ZenGen Privacy Policy

Effective Date: February 19, 2026

Last Updated: June 1, 2026

1. Introduction

ZenGen ("we," "our," or "us") operates the ZenGen mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. By using ZenGen, you agree to the collection and use of information as described in this policy. If you do not agree with any part of this policy, please do not use our App. We are committed to protecting your privacy and ensuring you have a positive experience using our application. This policy describes your choices regarding use, access, and correction of your personal information.

2. Information We Collect

We collect only the minimum amount of information necessary to provide you with a functional, personalized meditation experience.

2.1 Information You Provide Directly

• Name: Used to personalize your in-app experience (e.g., greetings, session summaries). • Email Address: Used for account identification and recovery purposes. We do not send marketing emails unless you explicitly opt in to receive them. • Phone Number: Collected optionally during onboarding. If — and only if — you enter a phone number AND check the promotional messaging box, your phone number is stored in our database (hosted by our backend provider, Supabase) and used to send you promotional text messages, such as membership specials, discounts, and free-gift offers. Providing your number and opting in is entirely optional and is never required to create an account or use the App. If you do not opt in, your phone number is not transmitted to or stored on our servers. You can opt out of promotional texts at any time by replying STOP to any message or by emailing support@zengen.app, and your number is permanently deleted when you delete your account. • Voice Recordings and Transcripts: When you use the meditation recording feature, your voice is temporarily captured and sent to OpenAI through our secure backend proxy for transcription. Raw audio recordings are not permanently stored on our servers. The resulting transcript, generated meditation script, mood, duration, and timestamp are stored as part of your session history so we can display your past sessions, maintain continuity across devices, and support account deletion/export workflows. Third-party processors may retain submitted audio or text for limited periods under their own data retention policies for trust, safety, abuse monitoring, and service reliability.

2.2 Information Generated by the App

• Meditation Session Data: Transcribed voice or typed input, duration, mood selection, generated meditation scripts, summaries, and timestamps associated with each session. • Streak and Usage Data: Current streak count, longest streak, daily session counts, and minutes used per day to provide you with gamification and progress-tracking features. • Interaction Timestamps: The date and time you initiate a recording session. This data is used exclusively to calculate an optimal notification time and is stored locally on your device. It is never transmitted to any server. • Subscription Status: Whether you are on the free or premium tier, subscription expiration dates, and pending downgrade status.

2.3 Information Collected Automatically

• Device Information: Device model, operating system version, and unique device identifiers may be collected by Apple as part of standard App Store operations. We do not independently collect device fingerprints or hardware identifiers. • Crash and Diagnostic Data: If you opt in to share diagnostics with Apple, anonymized crash reports may be shared with us through App Store Connect. These reports do not contain personally identifiable information. • We do NOT use cookies, tracking pixels, advertising identifiers (IDFA), or any third-party analytics SDKs.

2.4 Information We Do NOT Collect

• We do not collect your precise or approximate geographic location. • We do not access your contacts, photos, camera, calendar, or any other device resources beyond the microphone (used solely for recording your meditation input). • We do not collect browsing history, search queries, or data from other applications on your device. • We do not collect biometric data (fingerprints, face scans, etc.). • We do not collect financial information for in-app purchases. Subscription payment processing is handled entirely by Apple through the App Store; we never see, store, or have access to your credit card number, bank account, or Apple Pay details. (If you participate in the Affiliate Program, payout banking and tax information is collected and processed by our payment processor, Stripe — not by us; see Section 2.5.)

2.5 Affiliate Program Information

This section applies only if you choose to apply to or participate in the optional ZenGen Affiliate Program. We do not collect this information from ordinary app users. When you apply, we collect the information you submit and additional information needed to administer the program, which may include: your legal name, date of birth, email address, phone number, home or mailing address, government-issued identification details (such as driver's license number, issuing state, and expiration date), and the websites or social channels where you intend to promote ZenGen. We use this information to verify your identity, prevent fraud and abuse, evaluate your application, administer referral attribution, commissions, and payouts, and comply with our tax and legal obligations. We may share necessary information with identity-verification services and with our payment processor, Stripe. Stripe collects and processes your banking and tax information (such as a W-9 or W-8) to deliver payouts and issue tax forms (such as a Form 1099); we do not store your full bank or tax details ourselves. Affiliate application and verification records are retained for as long as necessary for the purposes above and to meet legal, tax, and audit requirements, even if your application is declined or your participation ends. The handling of your information in connection with the program is also described in the ZenGen Affiliate Agreement.

3. How Your Data Is Stored

Your privacy is foundational to our architecture. We employ a local-first storage model wherever possible.

3.1 Local Device Storage

The majority of your data is stored locally on your device using Apple's standard secure storage mechanisms (UserDefaults and the app's sandboxed file system). This includes: • Your profile information (name, email) • Your phone number, if you provided one (also stored on our servers when you opt in to promotional text messages — see Section 2.1) • Meditation session history and scripts • Streak and usage statistics • Notification interaction timestamps • Audio files for session replay (premium feature) • Subscription status and preferences Because this data resides on your device, it is subject to the same security protections as all other data on your iPhone or iPad. This means your device passcode, Face ID, Touch ID, and iOS data protection encryption all safeguard your ZenGen data. The security of your ZenGen data is therefore directly related to the security practices you maintain on your device, including: keeping your device software up to date, using a strong passcode, enabling biometric authentication, and being cautious about which apps you install and the permissions you grant them.

3.2 Cloud Synchronization

For account continuity and data backup, certain data may be synchronized to our secure cloud backend (hosted by Supabase, a trusted infrastructure provider). This includes: • Your profile information (name, email, tier status) • Meditation session data (transcribed or typed input, mood, duration, script text, summaries, and timestamps) Your phone number is included in cloud synchronization only when you opt in to promotional text messages. If you do not opt in, it remains on your device only. Cloud-stored data is encrypted in transit using TLS 1.2 or higher and encrypted at rest using AES-256 encryption. Access to our backend is restricted to authenticated requests using unique user identifiers. We do not permanently store raw audio recordings in the cloud.

3.3 Data Retention

• Local data persists on your device until you uninstall the App or manually clear the App's data through your device settings. • Cloud-synchronized data is retained as long as your account exists. If you request account deletion, we will permanently remove all associated data within 30 days. • Transcribed voice input, typed input, generated scripts, summaries, moods, durations, and timestamps are retained as part of your session history unless and until your account is deleted or the data is otherwise removed under this policy. Raw voice recordings are processed to create a transcript and are not permanently stored on our servers. Third-party processors may retain submitted audio or text for limited periods under their own data retention policies.

4. How We Use Your Information

We use the information we collect solely to provide, maintain, and improve the ZenGen experience: • To generate personalized meditation sessions based on your voice input and mood. • To track your meditation streaks, session history, and daily usage limits. • To calculate an optimal daily notification time that aligns with your meditation habits. • To process and manage your subscription (free or premium tier). • To personalize greetings and in-app messaging using your name. • To send promotional text messages (such as membership specials, discounts, and free gifts) to users who opt in by entering a phone number and checking the promotional messaging box. Message frequency varies, and message and data rates may apply. Reply STOP at any time to opt out. Consent to receive these messages is not a condition of purchasing or using the App. • Account access is provided exclusively through Sign in with Apple; we do not use your phone number for account recovery. • To improve our App's performance, fix bugs, and develop new features based on anonymized, aggregated usage patterns. We do NOT use your data for advertising, profiling, behavioral targeting, or any purpose unrelated to the direct functionality of the App.

5. Third-Party Services

We use a limited number of third-party services strictly necessary for the App's core functionality: • OpenAI API: When you record audio, your raw audio is sent to OpenAI through our secure backend proxy for transcription. Your transcribed or typed input may then be sent to OpenAI to generate meditation scripts, mood analysis, summaries, and related text features. OpenAI's data usage policies apply to this processing. As of this writing, OpenAI does not use API-submitted data to train models. • ElevenLabs API: Generated meditation scripts are sent to ElevenLabs for text-to-speech synthesis (voice generation). ElevenLabs processes the text to produce audio and returns it to the App. We do not send any personal information (name, email, etc.) to ElevenLabs. • Apple StoreKit / App Store: Subscription purchases and management are handled entirely by Apple. Apple's privacy policy governs all payment and subscription data. • Supabase: Our backend infrastructure provider for cloud data synchronization. Supabase acts as a data processor on our behalf and is contractually obligated to protect your data. They do not independently access or use your data. Aside from the processors described above, third parties do not receive your name, email, or phone number, except that if you opt in to promotional text messages we may share your phone number with a text-message delivery provider (for example, an SMS gateway) solely so it can deliver those messages to you on our behalf. We do not integrate any advertising networks, social media SDKs, or third-party analytics platforms, and we do not sell your personal information.

6. Data Sharing and Disclosure

We do not sell, rent, lease, or trade your personal information to any third party. Period. We do not share your data with third parties for their marketing or advertising purposes. We may disclose your information only in the following limited circumstances: • Legal Obligation: If we are required to do so by law, regulation, legal process, or governmental request (e.g., a subpoena, court order, or request from a law enforcement agency). • Protection of Rights: If disclosure is necessary to protect the rights, property, or safety of ZenGen, our users, or the public. • Business Transfers: In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your data may be transferred to the successor entity. We will notify you via in-app notice before your data becomes subject to a different privacy policy. • With Your Consent: We may share your data if you provide explicit, informed consent for a specific purpose.

7. Sensitive Information and Health Data

ZenGen is a meditation and wellness application. While users may share information about their emotional state or feelings during meditation recordings, ZenGen is NOT a medical device, healthcare provider, or health service, and the information you share is NOT treated as Protected Health Information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA) or similar health data regulations. However, we recognize the sensitive nature of personal reflections and emotional expressions. We treat all user-generated content with the highest degree of care: • Your voice recordings are processed transiently and never stored permanently. • Meditation scripts derived from your input are stored locally on your device and optionally synchronized in encrypted form. • We do not analyze, profile, or categorize users based on their emotional state for any commercial purpose. • We do not share emotional or wellness-related data with insurers, employers, healthcare providers, advertisers, or any other third party. • We do not make any health claims, diagnoses, or treatment recommendations. If you are experiencing a mental health emergency, please contact your local emergency services or a crisis helpline. ZenGen is not a substitute for professional medical advice, diagnosis, or treatment.

8. Children's Privacy

ZenGen is not directed to children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take steps to delete that information promptly. If you are a parent or guardian and believe your child has provided personal information to us, please contact us at the address below so we can take appropriate action.

9. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal data: • Right to Access: You may request a copy of all personal data we hold about you. • Right to Correction: You may update or correct your personal information at any time through the Edit Profile feature in the App. • Right to Deletion: You may request the deletion of your account and all associated data. Upon request, we will permanently delete all cloud-stored data within 30 days. Local data can be removed by uninstalling the App. • Right to Data Portability: You may request your data in a structured, commonly used, machine-readable format. • Right to Restrict Processing: You may request that we limit how we use your data. • Right to Object: You may object to the processing of your data for certain purposes. • Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing. To exercise any of these rights, please contact us using the information provided in Section 15.

10. California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with additional rights: • Right to Know: You may request the categories and specific pieces of personal information we have collected, the sources of collection, the business purpose for collection, and the categories of third parties with whom we share data. • Right to Delete: You may request deletion of your personal information, subject to certain exceptions. • Right to Opt-Out of Sale: We do NOT sell your personal information. As such, there is no need to opt out. • Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights. To make a verifiable consumer request, please contact us using the information in Section 15.

11. Washington and Nevada Residents (MHMDA / SB 370)

If you are a resident of Washington State or Nevada, state consumer health data laws — including Washington's My Health My Data Act (MHMDA) and Nevada's Senate Bill 370 — may apply to certain data processed by ZenGen. Because ZenGen collects voice recordings related to your emotional state, this information may be classified as "consumer health data" under these laws. We want to be transparent about how we handle it: • Purpose Limitation: We process consumer health data (your spoken reflections and the emotional context derived from them) solely and exclusively for the purpose of providing you with the personalized meditation service you requested. We do not use this data for any other purpose. • No Sale of Health Data: We do NOT sell, rent, trade, or otherwise make available your consumer health data to any third party for commercial purposes. Period. • Third-Party Processing: Consumer health data is shared with third-party processors (OpenAI for transcription and script generation; ElevenLabs for voice synthesis) only as strictly necessary to deliver the service. These processors are contractually prohibited from using your data for their own purposes. • Consent: By using ZenGen and accepting this Privacy Policy, you provide your informed, affirmative consent to the collection and processing of consumer health data as described herein. You may withdraw this consent at any time by discontinuing use of the App and requesting account deletion. • Right to Delete: You may request deletion of all consumer health data by contacting us. We will honor such requests within 30 days. If you have questions about your rights under MHMDA or SB 370, please contact us using the information in Section 15.

12. European Economic Area, United Kingdom, and Swiss Residents (GDPR)

If you reside in the European Economic Area (EEA), United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) and related laws provide you with enhanced data protection rights. Legal Bases for Processing: • Consent: We process your voice recordings and profile data based on your explicit consent, which you provide by using the App and accepting this Privacy Policy. • Contractual Necessity: We process subscription and account data as necessary to fulfill our contractual obligations to you. • Legitimate Interests: We process anonymized usage data to improve the App, provided such processing does not override your fundamental rights. International Data Transfers: Your data may be transferred to and processed in the United States. We ensure appropriate safeguards (such as Standard Contractual Clauses approved by the European Commission) are in place for such transfers. Data Protection Officer: For GDPR-related inquiries, please contact us using the information in Section 15.

13. Security

We implement commercially reasonable technical and organizational security measures to protect your data, including: • Encryption in transit (TLS 1.2+) and at rest (AES-256) for all cloud-stored data. • Secure, sandboxed local storage on your device as enforced by iOS. • API key security with server-side request validation. • Role-based access controls for our backend infrastructure. • Regular security reviews and updates. No method of electronic storage or transmission is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the security of your device and credentials.

14. Generative AI and Large Language Model Data Practices

ZenGen uses generative artificial intelligence ("AI") and large language models ("LLMs") provided by third-party services to deliver personalized meditation experiences. This section describes how your data interacts with these AI systems. What Data Is Processed by AI. When you use the App, the following data may be sent to third-party AI providers for processing: voice recordings (for transcription), transcribed text (for mood analysis and meditation script generation), and session metadata (for personalized insights such as journey recaps and mantras). Third-Party AI Providers. Our current AI providers include OpenAI (for transcription and text generation) and ElevenLabs (for text-to-speech audio synthesis). These providers process your data according to their own terms of service and privacy policies, which may change over time. We encourage you to review their policies directly. How AI Providers May Use Your Data. While we configure our AI integrations to minimize data retention and prohibit training on user data where such options are available, we cannot guarantee how third-party AI providers ultimately process, store, or handle data submitted to their services. AI provider practices may evolve as the technology and regulatory landscape changes. Evolving Technology. The AI models and services underlying the App are subject to updates, modifications, and replacements by their providers. These changes may affect how your data is processed and are outside our direct control. We will update this Privacy Policy to reflect material changes in our AI providers or data practices when we become aware of them. Data Minimization. We take steps to limit the data sent to AI providers to what is necessary for the App's core functionality. We do not send your name, email, Apple ID, or account information to AI providers. Only session-related content (transcriptions and text) is transmitted for processing. Your Choices. By using ZenGen, you consent to the processing of your session data by third-party AI services as described above. If you do not wish your data to be processed by AI systems, you should discontinue use of the App.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will: • Update the "Last Updated" date at the top of this policy. • Provide prominent in-app notice of the changes. • Where required by law, obtain your renewed consent. Your continued use of the App after any changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: ZenGen Support Email: privacy@zengen.app We will respond to all privacy-related inquiries within 30 days.

By using ZenGen, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.