Policy

Privacy Policy for Zunagu.
Last Updated: 21 June 2025.
Welcome to Zunagu!
1. Introduction, We are committed to protecting your privacy and handling your personal data in a transparent and secure manner. This Privacy Policy explains how Adapt Technology Corporation ("we", "us", or "our"), as the data controller, collects, uses, shares, and protects your personal data when you use our mobile application and related services (collectively, the "Service"). We adhere to the principles of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). By using our Service, you agree to the collection and use of information in accordance with this policy. 2. Who We Are, Adapt Technology Corporation 14591983, located at 9, Dalton House, 60 Windsor Ave, London, SW19 2RR, United Kingdom, is the data controller responsible for your personal data collected via the Service. You can contact us regarding this Privacy Policy at hello@Zunagu.com. 3. The Data We Collect About You, Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows: Identity Data: First name, last name, username or similar identifier, profile picture, and any information you provide in your public profile (e.g., expertise, interests, celebrity status claims). Contact Data: Email address, phone number (if provided), and any other communication details. Financial Data: Details related to payments for bookings, which are processed through our third-party payment provider, Stripe. Note: We do not directly store your full payment card details. We receive confirmation of payment from Stripe, along with limited transaction data (e.g., last 4 digits of card, transaction ID). Transaction Data: Details about bookings you have made or received, payments to and from you, and other details of services you have purchased from us or through the Service. Technical Data: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Service. Usage Data: Information about how you use our Service, including your activity within the app, pages viewed, features used, and patterns of engagement. Profile Data: Your username and password, bookings made by you, your interests, preferences, feedback, and survey responses. Communications Data: The content of your communications with us (e.g., support requests) and potentially data derived from your interactions with other users, though the content of video calls is not stored by us. Monitoring Data: Data generated from our automated checks and manual reviews of user conduct and content for compliance with our Terms & Conditions (e.g., flags for inappropriate content, details of account suspension/deletion). Special Categories of Personal Data: We do not intentionally collect any "special categories" of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Children's Data: Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected personal data from a child under 18 without parental consent, we will take steps to remove that information from our servers. 4. How We Collect Your Personal Data, We use different methods to collect data from and about you, including through: Direct Interactions: You provide us with your Identity, Contact, Profile, and Financial Data when you: Create an account. Set up your public profile. Request or accept bookings. Interact with customer support. Provide feedback or participate in surveys. Automated Technologies or Interactions: As you interact with our Service, we automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Third Parties: We may receive personal data about you from various third parties, such as: Payment Providers: Stripe (Financial and Transaction Data). Analytics Providers: [e.g., Google Analytics for Firebase, if used] (Technical and Usage Data). User Reporting: Other users of the Service may flag your profile or report conduct, which may lead to the collection of Monitoring Data. 5. How We Use Your Personal Data and Our Lawful Basis, We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: To perform the contract we are about to enter into or have entered into with you. This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (e.g., providing the Service, managing bookings, processing payments). Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., for security, service improvement, fraud prevention). Where we need to comply with a legal obligation (e.g., for tax purposes, legal disclosure requests, or anti-fraud measures). We may also rely on your consent in specific situations, which will be explicitly requested. You have the right to withdraw consent at any time where we are relying on consent to process your personal data. Below is a table outlining the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. Purpose/Activity of Processing Type of Data Involved Lawful Basis for Processing To register you as a new user and create your account Identity, Contact, Profile Performance of a contract with you To enable you to set your availability and price Identity, Profile, Usage Performance of a contract with you To facilitate booking requests and video calls Identity, Profile, Transaction, Usage Performance of a contract with you To process payments for bookings (via Stripe) Financial, Transaction Performance of a contract with you (with Stripe as a separate data controller for their part of the payment process) To manage our relationship with you, including notifying you about changes to our terms or privacy policy Identity, Contact, Profile, Communications Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To enable you to participate in a survey or provide feedback Identity, Profile, Communications Performance of a contract with you; Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) To administer and protect our business and this Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Technical, Identity, Usage Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation (e.g. for security audits) To detect, investigate, and prevent prohibited conduct (e.g., pornography, drug-related content, fraud, impersonation, misrepresentation, harassment, or other harmful behaviour) based on our Terms & Conditions Identity, Profile, Usage, Monitoring, Technical, Communications Necessary for our legitimate interests (to protect our users, uphold the integrity of the Service, and enforce our terms); Necessary to comply with a legal obligation (e.g., reporting illegal activities) To improve our Service, products/services, marketing, and user experience Technical, Usage, Profile Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Service updated and relevant, to develop our business) To deliver relevant advertising to you (if applicable) Technical, Usage, Profile Necessary for our legitimate interests (to develop our products/services and grow our business) No Video Call Recording: Please note that Zunagu does not allow users to record video calls through the application, nor do we store the content of your video calls. Our monitoring and review processes for prohibited conduct relate to behavioural patterns, flags, and metadata rather than the direct content of your communications. 6. Disclosures of Your Personal Data, We may share your personal data with the parties set out below for the purposes described in section 5: Internal Third Parties: Other companies within our group (if applicable) acting as processors or joint controllers who provide IT and system administration services. External Third Parties: Service Providers: Such as Stripe for payment processing. IT and System Administration Providers: Companies that provide IT, hosting, and system administration services. Analytics Providers: Who provide anonymised or aggregated data analytics services (e.g., Google Analytics for Firebase). Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services. Regulators and Other Authorities: Who require reporting of processing activities in certain circumstances. Law Enforcement or Government Bodies: If required by law, court order, or governmental regulation, or if we believe in good faith that such action is necessary to (a) comply with a legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (d) protect against legal liability. Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 7. International Transfers, Some of our external third parties (e.g., Stripe, or cloud hosting providers) may be based outside the UK and European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the UK/EEA. Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Secretary of State. Where we use certain service providers, we may use specific contracts approved for use in the UK/EEA which give personal data the same protection it has in the UK/EEA (e.g., Standard Contractual Clauses). Where providers are based in the US, they may be certified under a recognised data transfer framework (e.g., the EU-US Data Privacy Framework, if applicable and recognised for UK transfers). Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA. 8. Data Security, We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 9. Data Retention, We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, you can ask us to delete your data: see "Your Legal Rights" below for more information. In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 10. Your Legal Rights, Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us at hello@Zunagu.com. No Fee Usually Required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. What We May Need From You: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time Limit to Respond: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 11. Cookies and Similar Technologies, Our Service may use "cookies" and similar tracking technologies to enhance your experience. A cookie is a small file placed on your device. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience. Essential Cookies: These are necessary for the operation of our Service, enabling core functions like security, network management, and accessibility. You cannot opt out of these. Analytics Cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our Service when they are using it. This helps us to improve the way our Service works. You can set your device's browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Service may become inaccessible or not function properly. 12. Third-Party Links, The Service may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Service, we encourage you to read the privacy policy of every website you visit. 13. Changes to This Privacy Policy, We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Privacy Policy. We may also notify you via email or through prominent notice on our Service prior to the change becoming effective. You are advised to review this Privacy Policy periodically for any changes. 14. Contact Us, If you have any questions about this Privacy Policy or our privacy practices, please contact us at: hello@Zunagu.com 15. Complaints to the ICO, You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.