Privacy Policy

1. Who we are and what this covers

Zeeën (we, us, our) respects your privacy and is committed to protecting personal data. This Privacy Policy explains how we collect, use, disclose, store, and protect personal data when you use the Zeeën mobile application, website, and related services (the Services).

Zeeën is a real-world social discovery service that helps people see and connect with others nearby through shared social profiles. Zeeën does not host in-app messaging and is not a dating service.

The Services are operated by Zeeën Global Pte. Ltd. (UEN 202554703W), incorporated in Singapore. Registered office: 61 Robinson Rd, #07-01, Singapore 048547. This policy is built around Singapore's Personal Data Protection Act 2012 (PDPA) and also describes how we meet privacy obligations for users in Australia, New Zealand, the United States, and elsewhere.

Data Protection Officer: governance@zeeen.app.

2. The personal data we collect

We collect only the personal data reasonably necessary to operate Zeeën as a proximity-based social discovery service.

Data you provide

• Name or chosen display name, and username or profile identifier
• Profile photo (optional)
• At least one social media handle or profile link (required)
• Account preferences and visibility settings
• Your marketing-consent choice
• Support, safety, or feedback communications

Location and proximity data

When you choose to use discovery features, we process approximate location (for example city, suburb, or area) and short-range proximity signals indicating that users were near each other within a limited time window. We do not display exact user locations to other users, and we do not show live map pins. Location data is processed only while the app is in use or while discoverability is enabled.

Safety and abuse-prevention data

• Reports you submit, including category and any details
• Records of blocks, so blocked accounts are hidden
• Enforcement outcomes such as warnings, suspensions, and bans

Data collected automatically

• Device type, operating system, and app version
• Device identifiers used for security and abuse prevention
• Log data such as interactions, timestamps, and crash diagnostics
• IP address, used for security and operational integrity

2A. Collection notice

This Privacy Policy serves as our collection notice. Where practicable, we also show a short notice at or before the point of collection (for example, on the sign-up screen) that links here. When we collect your personal data we make clear: who we are and how to contact us (Zeeën Global Pte. Ltd.; governance@zeeen.app); the purposes for which we collect it (see section 3); that some information is required to provide the Services and that, if you do not provide it, we may be unable to create or operate your account; that your personal data may be disclosed to recipients located overseas (see section 8); and how you can access or correct your data, or make a complaint (see section 11).

3. How we use personal data

We use personal data to: create and manage accounts; show nearby profiles and recent proximity encounters based on your settings; operate, maintain, and improve the Services; maintain safety, security, and abuse prevention; respond to support requests; and comply with legal obligations. We do not sell personal data, and we do not use personal data for behavioural advertising outside Zeeën.

4. Marketing and promotional use

We will only use content that identifies you, for example your name, photo, or profile, in marketing, advertising, press, or investor materials if you have given prior opt-in consent. Consent is off by default and you can withdraw it at any time through the in-app control. On withdrawal we stop new promotional uses within a reasonable period, although copies already published may persist.

We never use the image, profile, or identifiable content of a user under 18 in any marketing, advertising, press, or investor material, regardless of any consent.

We may use aggregated or de-identified material that does not identify any individual without consent. The lawful basis for marketing use of identifiable content is your consent.

4A. Marketing communications

We may send marketing and promotional messages, such as product updates and offers, by email using Klaviyo (see section 8). We send these only where you have consented or where we are otherwise permitted to under applicable law. Every marketing message identifies Zeeën as the sender and includes an easy way to unsubscribe.

You can opt out of marketing communications at any time using the unsubscribe link in any message or by emailing governance@zeeen.app, and we will action your request within the timeframes required by law (including within five business days under the Spam Act 2003 (Cth) for users in Australia). Opting out of marketing does not stop essential service, transactional, safety, or account-related messages, which are not marketing.

5. Legal bases for processing

Depending on your location, we rely on one or more of: your consent (for example enabling location-based discovery, or marketing use of identifiable content); performance of the Services you request; our legitimate interests in operating and protecting the platform; and compliance with legal obligations. For users in the European Economic Area, the United Kingdom, or Switzerland, see section 11A for the specific GDPR lawful bases that apply to our processing.

6. Age

Zeeën is currently for users aged 18 and over. It is not intended for anyone under 18.

• You confirm you are at least 18 when you create an account.
• We do not currently collect a date of birth, and signing in with a third-party account (Apple, Google, or Meta) does not verify your age.
• If we have reason to believe a user is under 18, we will remove the account and delete the associated personal data, subject to any legal retention duty.
• We do not use the identifiable content of any user under 18 for marketing or promotional purposes. This remains true regardless of the minimum age in effect.

If you believe a person under 18 has provided personal data to us, contact governance@zeeen.app.

7. How we share personal data

Information you choose to display may be visible to nearby users based on your settings. Zeeën does not host in-app messaging. We use trusted third-party providers for infrastructure, support, and moderation tooling. They may process only the data needed to deliver their service, are bound by contract to protect it, and act only on our instructions. We may disclose limited data where required by law, a regulator, a court, or law enforcement, as described on our Law Enforcement Requests page.

8. Cross-border data transfers and overseas access

Zeeën is operated from Singapore and operates globally. Even where your personal data is stored in your own country, it may be accessed, processed, or disclosed to recipients located overseas.

Our primary hosting for user data is Amazon Web Services in Sydney, Australia. Although Australian users' data is hosted in Australia, it is accessible to and controlled by Zeeën Global Pte. Ltd. in Singapore, along with our authorised personnel and service providers who may be located in Singapore and elsewhere. We also use Intercom (United States) for user support and messaging, Klaviyo (United States) for email, Singular (United States) for install attribution and affiliate referral tracking, and Google reCAPTCHA (United States) to protect our web forms from spam and abuse.

For users in Australia: because your personal information is accessible from and may be disclosed to recipients outside Australia — including in Singapore and the United States — Australian Privacy Principle 8 (cross-border disclosure) applies. We take reasonable steps to ensure overseas recipients handle your personal information consistently with the Australian Privacy Principles, including through contractual controls and access restrictions, and we remain accountable for how they handle it, except where an exception under APP 8.2 applies (for example, where you have consented after being informed that APP 8.1 will not apply). The countries where overseas recipients are likely to be located are Singapore and the United States.

Where data is transferred or accessed across borders, we apply safeguards intended to maintain comparable protection, including contractual controls and restricted access.

9. Data retention

We keep personal data only as long as necessary for the purposes in this policy, unless a longer period is required or permitted by law.

• Account and profile data: kept while your account is active, and deleted within 30 days of a deletion request.
• Proximity and encounter records: shown in the feed for a 24-hour window.
• Safety, enforcement, security, and technical logs: kept for as long as necessary for safety, security, and legal purposes.

10. Data deletion

You may request deletion of your account and personal data at any time, through the in-app help centre or by emailing governance@zeeen.app. On a valid request we disable discoverability immediately, schedule your profile and social links for permanent removal, and delete your personal data within 30 days, subject to legal or security retention duties. Deleting your account does not automatically cancel a subscription bought through Apple or Google; manage those in your Apple or Google account settings.

Additional workflow details are available at /data-deletion, but you do not need that page to request deletion.

11. Your rights

Depending on where you live, you may have rights to access the personal data we hold about you, to correct it, to withdraw consent, and to request deletion. To exercise any right, contact governance@zeeen.app.

• Singapore: access and correction rights and consent withdrawal under the PDPA.
• Australia: access and correction rights under the Privacy Act 1988 and the Australian Privacy Principles, including protections for cross-border disclosure of your personal information under APP 8 (see section 8). You may also complain to the Office of the Australian Information Commissioner (OAIC).
• New Zealand: access and correction rights under the Privacy Act 2020.
• United States: California residents have rights under the CCPA and CPRA, including access, deletion, and to opt out of sale or sharing. We do not sell personal data.

11A. Additional rights for users in the EEA, UK, and Switzerland

If you are located in the European Economic Area, the United Kingdom, or Switzerland, the General Data Protection Regulation (and the UK GDPR and the Swiss Federal Act on Data Protection) give you additional rights in relation to your personal data.

Lawful bases for processing. Where the GDPR applies, we process your personal data on the following bases:

• Performance of a contract, to provide the Services you have requested.
• Your consent, for example enabling location-based discovery, or marketing use of identifiable content.
• Our legitimate interests, in operating and protecting the platform.
• Compliance with our legal obligations.

Your rights. You have the right to:

• Access the personal data we hold about you.
• Have inaccurate or incomplete data corrected.
• Request erasure of your personal data.
• Restrict or object to certain processing.
• Receive your data in a portable format.
• Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

Complaints. You have the right to lodge a complaint with your local data protection authority.

To exercise any of these rights, contact our Data Protection Officer at governance@zeeen.app.

13. Security

We use safeguards designed to protect personal data, including:

• Encryption of data in transit
• Access controls and least-privilege access
• Monitoring and logging for security and abuse signals
• Contractual and operational controls over vendor access

No system is completely secure, and we continue to improve our controls.

14. Data breaches

If a data breach occurs that is likely to result in serious harm, we assess it and notify the relevant regulator and affected individuals as required by applicable law, including the Notifiable Data Breaches scheme in Australia and breach-notification obligations under the PDPA in Singapore.

15. Changes to this policy

We may update this policy from time to time and will post changes with an updated date. For material changes we will notify you in-app or by email before they take effect.

16. Contact

For privacy questions, rights requests, or concerns, contact our Data Protection Officer at governance@zeeen.app.

Operational mailing address: No. 7 Temasek Boulevard, #12-07 Suntec Tower One, Singapore 038987.
Registered office: 61 Robinson Rd, #07-01, Singapore 048547.