LEGAL

Privacy Policy

Effective date: February 4, 2026

1. Introduction

This Privacy Policy explains how Zoltraa Technologies ("Zoltraa", "we", "us", or "our") collects, uses, and discloses information about you when you access or use our services, including the Zoltraa web app (the "Service").

At Zoltraa, we understand that your financial data is among the most sensitive information you can share. We have designed our Service with privacy and security as foundational principles, not afterthoughts. This Privacy Policy is intended to provide you with complete transparency about how we handle your information, what data we collect, how we process it, and most importantly, what we do NOT do with your data. We believe in giving you control over your financial information. This policy outlines the specific technical and organizational measures we have implemented to protect your privacy, including our unique approach to bank statement processing that prioritizes your data security above all else. By using our Service, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with this policy, please do not access or use our Service. We encourage you to read this policy carefully and reach out to us if you have any questions or concerns.

2. Data We Collect

We collect only the minimum amount of information necessary to provide you with our expense tracking and analytics service. We categorize the data we collect into several types:

2.1 Account and Profile Information

When you create an account with Zoltraa, we collect basic identification and contact information that you provide directly to us. This includes your name, email address, and any contact details you choose to share. We collect this information to create and maintain your account, communicate with you about the Service, send you important notifications, and provide customer support when needed. Your email address serves as your primary account identifier and is used for authentication, password recovery, security alerts, and service-related communications. You can update your profile information at any time through your account settings.

2.2 Bank Statement Upload and Transaction Data

This section describes one of the most important aspects of our Service: how we handle your bank statements and the financial transaction data contained within them. What Happens When You Upload a Bank Statement: When you upload a bank statement to Zoltraa, we process it entirely in memory using our proprietary Python-based table scanning technology. This is a critical security feature that distinguishes us from many other financial services. Your uploaded PDF file is NEVER written to disk, NEVER stored in any database, and NEVER retained on our servers beyond the brief processing period. The Processing Workflow: Here is the detailed step-by-step process that occurs when you upload a bank statement: Step 1 - Secure Upload: Your PDF bank statement is uploaded to our servers through an encrypted HTTPS connection. The file is received directly into our application's memory buffer. Step 2 - In-Memory Processing: The PDF file is immediately processed using our Python-based table scanning engine. This engine reads the PDF structure, identifies transaction tables, and extracts relevant transaction data—all while keeping the file exclusively in RAM (random access memory). At no point during this process is the file written to any persistent storage medium such as a hard drive, SSD, or database. Step 3 - Data Extraction: From each transaction row in your bank statement, we extract only the following four pieces of information: the transaction amount, the transaction date, the transaction description (typically the merchant name or transaction type), and the transaction reference number (if available in the statement). We do not extract or retain any other information such as your full account number, sort code, bank name, branch information, opening or closing balances, or any personal identifiers that may appear in statement headers or footers. Step 4 - Tokenization and Encoding: The extracted transaction data is immediately tokenized and encoded for storage in our secure database. Tokenization is a security process that converts sensitive data into non-sensitive tokens that can only be understood by our authorized systems. This means that even if our database were somehow compromised, the tokenized transaction data would be meaningless to any unauthorized party. Step 5 - Immediate Deletion: Once the transaction data has been extracted, tokenized, and encoded, the original PDF file is immediately and permanently deleted from memory. This entire process typically takes between 2 to 3 minutes depending on the size and complexity of your bank statement. After this processing window, no trace of the original PDF exists anywhere in our systems. Step 6 - Secure Storage: Only the tokenized and encoded transaction metadata (amount, date, description, and transaction reference) is stored in our encrypted database. This data is encrypted both at rest and in transit, using industry-standard encryption protocols. Supported File Formats: We currently support bank statements in PDF format only. Our Python-based parsing engine is specifically optimized to read and extract tabular transaction data from PDF documents generated by banks and financial institutions. We do not support image files (JPG, PNG), scanned documents, or other file formats at this time, as these would require different processing technologies that might compromise our security-first approach. What We Do NOT Store: It is equally important to understand what we do NOT collect or store from your bank statements. We do not store your complete bank statement file, your full bank account number, your bank sort code or routing number, your bank's name or branch information, your account opening or closing balances, any personal identification numbers that may appear on the statement, statement headers or footers containing personal information, any images or logos embedded in the PDF, or any other data beyond the four specific transaction fields mentioned above (amount, date, description, and transaction reference). No AI or Machine Learning Processing: We want to be absolutely clear that we do NOT use artificial intelligence, machine learning algorithms, or any form of automated decision-making systems to process your bank statements or transaction data. Our parsing technology is a deterministic, rule-based table scanning system built in Python. This means the extraction process follows explicit programming rules and does not involve any AI models that might inadvertently retain or learn from your financial data. We made this architectural decision specifically to protect your privacy and ensure that your sensitive financial information is never used to train algorithms or contribute to any machine learning datasets.

2.3 Bank Connection Data (Alternative Method)

In addition to manual bank statement uploads, we may offer secure, token-based connections to your bank accounts through trusted banking partners and open banking APIs. When you use this feature, we collect transactional metadata directly from your bank through secure API connections. We do not store your actual bank login credentials; instead, we use secure OAuth-based tokens that grant us limited, read-only access to retrieve transaction data on your behalf. You can revoke these tokens at any time through your account settings or directly through your bank's security settings.

2.4 Usage Data and Technical Information

When you interact with our Service, we automatically collect certain technical information about your device and how you use the Service. This includes your IP address, browser type and version, operating system and version, device identifiers, the pages or features you access within the Service, the time and date of your visits, the time spent on specific pages, and the referring website or source that directed you to our Service. We collect this information to understand how users interact with our Service, identify technical issues, improve our user interface and experience, enhance security by detecting unusual access patterns, and optimize the performance and reliability of our platform. This data is aggregated and anonymized whenever possible and is not used to personally identify you except when necessary for security purposes (such as detecting fraudulent login attempts).

2.5 Location Data

With your explicit permission, we may collect approximate location data based on your IP address or device GPS coordinates. We use location data to enhance security by flagging login attempts from unusual locations, provide localized features and insights, and improve the overall relevance of our Service to your specific geographic context. You can control location permissions through your device settings or browser settings at any time. We do not track your precise real-time location or create detailed location histories.

2.6 Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to enhance your experience on our Service. Cookies are small text files stored on your device that help us recognize you, remember your preferences, keep you logged in between sessions, and understand how you use the Service. We use several types of cookies: Essential cookies that are necessary for the Service to function properly (such as authentication cookies), functional cookies that remember your preferences and settings, analytics cookies that help us understand usage patterns and improve the Service, and security cookies that protect your account from unauthorized access. You can control cookie preferences through your browser settings. However, please note that disabling essential cookies may affect your ability to use certain features of the Service. For more detailed information about our cookie practices, please refer to our separate Cookies Policy.

3. How We Use Your Data

We use the information we collect solely to provide, maintain, improve, and protect our Service. We do not sell your personal information to third parties, and we do not use your financial data for any purpose other than delivering the expense tracking and analytics features you expect from Zoltraa.

3.1 Authentication and Account Management

We use your account information to authenticate your identity when you log in, verify that you are authorized to access specific account data, manage your account settings and preferences, enable password reset and account recovery processes, and maintain the security and integrity of your account. Authentication is a critical security function that ensures only you can access your financial data within our Service.

3.2 Transaction Data Processing and Analytics

The core purpose of our Service is to provide you with meaningful insights into your spending patterns and financial behavior. We use the transaction data extracted from your bank statements (amount, date, description, and transaction reference) to perform various analytical functions on your behalf. Specifically, we use this data to: Categorize your transactions automatically based on merchant names and descriptions. For example, transactions at grocery stores are categorized as "Groceries," transactions at gas stations as "Transportation," and so forth. This categorization is performed using rule-based logic and predefined merchant databases—not AI or machine learning. Aggregate your spending across different categories and time periods to generate spending reports, charts, and visualizations that help you understand where your money goes. Identify spending trends and patterns over time, such as increases or decreases in specific categories, recurring transactions, and seasonal variations in your expenses. Calculate summary statistics such as total monthly spending, average transaction amounts, most frequent merchants, and highest spending categories. Generate personalized insights and recommendations to help you manage your finances more effectively. These insights are based solely on your own transaction patterns and are not influenced by other users' data or external algorithms. Enable you to search, filter, and review your transaction history through our intuitive interface, making it easy to find specific transactions or analyze particular time periods.

3.3 Service Personalization

We use your usage patterns and preferences to customize your experience with the Service. This includes remembering your preferred currency, date format, and display settings, showing you the most relevant insights and reports based on your spending patterns, organizing your dashboard to highlight the information most important to you, and adapting the interface based on your interactions and feedback. Personalization enhances usability and ensures that Zoltraa works the way you want it to.

3.4 Communication and Support

We use your contact information to communicate with you about important matters related to your account and the Service. This includes sending you transactional emails such as account verification, password reset confirmations, and security alerts, notifying you of important updates to our Service, Privacy Policy, or Terms of Service, responding to your support requests and inquiries, providing customer service and technical assistance when you encounter issues, and occasionally sending you product announcements or feature updates that we believe may be of interest to you. You can opt out of non-essential communications at any time through your account settings or by following the unsubscribe link in our emails.

3.5 Security and Fraud Prevention

We use technical information, including IP addresses, device identifiers, and usage patterns, to protect the security of your account and our Service. This includes detecting and preventing unauthorized access attempts, identifying suspicious login patterns or unusual account activity, protecting against fraud, abuse, and malicious activities, monitoring for security vulnerabilities and potential threats, and enforcing our Terms of Service and acceptable use policies. These security measures are essential to maintaining the trust and safety of our platform.

3.6 Service Improvement and Analytics

We analyze aggregated and anonymized usage data to understand how users interact with our Service and identify opportunities for improvement. This helps us fix bugs and technical issues, optimize the performance and speed of our platform, develop new features and functionality that users need, improve our user interface and user experience design, and make data-driven decisions about product development and resource allocation. This analysis is conducted on anonymized data that cannot be traced back to individual users, ensuring your privacy is protected even during our internal analytics processes.

3.7 Legal Compliance

In certain circumstances, we may need to use or disclose your information to comply with legal obligations, such as responding to valid legal requests from law enforcement or regulatory authorities, enforcing our legal rights and agreements, preventing fraud or illegal activities, protecting the safety and security of our users and the public, and complying with applicable financial regulations and data protection laws. We will only disclose your information when legally required to do so and will make reasonable efforts to notify you of such requests unless prohibited by law.

4. Data Sharing and Disclosure

Zoltraa is committed to keeping your financial data private and secure. We do not sell, rent, or trade your personal information or transaction data to third parties for marketing purposes. We share your information only in the limited circumstances described below, and always with appropriate safeguards to protect your privacy.

4.1 No Third-Party Data Sharing for Statement Processing

One of the most important aspects of our privacy commitment is that we do NOT share your bank statements or transaction data with any third-party services for processing, analysis, or any other purpose. Unlike many financial technology services that rely on third-party data processors, OCR services, or cloud storage providers to handle sensitive financial documents, Zoltraa processes all bank statement uploads entirely in-house using our own proprietary technology. When you upload a bank statement, it is processed exclusively on our own secure servers using our Python-based table scanning engine. We do not use any third-party optical character recognition (OCR) services, external document processing APIs, third-party cloud storage solutions for uploaded files, external machine learning or AI services for data extraction, or any other third-party services that would require sharing your bank statement or transaction data. This approach significantly reduces the risk of data breaches, unauthorized access, or misuse of your financial information because your sensitive data never leaves our controlled environment during the processing stage. Our commitment to in-house processing means fewer entities have access to your data, creating a more secure and private experience.

4.2 Service Providers and Infrastructure Partners

While we do not share your bank statements with third parties, we do work with a limited number of trusted service providers who help us operate and maintain the infrastructure that powers the Zoltraa Service. These service providers may have access to certain categories of data, but never your raw bank statements or unencrypted transaction details. The types of service providers we may work with include: Cloud Hosting Providers: We use reputable cloud infrastructure providers to host our application servers and databases. However, as stated earlier, your uploaded bank statement files are never stored on these servers—they are processed in memory and immediately deleted. Only encrypted and tokenized transaction metadata is stored in our databases. Security and Monitoring Services: We may use security services to monitor for threats, detect intrusions, and protect against cyberattacks. These services have access to system logs and technical data but do not have access to your financial transaction data. Email Service Providers: We use third-party email services to send you transactional emails, security alerts, and account notifications. These providers have access to your email address and the content of the messages we send, but not your financial data. Customer Support Tools: We may use customer support platforms to manage support tickets and communicate with you when you need assistance. Support representatives have access only to the information necessary to resolve your issue and are bound by strict confidentiality obligations. All service providers are carefully vetted and are contractually obligated to protect your information with the same level of security and privacy that we maintain ourselves. They are prohibited from using your data for their own purposes and must comply with all applicable data protection laws and regulations.

4.3 Banking Partners and Open Banking Providers

If you choose to connect your bank account directly to Zoltraa using our token-based connection feature (as an alternative to manual statement uploads), we work with regulated banking partners and open banking service providers to securely retrieve your transaction data. These partners are licensed financial institutions or authorized open banking providers that operate under strict regulatory oversight. We share only the minimum information necessary to establish and maintain these connections, and all data transfers occur through secure, encrypted channels. You can disconnect your bank account at any time, which immediately revokes our access to retrieve new transactions.

4.4 Legal Requirements and Law Enforcement

We may disclose your information if we are required to do so by law or if we believe in good faith that such disclosure is necessary to comply with legal processes such as a court order, subpoena, or search warrant, respond to claims that any content violates the rights of third parties, protect the rights, property, or safety of Zoltraa, our users, or the public, or comply with regulatory requirements imposed by financial authorities or data protection regulators. Whenever possible and legally permissible, we will notify you before disclosing your information in response to legal requests, giving you an opportunity to challenge the request if you choose to do so. We carefully review all legal requests to ensure they are valid and disclose only the specific information required by law.

4.5 Business Transfers and Corporate Transactions

In the event that Zoltraa is involved in a merger, acquisition, asset sale, bankruptcy, or other corporate transaction, your information may be transferred to the acquiring entity or successor organization. In such circumstances, we will require the receiving party to honor the commitments made in this Privacy Policy and provide you with notice of the transfer and any choices you may have regarding your information. Your data will remain subject to appropriate confidentiality obligations during and after any such transaction.

4.6 Aggregated and Anonymized Data

We may create aggregated, anonymized, or de-identified data from the information we collect, which cannot be used to identify you personally. This aggregated data may be used for research, analytics, product development, and industry reporting purposes. For example, we might analyze aggregated spending trends across all users to understand broader economic patterns or improve our categorization algorithms. This aggregated data does not contain any personally identifiable information and cannot be traced back to individual users.

5. Data Retention and Security

Protecting your financial data is our highest priority. We have implemented comprehensive technical and organizational security measures to safeguard your information from unauthorized access, disclosure, alteration, and destruction.

5.1 Data Retention Policies

We retain your information only for as long as necessary to provide you with the Service, fulfill the purposes described in this Privacy Policy, and comply with legal obligations. Our specific retention policies vary depending on the type of data: Uploaded Bank Statement Files: As described in detail in Section 2.2, uploaded bank statement PDF files are NEVER stored on our servers. These files are processed entirely in memory and are permanently deleted immediately after the transaction data has been extracted and encoded—typically within 2 to 3 minutes of upload. There is no retention period for these files because they are never persisted to any storage medium in the first place. Once deleted from memory, the files cannot be recovered by anyone, including Zoltraa employees or administrators. Extracted Transaction Data: The tokenized and encrypted transaction metadata (amount, date, description, and transaction reference) that we extract from your bank statements is stored in our secure database for as long as you maintain an active account with Zoltraa. This data is essential to providing you with the core functionality of the Service—tracking expenses, generating reports, and analyzing spending patterns over time. If you delete specific transactions through your account interface, they are permanently removed from our database. If you close your account, all of your transaction data is permanently deleted as described in Section 6.3 below. Account Information: Your account and profile information (name, email, contact details) is retained for as long as your account remains active. After you close your account, we may retain certain account information for a limited period to comply with legal obligations, resolve disputes, enforce our agreements, and prevent fraud. Typically, this retention period does not exceed 90 days after account closure, unless a longer retention period is required by law or necessary to protect our legal interests. Usage Data and Technical Logs: Technical logs, including IP addresses, access timestamps, and usage patterns, are retained for security and troubleshooting purposes. These logs are typically retained for up to 12 months, after which they are automatically purged from our systems. Security incident logs may be retained for longer periods if necessary for ongoing investigations or legal proceedings.

5.2 Encryption and Data Security Measures

We employ multiple layers of security controls to protect your data throughout its lifecycle: Encryption in Transit: All data transmitted between your device and our servers is protected using industry-standard TLS (Transport Layer Security) encryption. This includes bank statement uploads, API requests, and any other communication with our Service. TLS encryption ensures that your data cannot be intercepted or read by unauthorized parties during transmission over the internet. Encryption at Rest: All data stored in our databases, including your tokenized transaction metadata and account information, is encrypted at rest using strong encryption algorithms. This means that even if someone gained unauthorized physical access to our servers or storage media, they would not be able to read your data without the encryption keys, which are stored separately and protected with additional security controls. Tokenization: As described earlier, transaction data extracted from your bank statements is immediately tokenized before storage. Tokenization replaces sensitive data elements with non-sensitive tokens that have no exploitable value. This adds an additional layer of security beyond encryption, ensuring that your actual transaction details are protected even within our own systems. Secure File Processing: The in-memory processing of bank statement uploads is a critical security feature. By never writing uploaded files to disk, we eliminate entire categories of security risks, including unauthorized access to stored files, data leakage through backup systems, forensic recovery of deleted files, and exposure through compromised storage infrastructure. Immediate Deletion Protocols: After transaction data is extracted from an uploaded bank statement, the original file is immediately and securely deleted from memory using secure deletion methods that overwrite the memory space to prevent any possibility of recovery. This happens automatically and is not dependent on any manual action by our staff.

5.3 Access Controls and Authentication

We implement strict access controls to ensure that only authorized personnel can access sensitive systems and data. This includes role-based access control (RBAC) that limits employee access to only the data and systems necessary for their job functions, multi-factor authentication (MFA) required for all administrative access to production systems, regular access reviews and audits to ensure that permissions remain appropriate, immediate revocation of access when employees leave the company or change roles, and comprehensive audit logging of all access to sensitive data and systems. For your own account security, we strongly recommend that you enable two-factor authentication (2FA) and use a strong, unique password that you do not use for any other service.

5.4 Security Monitoring and Incident Response

We continuously monitor our systems for security threats, vulnerabilities, and suspicious activities. Our security program includes automated intrusion detection systems that alert us to potential attacks, regular vulnerability assessments and penetration testing by independent security experts, real-time monitoring of system logs for anomalous behavior, security patches and updates applied promptly to address known vulnerabilities, and a formal incident response plan that defines how we detect, contain, and remediate security incidents. In the unlikely event of a data breach that affects your information, we will notify you promptly in accordance with applicable laws and regulations, provide you with information about what happened and what data was affected, and offer guidance on steps you can take to protect yourself.

5.5 Compliance and Certifications

While we have not explicitly mentioned specific compliance frameworks like PCI-DSS or SOC 2 in your requirements, we want to assure you that our security practices are designed to align with industry best practices and regulatory expectations for handling financial data. We regularly review and update our security policies and procedures to reflect evolving threats, new technologies, and changes in regulatory requirements. Our goal is to maintain a security posture that meets or exceeds the standards expected of financial technology companies.

5.6 Employee Training and Awareness

All Zoltraa employees undergo mandatory security awareness training to understand the importance of data protection, recognize security threats, and follow secure practices in their daily work. Employees with access to sensitive systems receive additional specialized training. We foster a culture of security awareness throughout our organization, ensuring that protecting your data is everyone's responsibility.

5.7 Physical Security

While our application and data infrastructure is cloud-based, we rely on reputable cloud providers that maintain robust physical security controls at their data centers, including 24/7 security personnel, biometric access controls, video surveillance, environmental controls to prevent equipment damage, and redundant power and network connectivity to ensure availability. We carefully select cloud providers that hold relevant security certifications and comply with international data protection standards.

6. Your Rights and Choices

You have significant control over your personal information and how it is used within the Zoltraa Service. We respect your rights and provide you with the tools and mechanisms to exercise those rights effectively.

6.1 Access to Your Information

You have the right to access the personal information we hold about you. Through your account dashboard, you can view your profile information, review all stored transaction data, see your account activity history, and access reports and insights generated from your data. If you need a comprehensive copy of all personal information we hold about you, you can submit a formal data access request by contacting us at privacy@zoltraa.example. We will respond to your request within 30 days and provide you with a structured, machine-readable export of your data.

6.2 Correction and Updates

You have the right to correct any inaccurate or incomplete personal information we hold about you. You can update your profile information (name, email, contact details) directly through your account settings at any time. For transaction data, you can edit transaction descriptions or categories through the transaction management interface. If you believe other information we hold is inaccurate and you cannot correct it yourself, please contact us and we will investigate and make necessary corrections.

6.3 Data Deletion and the Right to Be Forgotten

You have the right to request deletion of your personal information, subject to certain legal limitations. You can exercise this right in several ways: Deleting Individual Transactions: You can delete individual transactions or groups of transactions at any time through your account interface. When you delete a transaction, it is permanently removed from our database and cannot be recovered. This gives you granular control over what data you want to retain. Account Closure and Complete Data Deletion: You can close your Zoltraa account at any time by accessing the account settings and selecting the option to close your account. When you close your account, all of your personal information and transaction data is permanently deleted from our active systems within 30 days. This includes your profile information, all stored transaction metadata, usage history and preferences, and any other data associated with your account. Please note that we may retain certain information for a limited period after account closure if required by law, necessary to resolve disputes, enforce our agreements, or prevent fraud. However, this retention period typically does not exceed 90 days, and the retained information is securely isolated and not used for any operational purposes. Requesting Expedited Deletion: If you need your data deleted more urgently than the standard 30-day account closure process, you can submit a formal deletion request to privacy@zoltraa.example. We will prioritize your request and complete the deletion within 7 business days, subject to any legal obligations that may require us to retain certain information.

6.4 Data Portability

While we do not currently offer an automated data export feature that allows you to download your transaction data in a portable format, you have the right to request a copy of your data for transfer to another service. If you wish to export your data, please contact us at privacy@zoltraa.example with your request. We will provide you with a structured export of your transaction data in a commonly used format (such as CSV or JSON) within 30 days. Please note that this export will include only the transaction metadata we store (amount, date, description, transaction reference)—we cannot provide the original bank statement files as these are never stored in our systems.

6.5 Restriction of Processing

In certain circumstances, you have the right to restrict how we process your personal information. This means we will store your data but not actively use it for any purposes. You might request restriction of processing if you contest the accuracy of your data and want us to pause processing while we verify its accuracy, you believe our processing is unlawful but you prefer restriction rather than deletion, we no longer need the data but you need us to retain it for legal claims, or you have objected to processing and are awaiting verification of whether our legitimate interests override your objection. To request restriction of processing, please contact us at privacy@zoltraa.example. We will respond to your request within 30 days.

6.6 Objection to Processing

You have the right to object to certain types of processing of your personal information, particularly processing based on our legitimate interests. If you object to processing, we will stop processing your information unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for legal claims. To object to processing, please contact us at privacy@zoltraa.example with details about what processing you are objecting to and why.

6.7 Communication Preferences

You have control over the communications you receive from us. You can opt out of promotional emails by clicking the "unsubscribe" link at the bottom of any marketing email we send you, or by adjusting your communication preferences in your account settings. Please note that even if you opt out of promotional communications, we will still send you transactional emails related to your account, such as security alerts, password reset confirmations, and important service updates that are necessary for the operation of your account.

6.8 Cookie Preferences

You can control cookie preferences through your browser settings. Most browsers allow you to block all cookies, accept only certain cookies, or receive notifications when cookies are being set. Please note that if you block essential cookies, some features of the Service may not function properly. For more information about our use of cookies and how to manage them, please see our separate Cookies Policy.

6.9 Location Data Permissions

If you have granted us permission to access your location data, you can revoke this permission at any time through your device settings (for mobile apps) or browser settings (for web access). Revoking location permissions will not affect your ability to use the core features of the Service, but may impact certain location-based features or security measures.

6.10 Exercising Your Rights

To exercise any of the rights described in this section, you can contact us at privacy@zoltraa.example. When submitting a request, please provide sufficient information to allow us to verify your identity and locate your account. This typically includes your name, email address associated with your account, and a description of the specific right you wish to exercise. We will respond to all requests within 30 days of receipt. If your request is particularly complex or you have made multiple requests, we may extend this period by up to 60 additional days, in which case we will notify you of the extension and explain the reason for the delay. There is no charge for exercising your rights unless your requests are manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable administrative fee or decline to act on the request.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience with the Zoltraa Service, remember your preferences, keep you logged in, and understand how you use our platform. A cookie is a small text file that is stored on your device when you visit a website. Cookies allow websites to recognize your device, remember your preferences, and provide you with a more personalized and seamless experience across multiple visits.

7.1 Types of Cookies We Use

Essential Cookies: These cookies are necessary for the Service to function properly and cannot be disabled without severely impacting your ability to use the platform. Essential cookies enable core functionality such as user authentication (keeping you logged in), security features (protecting against cross-site request forgery attacks), session management (maintaining your session state as you navigate the Service), and load balancing (ensuring requests are routed to the appropriate servers). Without these cookies, many features of the Service would not work correctly. Functional Cookies: Functional cookies remember your preferences and settings to provide you with a more personalized experience. These include cookies that remember your preferred language, currency, and display settings, store your dashboard layout preferences and customizations, remember whether you've seen certain notices or tutorials, and save your filter and sorting preferences. Functional cookies enhance usability but are not strictly necessary for the Service to operate. Analytics Cookies: We use analytics cookies to understand how users interact with the Service and identify opportunities for improvement. These cookies collect anonymized information about page views, navigation patterns, feature usage, time spent on different pages, and error messages or issues encountered. This data helps us improve the user experience, fix bugs, optimize performance, and develop new features that users need. Analytics cookies do not collect personally identifiable information and the data is aggregated across all users. Security Cookies: Security cookies help us detect and prevent fraudulent activity and protect your account from unauthorized access. These cookies enable us to detect suspicious login patterns, verify that requests are coming from legitimate users, implement rate limiting to prevent abuse, and enforce security policies such as session timeouts. Security cookies are essential to maintaining the safety and integrity of the Service.

7.2 Third-Party Cookies

We do not use third-party advertising cookies or allow advertisers to place cookies on our Service. However, we may use third-party service providers for essential functions such as analytics and security monitoring, and these providers may set their own cookies. Any third-party cookies are subject to the privacy policies of those third parties, and we encourage you to review those policies to understand how your information is used.

7.3 Cookie Duration

Cookies may be session cookies (which expire when you close your browser) or persistent cookies (which remain on your device until they expire or you delete them). We use both types depending on the purpose of the cookie. Session cookies are used for authentication and security, while persistent cookies are used to remember your preferences and improve your experience across multiple visits.

7.4 Managing Cookie Preferences

You can control and manage cookies through your browser settings. Most modern browsers allow you to block all cookies, accept only first-party cookies, receive notifications when cookies are being set, or delete existing cookies. The process for managing cookies varies by browser, but is typically found in the privacy or security settings section. Please be aware that if you block or delete essential cookies, you may not be able to use certain features of the Service, and your experience may be significantly degraded. Blocking functional or analytics cookies will not prevent you from using the Service, but may affect the personalization and quality of your experience. For more detailed information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org or www.youronlinechoices.com.

7.5 Other Tracking Technologies

In addition to cookies, we may use other tracking technologies such as web beacons (also known as pixel tags or clear GIFs) and local storage. Web beacons are tiny graphics with a unique identifier that are embedded in emails or web pages to track whether content has been viewed. Local storage is a technology that allows websites to store data on your device similar to cookies but with greater capacity. We use these technologies for similar purposes as cookies, including analytics, security, and improving the Service.

8. International Transfers

Zoltraa is a global service, and your information may be transferred to, stored in, and processed in countries other than your country of residence. These countries may have data protection laws that differ from the laws of your country. When we transfer your information internationally, we take appropriate steps to ensure that your data receives adequate protection and that the transfer complies with applicable data protection laws. Our safeguards include implementing standard contractual clauses approved by relevant regulatory authorities, working only with service providers that maintain adequate data protection standards, conducting privacy impact assessments for high-risk transfers, ensuring encryption of data in transit and at rest regardless of geographic location, and regularly reviewing and updating our data transfer practices to reflect changes in international data protection requirements. If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we ensure that transfers of personal data to countries outside these regions are protected by appropriate safeguards as required by the General Data Protection Regulation (GDPR) and other applicable laws. These safeguards may include the use of standard contractual clauses, adequacy decisions by the European Commission recognizing certain countries as providing adequate protection, or other legally recognized transfer mechanisms. If you have questions about international transfers of your data or would like more information about the specific safeguards we have implemented, please contact us at privacy@zoltraa.example.

9. Children's Privacy

The Zoltraa Service is not intended for use by individuals under the age of 18, or the age of majority in their jurisdiction, whichever is higher. We do not knowingly collect personal information from children. Financial services such as expense tracking and bank statement analysis are designed for adults who manage their own finances. If we become aware that we have inadvertently collected personal information from a child under 18 without proper parental consent, we will take immediate steps to delete that information from our systems. If you are a parent or guardian and believe that your child has provided personal information to us, please contact us at privacy@zoltraa.example and we will promptly investigate and delete the information. We take the protection of children's privacy seriously and maintain processes to verify the age of users where appropriate and prevent unauthorized account creation by minors.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other operational, legal, or regulatory reasons. When we make changes, we will update the "Effective date" at the top of this policy to indicate when the changes take effect. If we make material changes to this Privacy Policy that significantly affect your rights or how we use your information, we will provide you with prominent notice before the changes take effect. This may include sending you an email notification to the email address associated with your account, displaying a prominent notice on our website or within the Service, or using other appropriate communication channels. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information and the choices available to you. Your continued use of the Service after changes to the Privacy Policy have been posted constitutes your acceptance of the updated policy. If you do not agree with any changes to the Privacy Policy, you may close your account at any time by following the account closure process described in Section 6.3.

11. Your California Privacy Rights

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) regarding your personal information. These rights include the right to know what personal information we collect, use, disclose, and sell about you, the right to request deletion of your personal information subject to certain exceptions, the right to opt-out of the sale or sharing of your personal information (note: we do not sell your personal information), the right to correct inaccurate personal information, the right to limit the use and disclosure of sensitive personal information, and the right to non-discrimination for exercising your privacy rights. To exercise any of these rights, please contact us at privacy@zoltraa.example. We will respond to verifiable consumer requests within 45 days as required by law. We may extend this period by an additional 45 days when reasonably necessary, in which case we will notify you of the extension and the reason for it. We do not sell personal information, and we do not discriminate against users who exercise their privacy rights. You have the right to designate an authorized agent to submit requests on your behalf, subject to verification requirements.

12. Your European Privacy Rights

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) and equivalent local laws. In addition to the rights described throughout this Privacy Policy, you have the right to lodge a complaint with your local data protection authority if you believe we have not complied with applicable data protection laws, the right to withdraw consent at any time where we rely on consent as the legal basis for processing your information, the right to object to processing based on legitimate interests, and the right to receive information about the legal basis for each processing activity. We process your personal information based on several legal bases, including performance of a contract (to provide the Service you have requested), legitimate interests (to improve the Service, prevent fraud, and ensure security), legal obligations (to comply with applicable laws), and consent (where we have asked for and received your specific consent). For questions about our processing of your information or to exercise your rights under the GDPR, please contact us at privacy@zoltraa.example.

13. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or how we handle your information, we encourage you to contact us. We take all privacy inquiries seriously and will investigate and respond to your concerns promptly. You can reach us at: Email: privacy@zoltraa.example Subject Line: Privacy Inquiry - [Your Issue] Response Time: We aim to respond to all privacy inquiries within 5 business days, and to resolve most issues within 30 days. When contacting us, please provide as much detail as possible about your question or concern, including your account email address (to help us locate your account), a description of the issue or request, and any relevant supporting information or documentation. This will help us address your inquiry more efficiently and effectively. We value your feedback and are committed to maintaining your trust. If you believe we have not adequately addressed your privacy concerns, you have the right to contact your local data protection authority or seek other legal remedies available to you. Thank you for trusting Zoltraa with your financial data. We are committed to protecting your privacy and providing you with transparent, secure, and user-friendly expense tracking services.