or model training. Tenant-level data isolation at the database level prevents any cross-user query.

Your control:

• View all personalization data in Settings
• Edit any field
• Reset all personalization
• Export (included in JSON data export)
• Delete independently of account
• Toggle OFF entirely in Settings > Privacy > Personalization

Tier 4: Account-Scoped Adaptive Learning (Default-On, Settings Toggle)

What it is: Per-user improvements the system learns over time to better serve you. Never aggregated.

Examples:

• Your MarketingBot learning you prefer concise tone
• Your companions learning you want proactive vs. reactive responses
• Preferred working hours and interaction patterns

Legal basis: Performance of contract (Art. 6(1)(b)) and legitimate interest (Art. 6(1)(f)) — adaptive learning is how your companions deliver the persistent, personalized service you sign up for. It is account-scoped and never aggregated across users. You retain the right to object and may turn it off at any time (see Your control).

Critical guarantee: What's stored is per-user adaptation data. What's NOT collected for company use is the underlying patterns. The user's companions get better; we learn nothing aggregate from this.

Your control:

• View what the system has learned in Settings
• Reset ("reset my team's learning")
• Toggle OFF entirely in Settings > Privacy > Adaptive Learning
• Full audit trail of what was adapted and when
• Export and delete independently

Tier 5: Training Data — We Do Not Train On Your Data

Zoey OS does not use your data to train AI models. We operate no training pipeline and have no infrastructure to repurpose your conversations, content, or personalization data for model training, and we do not share your data with any third party for the purpose of training their models. This is a brand commitment and an architectural enforcement.

We do use external AI providers to run the Service — Anthropic for chat and voice, and OpenAI for the embeddings that power semantic search. Sending your data to these providers to generate a response or index your content is inference, not training. How that data is handled depends on your billing mode:

• Standard and BYO "All API": inference and embeddings run through commercial API accounts. Under those providers' commercial terms, your inputs and outputs are not used to train their models.
• BYO "Claude Code": chat inference runs on your own Anthropic subscription via Claude Code on your machine. That data is governed by your Anthropic account's terms and training settings, which we do not control. Anthropic's consumer plans may use data for model improvement unless you opt out in your account — we recommend reviewing those settings.

Special Categories of Personal Data (Article 9 GDPR)

Your companions process whatever you choose to share in conversation, which may incidentally include "special category" data under Article 9 GDPR — for example, data revealing health, religious or philosophical beliefs, political opinions, or sexual orientation. We want to be clear about how this is handled:

• We do not solicit special-category data, and we do not use it to profile you, target you, or make automated decisions about you.
• Any such data is processed only to provide the Service at your direction — so your companion can respond to what you tell it — and is held under the same account-scoped isolation, security, and deletion controls as all your other data.
• We never aggregate it across users and never use it to train AI models.
• By choosing to share such information with your companions, you provide your explicit consent to its processing for this purpose under Article 9(2)(a) GDPR. You can delete it at any time — per individual memory, or by deleting your account.

3. Categories of Personal Data We Collect

3.1 Account Information

• Email address
• Name (if provided)
• Password (hashed using industry-standard algorithms, never stored in plaintext, excluded from data exports)
• Billing information (processed by Stripe — we do not store full payment card numbers)
• Account creation date
• Subscription tier and status

3.2 Conversation and Content Data

• Text conversations with your AI team
• Voice transcripts
• Files you upload or create
• Notes, tasks, and workflow data
• Integration data pulled from connected third-party services at your direction

3.3 Usage and Billing Metering

• Voice minutes consumed (to enforce plan limits and for billing)
• Token / inference consumption (to enforce plan limits and for billing)
• Login and account-activity timestamps (for security and account management)

We collect this operational metering only to run, secure, and bill the Service. We do not collect behavioral product analytics, session-tracking, or feature-usage metrics.

3.4 Device and Technical Data

• IP address (logged for security, not used for tracking)
• Device type and operating system
• App version
• Browser type (for web-based interactions)
• Hardware identifier (hashed, for device limit enforcement only)

3.5 Personalization Data

• Interest selections from onboarding
• Communication style preferences
• Companion customizations and configurations
• Adaptive learning data
• Terminology and interaction preferences

3.6 Consent Records

• Timestamp, IP, user-agent for each consent given
• Version of each document accepted
• Consent method (checkbox, settings toggle, verbal)
• Withdrawal records

4. How We Use Your Information

Purpose	Data Used	Legal Basis
Provide the Services	Account info, conversations, integrations	Contractual necessity
Process payments	Billing info (via Stripe)	Contractual necessity
Personalize your experience and remember you	Tier 3 & 4 data	Performance of contract; legitimate interest
Respond to support requests	Account info, relevant conversations	Contractual necessity
Detect abuse and prevent fraud	Operational and security signals, IP, device info	Legitimate interest
Meet legal obligations	As required	Legal obligation
Send transactional communications	Email address	Contractual necessity
Send marketing communications	Email address	Consent (opt-in only)

5. What We Do Not Do

• We do not sell your personal data
• We do not use your conversations to train AI models (ours or anyone else's)
• We do not run behavioral analytics or track how you use the application
• We do not aggregate your personalization data for company analytics
• We do not share personal data with third parties for their marketing purposes
• We do not create or store biometric voiceprints
• We do not profile you for advertising purposes
• We do not provide data to data brokers

6. How We Share Your Information

We share your information only in the following circumstances:

6.1 Subprocessors (Required for Service Delivery)

We use third-party service providers to deliver the Services. Each operates under contractual obligations limiting their use of your data to service provision only. A complete, up-to-date list is maintained at zoeyos.com/legal/subprocessors. We will notify you by email at least 30 days before adding any new subprocessor.

6.2 Legal Requirements

We may disclose your information if required by law, subpoena, court order, or government request. We will notify you of such requests unless legally prohibited from doing so.

6.3 Business Transfers

If Zoey OS is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

6.4 With Your Consent

We may share your information for other purposes with your explicit consent.

7. Data Retention and Deletion

7.1 Active Accounts

Data Type	Retention
Operational telemetry	90 days
Personalization data	Until you reset or delete
Adaptive learning data	Until you reset or delete
Conversation history	Retained for companion persistence until account deletion
Voice transcripts	Retained for companion persistence until account deletion
Billing records	7 years (legal requirement)

7.2 Account Deletion

When you delete your account:

• We offer you a configuration export file before deletion (so you can restore your team if you return)
• All user data is wiped from production within 30 days
• All user data is removed from backups within 1 year as backup retention cycles expire
• A deletion confirmation email is sent to your registered address
• Billing records may be retained for 7 years per legal requirements (anonymized)

7.3 Subscription Cancellation (Without Account Deletion)

• Data retained for 90 days for potential reactivation
• After 90 days without reactivation: full deletion procedure begins
• You may request immediate deletion at any time by deleting your account

8. Your Rights

Regardless of your location, we provide the following rights to all users:

8.1 Right to Access

You can view and download all data we hold about you through Settings > Privacy > Export My Data.

8.2 Right to Correction

You can edit your profile, personalization data, and account information at any time through Settings.

8.3 Right to Deletion

You can delete your account and all associated data through Settings > Account > Delete Account.

8.4 Right to Portability

Your data export is provided in machine-readable JSON format.

8.5 Right to Restrict Processing

You can disable Tier 3 personalization and Tier 4 adaptive learning independently without deleting your account.

8.6 Right to Withdraw Consent

You can withdraw consent for non-essential processing (marketing emails) at any time without affecting your access to core Services.

8.7 Right to Object

You can object to specific processing activities by contacting legal@zoeyos.com.

9. Children's Privacy (COPPA Compliance)

9.1 Age Requirement

The Services are not directed to children under 13. We do not knowingly collect personal information from children under 13.

9.2 Parental Consent

Users between 13 and 18 may only use the Services with verifiable parental or guardian consent. During account creation for users who indicate they are under 18, we require:

• Parent/guardian email address for consent verification
• Parental consent confirmation before account activation

9.3 Parental Rights

Parents or guardians of users under 18 may:

• Review their child's personal information by contacting legal@zoeyos.com
• Request deletion of their child's personal information
• Refuse further collection of their child's personal information
• Request that we stop contacting their child

9.4 Voice Data and Minors

Voice interaction data, including audio characteristics, is classified as personal information under applicable law. We do not knowingly collect voice data from users under 13. Voice features require an active account and are subject to the same age restrictions as the Services.

9.5 Discovery of Underage Users

If we discover that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information within 48 hours of discovery. If you believe a child under 13 has provided us personal information, please contact legal@zoeyos.com immediately.

10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights:

10.1 Right to Know

You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collection, and the categories of third parties with whom we share it.

10.2 Right to Delete

You may request deletion of your personal information, subject to legal exceptions.

10.3 Right to Opt-Out of Sale

We do not sell personal information. We do not share personal information for cross-context behavioral advertising. No opt-out is necessary, but you may still submit a request to confirm this at legal@zoeyos.com.

10.4 Right to Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights.

10.5 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification of the agent's authority.

To exercise any of these rights, contact legal@zoeyos.com or use the self-service tools in your account Settings.

11. European Union Data Subject Rights (GDPR)

Note: Zoey OS is currently available only to users in the United States. The GDPR-specific provisions in this section apply only if and when we offer the Services in the EU, EEA, United Kingdom, or Switzerland; they are included now for transparency and future expansion.

If you are a resident of the European Union, European Economic Area, United Kingdom, or Switzerland, you have the following additional rights:

11.1 Legal Bases for Processing

Processing Activity	Legal Basis
Providing the Services	Performance of contract
Billing and payments	Performance of contract
Personalization & adaptive learning (Tier 3 & 4)	Performance of contract; legitimate interest
Security and fraud prevention	Legitimate interest
Legal compliance	Legal obligation
Marketing communications	Consent

11.2 Your Rights Under GDPR

In addition to the rights in Section 8, you have the right to:

• Lodge a complaint with your local data protection supervisory authority
• Object to processing based on legitimate interest
• Restrict processing under certain circumstances
• Receive your data in a structured, commonly used, machine-readable format

11.3 Data Transfers

The Services are hosted in the United States. If you are located outside the United States, your data will be transferred to and processed in the United States. We ensure appropriate safeguards for such transfers through Standard Contractual Clauses (SCCs) with our subprocessors and, where applicable, the EU-US Data Privacy Framework, together with contractual commitments equivalent to GDPR protections for all users regardless of location.

11.4 Data Subject Requests

We will respond to verified data subject requests within 30 days. Contact legal@zoeyos.com.

12. Cookies and Tracking

12.1 What We Use

We use only essential cookies required for the Services to function. We do not use:

• Third-party advertising cookies
• Cross-site tracking cookies
• Social media tracking pixels
• Fingerprinting techniques (beyond the hardware identifier for device limits disclosed in our Terms)

12.2 Essential Cookies

Cookie	Purpose	Duration
Session cookie	Maintain your login state	Session
CSRF token	Prevent cross-site request forgery	Session
Preferences	Store your display preferences	1 year

12.3 Do Not Track Signals

We do not currently respond to Do Not Track (DNT) browser signals. Our website uses a privacy-focused analytics tool that is loaded only after you accept the cookie consent banner. If you decline or do not interact with the banner, no analytics cookies are set. No analytics data is shared with advertising networks.

12.4 Analytics

We do not currently collect behavioral or aggregate usage analytics within the desktop application (see Tier 2 above). Error and crash reporting used to keep the Service secure and working is covered under Tier 1 (operational telemetry).

12.5 Cookie Consent

Our cookie consent banner allows you to accept or reject non-essential cookies before any are set. Essential cookies (required for the service to function) do not require consent.

13. Data Security

13.1 Technical Measures

We implement the following security measures:

• Encryption in transit (TLS 1.2+) for all data communications
• Encryption at rest (AES-256) for all stored data
• Tenant-level data isolation at the database level preventing cross-user data access
• Regular security patching and dependency updates
• Network segmentation between production and development environments
• Audit logging of all administrative data access

13.2 Organizational Measures

• Multi-factor authentication on all administrative accounts
• Password management with no shared credentials
• Regular backup testing (at least one tested restore per 90 days)
• Documented incident response plan
• Employee security awareness training

13.3 Breach Notification

In the event of a data breach affecting your personal information, we will:

• Notify affected users within 72 hours of confirmed breach
• Provide details of what data was affected
• Describe steps we are taking to address the breach
• Provide guidance on steps you can take to protect yourself
• Notify relevant regulatory authorities as required by law

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Email to your registered address (at least 30 days before changes take effect)
• Prominent notice within the Services
• Posting the updated policy on our website with a new effective date

If changes materially reduce your privacy rights, we will obtain your explicit consent before the changes take effect. Your continued use of the Services after the effective date of any update constitutes acceptance (except where explicit consent is required).

15. Contact Us

For any privacy-related questions, concerns, or requests:

We aim to respond to all privacy inquiries within 5 business days.

Last updated: June 1, 2026 · Version 1.0