Legal

Privacy Notice

Last Updated: February 2, 2026

This Privacy Notice is designed to help you understand how Zapshot (“we”, ”us”, “our“)  collect, use, and share your personal information and to help you understand and exercise your privacy rights. Please read our Privacy Notice carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your Personal Information (including Biometric Data)in accordance with our Services.

1. SCOPE

This Privacy Notice applies to personal information we process, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Notice easier to read, our websites, mobile applications, and other offerings are collectively called “Services.”

2. CHANGES TO THIS PRIVACY NOTICE

We may revise this Privacy Notice from time to time at our sole discretion. If there are any material changes to this Privacy Notice, we will notify you and obtain your consent where required by applicable law. We will review and update this Privacy Notice at least once every twelve (12) months, or sooner if our data practices materially change, and include the date of the last update.

You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

3. NOTICE AT COLLECTION

We are required by California law (CCPA/CPRA) to inform consumers, at or before the point of collection, about the categories of Personal Information we collect and the purposes for that collection. This section provides a summary. For full detail on our collection methods, sources, and third parties, please refer to Section 5.

The table below summarizes the categories of Personal Information we collect from you, the purposes for which we use the information, the criteria we use for retention, and whether we "Share" the information for cross-context behavioral advertising (Targeted Advertising).

Category of Personal Information

Purpose for Collection

Retention Period/Criteria

Selling/Sharing (Advertising)

Identifiers (e.g., Name, Email, IP, Phone, Account ID)

Account Setup, Authentication, Security, Service Provision

Account active period + required legal/compliance period (e.g., 3 years).

No

Biometric Information (SPI) (Voiceprint Template)

Authentication, AI Voice Synthesis (ZapVoice). Not used for advertising or profile building.

Earliest of: (a) Purpose fulfilled, (b) Account deletion, (c) 30 days inactivity (ZapVoice), or (d) 3 years from relationship termination.

No

Sensitive Geolocation Data (Precise Location, if permitted)

Location-based features, Security, Fraud Prevention.

Necessary minimum period (e.g., end of session) or as required to retain associated content.

No

Audio/Visual Information (Messages, ZapMoments, Photos)

Core Service Provision, Trust & Safety (Content Moderation), Security.

Necessary duration for service. Users can delete via in-app controls.

No

Internet/Electronic Activity (Usage, Interactions, IP approx.)

Service Improvement (Analytics), Performance, Contextual Advertising.

Variable (e.g., up to 3 years) depending on specific data type and analytic needs.

No

Inferences (Preferences, Characteristics)

Personalization of Content and Services.

Account active period.

No

For a full list of all Personal Information collected, the sources we collect from, and your ability to limit the use of Sensitive Personal Information, please refer to our complete Privacy Notice below.

4. BIOMETRIC INFORMATION POLICY

This policy specifically governs our collection, retention, and use of your Biometric Information, which is categorized as Sensitive Personal Information under applicable state laws.

A. Collection and Purpose We only collect your Biometric Information with your explicit and voluntary consent. The types of Biometric Information collected, and their limited purposes, are:

Zapshot does not use, share, or sell your Biometric Information for advertising, profiling, or to infer characteristics about you.

B. Disclosure and Processing Partners We do not Sell or share your Biometric Information. We share this information only with trusted third-party Service Providers solely for the business purpose of enabling the features you have requested. These partners include:

We require all partners processing this sensitive data to be contractually bound to maintain confidentiality and use the information only for specified purposes.

C. Retention and Destruction We will retain your Biometric Information only as long as is necessary to fulfill the initial, stated purpose of collection. We will permanently destroy your Biometric Information from our systems, and direct our service providers to do the same, upon the earliest of the following events:

  1. The initial purpose for collecting the Biometric Data has been satisfied.
  2. Your user account is deleted.
  3. Your account remains inactive for thirty (30) consecutive days (applies only to the volatile Voiceprint Templates for ZapVoice functionality, as specified in our FAQ).
  4. Three (3) years from the date of the termination of your relationship with Zapshot.

We employ strict security safeguards, including implementing measures that meet or exceed the requirements of applicable state laws (e.g., BIPA and CPRA), to protect your Biometric Data from unauthorized access, disclosure, or use. We will not re-enroll your Voiceprint Templates without obtaining new, explicit consent from you.

5. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources, such as third-party services and organizations, as described below.

  1. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

  1. Information Collected Automatically

We may collect personal information automatically when you use our Services:

Our uses of these Technologies fall into the following general categories:

See Section 8 below to understand your choices regarding these Technologies.

  1. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. This also includes information from third parties regarding potential violations of our Terms (such as inappropriate content reports) or legal compliance, which may include your personal information. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site like TikTok, we may collect information about you from that third-party application that you have made available via your privacy settings.

6. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including providing our services, providing administrative services, and marketing our products and services, as described below.

  1. Provide Our Services

We use your information to provide you with our Services, such as:

  1. Administrative Purposes

We use your information for various administrative purposes, such as:

  1. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

7. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

  1. Disclosures to Provide Our Services

The categories of third parties with whom we may disclose your information are described below.

  1. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety (including using Sensitive Personal Information for these security and verification purposes); enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

  1. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties.

8. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

If you would like to exercise any of these rights, please contact us as set forth in Section 16 below. We will process such requests in accordance with applicable laws.

9. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your Personal Information, including Sensitive Personal Information, will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. These safeguards include implementing measures that meet or exceed the requirements of applicable state laws (e.g., BIPA and CPRA) for the protection of Biometric Data. To the fullest extent permitted by applicable law, we do not accept liability for any disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on our Services, or by sending an email to you.

10. SECURITY OF COMMUNICATIONS

We use industry-standard encryption (such as TLS) for data in transit and at rest. Messages, media, and other content posted in Cloud Chats (Open Rooms, Peekable Rooms, Private Rooms) are stored encrypted on our servers to ensure multi-device access and functionality.

Voice/Video Content: We generally do not store the contents of live voice or video calls/channels (if offered). Content generated via ZapMoment (dual-camera video) is stored encrypted on our servers to facilitate sharing and is retained in accordance with the content policies set by the user.

11. RETENTION OF PERSONAL INFORMATION

Except as described in Section 3(B) above with respect to biometric information, we store the personal information we collect as described in this Privacy Notice for as long as you keep your account active or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Upon account deletion, we aim to permanently delete all associated user-provided Personal Information within thirty (30) days, except for any data retained for legal or compliance purposes as required by law.

12. SUPPLEMENTAL NOTICE FOR U.S. RESIDENTS

This U.S. Privacy Notice (this “Notice”) covers our information collection practices and describes your rights regarding your personal information for the United States of America (U.S.) residents. All terms defined in the privacy laws of the states of the U.S. (respectively and collectively, the “State Privacy Law(s)”) have the same meanings when used in this section.

Categories of personal information we collect

U.S. residents have the right to know what categories of personal information we collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. U.S. residents can find this information below:

Category of Personal Information Collected by Us

Category of Third Parties Information is Disclosed to for a Business Purpose

Identifiers

Such as alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, phone number,  or other similar identifiers.

  • Data analytics providers
  • Social networks
  • Service providers

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Such as a name, physical characteristics or description, telephone number, or Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.

  • Social networks
  • Service providers

Protected classification characteristics (Sensitive Personal Information)

Such as demographics derived from your use of the Services (e.g., age range, gender, interests) and information you provide (e.g., age, where collected).

  • Data analytics providers
  • Service providers

Commercial information

Such as browsing history, Search history, and interactions with our services.

  • Data analytics providers

Biometric information

Behavioral characteristics that can be used to establish individual identity, such as  Voiceprint Templates (ZapVoice).

  • Service providers
  • Biometric Processing Partners ( ElevenLabs, Cloudinary)

Audio, electronic, visual, thermal, olfactory, or similar information

Such as voice recordings, video recordings (ZapMoment), photos, or other audio/visual content provided by users.

  • Service providers
  • Data analytics providers
  • Social networks

Internet or other electronic network activity

Such as browsing history, search history, post, and information on a consumer's interaction with an internet website, application.

  • Data analytics providers
  • Social networks
  • Service providers

Geolocation data

Such as general location information (e.g., city, state, or zip code) derived from your IP address or device settings.

  • Data analytics providers
  • Service Providers

Professional or employment-related information

Such as information you provide about your professional status or industry in your profile or communications.

  • Service Providers

Inferences drawn from other personal information

Such as user preferences, characteristics, and behavior patterns derived from demographic and engagement data.

  • Data analytics providers
  • Service Providers

“Sales” or “Share” of Personal Information under the State Privacy Laws

For the purposes of the respective State Privacy Laws, Zapshot does not "Sell" Personal Information, and does not "Share" Personal Information. We have not "Sold"or "Shared"  any Personal Information during the 12 months preceding the effective date of this Notice.

Our Use and Disclosure of Sensitive Personal Information:

Without your consent, we do not use or disclose your sensitive information for purposes other than those specified by State Privacy Laws.

Additional Privacy Rights for U.S. Residents

You may exercise the following rights by submitting a verifiable consumer request through one of the following methods:

  1. Web Form/Contact Page (available in Section 16)
  2. Dedicated Privacy Email (contact@ph7.ltd in Section 16)

Non-Discrimination. U.S. residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by respective State Privacy Law.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in Section 16 below.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request,  we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

If you are a U.S. resident and would like to exercise any of your rights under respective State Privacy Laws, please contact us as set forth in Section 16 below. We will process such requests in accordance with applicable laws.

Nevada Residents. Nevada residents have the right to submit a verified request directing us not to sell Personal Information. Zapshot currently does not sell Personal Information as defined by Nevada law, and therefore, we already comply with this right. However, if you are a Nevada resident and wish to exercise this right, please submit your request to contact@ph7.ltd or via the contact form in Section 16.

California Shine the Light. We are exempted from the requirement to grant such a request because we do not disclose personal information of customers for third parties’ direct marketing purposes unless a customer directs us.

Right to Appeal. If we decline to take action on your request, we will inform you of the reasons for the decision and provide instructions on how to appeal. You have the right to submit an appeal of our decision by contacting us at the dedicated privacy email address (contact@ph7.ltd) within forty-five (45) days of receiving our denial. We will respond to the appeal within the required timeframe (e.g., 60 days for Virginia) and notify you in writing of any resulting action. If your appeal is denied, you may contact your State's Attorney General (e.g., Colorado and Virginia residents) to file a complaint.

Privacy Rights for California Minors in the Digital World. If you are under the age of 18, you have the right to request permanent deletion of content or information you posted on our service. Please note that, when you post the content,  it can be collected, stored, or shared by others, and we cannot delete such information held by others. If you request to exercise the above rights, please contact us as set forth in Section 16 below.

13. SUPPLEMENTAL NOTICE FOR EU RESIDENTS

This Supplemental GDPR Privacy Notice only applies to our processing of personal data that is subject to the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) and equivalent laws of the United Kingdom of Great Britain and Northern Ireland (the “UK”)(“GDPR”). This Notice is applicable only to personal data concerning data subjects (“you” or “your”) in the member states of the European Union and three EEA/EFTA states - Iceland, Liechtenstein, Norway (collectively, the  “EU”), and the UK.

For purposes of this notice, the terms defined under the GDPR have the meanings ascribed to them under the GDPR.

We are responsible for your personal data as a data controller. If you have any questions or would like to uphold your rights, please contact us at;

Email: contact@ph7.ltd

Transfers to third countries outside the EU

Your personal data may be transferred to third countries outside the EU with or without an adequate decision by the European Commission. In the case of any transfer of personal data to a country that does not have an adequate level of data protection in light of the standards under the GDPR, we will ensure such transfer will be made through the Standard Contractual Clauses adopted in accordance with the GDPR.

No obligation to provide your personal data

You have no obligation to provide your personal data to us either under applicable law or a contract. Once you make an order for our services, we may require your personal data based on the contract with you, in which case your failure to provide the personal data we require may prevent us from providing you with the services.

Profiling

We will not make decisions based solely on automated processing, including profiling on collected personal data, including Biometric Data, which produces legal effects concerning the User or similarly significantly affects the User.

Additional Privacy Rights for EU Residents

You may exercise the following rights by contacting us or a representative or data protection officer. If you request to exercise the following rights, please contact us as set forth in Section 16 below.

Right to erasure. You may obtain the erasure of your personal data, subject to certain exceptions under the GDPR, where: (i) such personal data is no longer necessary in relation to the purposes for which we collected and processed it; (ii) you withdraw your consent to our processing solely based upon your consent; (iii) you object to our processing and there are no overriding legitimate grounds for such processing; (iv) our processing is unlawful; (v) your personal data has to be erased in compliance with a legal obligation.

Right to restriction of processing. You may obtain restriction of processing of your personal data, subject to certain exceptions under the GDPR, where: (i) you contest the accuracy of your personal data: (ii) our processing is unlawful, and you select to restrict our processing instead of requesting erasure of your personal data: (iii)  you request us to establish, exercise or defense legal claims that need your personal data no longer necessary for the purposes of our processing; or (iv) you exercise the right to object to our processing and wait for verification on where we have overriding legitimate grounds.

Right to data portability. You may receive your personal data or direct us to transmit your personal data to a third party you designate, provided that we process such personal data based upon your consent or as the performance of a contract with you.

Right to object. You may object to the processing of your personal data where our processing is based upon the exercise of our official authority or our legitimate interests, including “profiling” or for direct marketing purposes.

Right to the withdrawal of your consent.  We may process certain data (including analytics data) based on your consent (GDPR Article 6(1)(a)) or our legitimate interests (GDPR Article 6(1)(f))—for example, using Google Analytics to understand user behavior and improve our Services. You may withdraw your consent at any time to the processing of your personal data that we have collected about you. The legality of processing based on consent prior to withdrawal will not be affected by withdrawal of consent.

Right to complain. You may lodge a complaint with the supervisory authority, in particular, in the member state of the EU or the UK where you have a habitual residence or place of work or where the alleged infringement of GDPR took place.

14. CHILDREN’S INFORMATION

The Services are strictly for users aged 13 and older. The Services are not directed to children under 13 in the United States and under the applicable age of consent in other countries ("Child" or "Children"). We do not knowingly collect or store personal information from Children. If you are under 13 years of age, you are prohibited from using this Service. If we obtain actual knowledge that we have inadvertently collected Personal Information from a Child under the age of 13, we will take reasonable measures to immediately delete that information from our records. If you believe we may have unintentionally collected personal information from your Child, please contact us as set forth in Section 16 below so we can investigate and delete the data.

15. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications, and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

16. CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, including the California Consumer Privacy Act (CCPA) rights to Know and Delete, please contact us at:

PH7, Ltd.

10940 Wilshire Blvd. Los Angeles​, CA​, 90024

https://www.zapshot.me/contact

contact@ph7.ltd

Additionally, if you reside in the EEA, you can contact our Data Protection Officer, European representative, UK representative, or file a complaint with the supervisory authorities in Europe, the UK.

Representative

Our representative in the EU/UK is Classmethod (Europe) GmbH. You can contact our representative at;

Mail: Krausenstr.9 -10, 10117 Berlin, Germany

Email: gdpr@ph7.ltd

Data Protection Officer

You can contact our Data Protection Officer at;

Email: dpo@ph7.ltd