Privacy Policy

1. Scope

This Policy explains how ZOTO collects, uses, stores, shares, and protects personal data when you use the ZOTO app or website, including free and paid tiers (visa alerts, parcels, job referrals, discounts, accommodation, community hubs, rewards).

2. Data We Collect

Do not include sensitive personal information such as health, religion or sexual orientation in listings, chats or AI prompts unless needed for your purpose. Browsing a cultural community page is not treated as explicit consent to processing your ethnicity. Any processing requiring explicit consent needs a separate, specific lawful basis; general acceptance of these policies is not that consent.

3. How We Use Your Data

4. Consent

4.1 Optional analytics is off until you choose to accept it. Discount email preferences are separate from analytics and from agreeing to the account terms. Refusing optional analytics does not prevent you from using ZOTO. Session replay is disabled.

4.2 Change analytics choices using Cookie settings or Privacy & data, including when signed out. Withdrawing consent stops future optional tracking and clears the analytics identifiers managed by the app on that browser. It does not automatically erase records already held by providers; request access or erasure at hello@zoto.ie. Turn discount emails off using Offer email alerts in Profile or Exploding Discounts without losing access to discounts. Withdrawal does not affect the lawfulness of prior processing.

4.3 Consent for minors is not sought; the Platform is restricted to users 18+.

4.4 Analytics choices store a consent version and time in this browser. Discount email opt-ins and preference changes record the account, choice, time, source and consent wording/version. Older preferences may not have a recorded wording/version; we do not retrospectively assign one.

5. Sharing and Disclosure

5.1 We share data with:

• (a) Payment processors (Stripe) - transaction data only;
• (b) Partner Brands - limited data (e.g., name, redemption code) needed to fulfil a discount or referral, with your consent or where necessary for contract performance;
• (c) Logistics and courier partners - shipping data for parcel services;
• (d) Influencer and referral partners - anonymised or aggregated attribution data, not full personal profiles, unless you explicitly opt in;
• (e) Optional analytics provider - PostHog receives limited device and app interaction data only after analytics consent. A random browser identifier lets us measure feature use and return visits on that browser for up to 90 days. This is pseudonymous measurement, not a count of identified people or activity across devices. The app includes general signed-in/member/admin flags but does not attach your account ID, employer, city or cultural-community profile. Signing out starts a new identifier. Google Analytics and session replay are disabled;
• (f) AI service providers - inputs and relevant context, including uploaded content needed for an AI feature, pass through the Lovable AI gateway to third-party model providers, including Google, to generate results. Lovable states that the gateway does not store raw prompts or responses unless explicitly saved. Provider retention and any use for model training depend on the provider's policies and applicable service terms; we have not verified a zero-retention or blanket no-training guarantee for ZOTO's upstream providers;
• (g) Cloud infrastructure and hosting providers, including Lovable Cloud / Supabase, which host account records, content and uploaded files;
• (h) Government or regulatory authorities where legally compelled - we will notify you unless legally prohibited.

5.2 We do not sell personal data to third parties for their own independent marketing purposes.

5.3 Contact hello@zoto.ie for details about the providers relevant to your data and the applicable processing arrangements. Optional analytics is separate from the hosting and payment processing needed to provide the service.

5.4 Optional Directory photos are stored through Lovable Cloud / Supabase for listing review and display. You can preview your uploads; administrators can view photos attached to submitted listings and proposed edits. Other members can view photos attached to approved, open listings. Access checks issue photo links that expire after up to five minutes. Anyone holding a copied link can use it until it expires, even if listing access changes meanwhile. Directory photos are not included on public share pages, sent for AI processing, or automatically copied from Easy Post source files.

6. International Transfers

Personal data may be processed outside the EU/EEA; ZOTO's PostHog endpoint is in the United States. Applicable transfer safeguards and provider arrangements must be confirmed for the services used. Contact hello@zoto.ie to request the relevant details. A provider's location alone does not determine whether a transfer is lawful.

7. Retention

Directory photos remain stored while referenced by a listing or saved proposed edit, including paused or rejected versions. Account deletion removes the Directory listing and its proposed edit, making their photos eligible for cleanup. Unattached uploads are scheduled for cleanup after an explicit discard or a 24-hour grace period; interrupted uploads have a 10-minute grace period. Cleanup retries can delay deletion, and repeated failures require administrator attention. Removing a photo from a draft does not immediately delete a copy still attached to a listing or proposed edit.

8. Your Rights

Subject to applicable law, you may request access, correction, erasure, restriction, portability, object to processing and withdraw consent. You may complain to the Irish Data Protection Commission or another competent supervisory authority. Use the privacy-request form at zoto.ie/support or email hello@zoto.ie; an account or paid membership is not required. Under GDPR, requests normally receive a response within one calendar month; any lawful extension and its reasons must be explained within that month. Privacy & data offers an account-record export and account closure. The export explains its scope; uploaded files, provider-held records and other records needing review can be requested through support. Account closure is not a promise to erase every record held by every provider, or records lawfully retained for accounting or legal claims.

The request form records the information you submit, its receipt time, acknowledgement-delivery status and handling history. These records support handling consumer, privacy and safety requests, meeting applicable legal obligations and documenting decisions. Access is restricted to authorised administrators. An acknowledgement confirms receipt; identity may need proportionate verification before personal data is disclosed or erased. Do not submit passwords, full card details or identity documents in the form.

9. Security

ZOTO uses HTTPS and account/role-based access controls. Security and incident handling require ongoing review. Where a personal-data breach must be reported under GDPR Article 33, the controller must notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware, explaining any delay. Affected people must be informed without undue delay where Article 34 requires it.

10. Children's Privacy

The Platform is not directed at individuals under 18. We do not knowingly collect data from minors; accounts found to belong to minors will be deleted.

11. AI, AI-Generated Content and Automated Decision-Making

11.1 ZOTO uses artificial intelligence to power certain features - for example drafting or improving listing text, assisting in chats, and generating suggestions. Some content you see on the Platform may be AI-generated or AI-assisted; such content may contain errors and should be verified before you rely on it.

11.2 When you use an AI feature, the text you enter (and limited context needed to answer) is sent to third-party AI model providers to generate a response, as described in Section 5. Do not enter sensitive personal data, passwords or payment details into AI prompts.

11.3 ZOTO does not currently use fully automated decision-making producing legal effects. If introduced (e.g., algorithmic job matching), users will be informed and given the right to request human review (GDPR Art. 22).

11.4 New job, event and business listing submissions and proposed edits may be checked through Lovable AI and Google to assist administrators. The check uses the listing details intended for publication, including supplied application or business contacts, and records a recommendation for that version. It does not automatically approve, reject or hide the listing. An administrator decides whether to publish. This listing-review feature does not read private chats, account profiles or Directory photo files.

11.5 Notice published 8 September 2026: additional AI-assisted moderation is planned to start no earlier than 24 September 2026. Housing posts and edits may be checked using their published text and listing details, excluding photos and account profiles. Housing posting and editing remain immediate. New Flight Buddy group messages may be checked automatically. Private referral, Housing and direct chats are checked only when a participant reports a specific message; the check is limited to that message and up to two preceding messages from the same chat within 30 minutes. A whole-chat report without a selected message remains for human review. Existing chat history is not scanned in bulk.

11.6 These additional checks use Lovable AI and Google and give administrators version-specific recommendations. They may make mistakes; a human decides any moderation action. AI does not automatically hide messages or listings, suspend accounts or publish content. If the AI service is unavailable, chat and Housing continue normally and checks may retry. ZOTO stores references, version hashes, bounded recommendations and review history rather than a separate raw-message archive. Reports and message retention continue under the existing retention rules. You can report content or contact hello@zoto.ie to ask for a review of a moderation decision.

12. Changes to this Policy

Material changes are communicated via email or in-app notice at least 15 days before taking effect, with an updated "Last updated" date and, where required, fresh consent.

13. Contact

Data protection queries: hello@zoto.ie. Grievance Officer: [Name and Address]. EU Representative: [Name and Address]. You may also complain to your local EU Data Protection Authority or, in India, the Data Protection Board.