ZYNTRA – PRIVACY POLICY

Last Updated: March, 2025

LEGAL HEADER

This Privacy Policy (“Policy”) governs the manner in which BrainX, a private company incorporated under the laws of England and Wales, with operational presence in Nigeria (“BrainX,” “Zyntra,” “we,” “us,” or “our”), collects, uses, processes, stores, shares, and protects Personal Data (defined below) relating to users (“you” or “users”) of the Zyntra Platform (defined below).

Zyntra is wholly owned by BrainX Innovative Systems Ltd., which operates as a subsidiary of PreciousX, a global technology and innovation group.

BrainX is committed to ensuring that your privacy and Personal Data are protected in accordance with applicable laws, including but not limited to:

·       The United Kingdom General Data Protection Regulation (UK GDPR);

·       The European Union General Data Protection Regulation (EU GDPR);

·       The California Consumer Privacy Act (CCPA);

·       The Nigerian Data Protection Act (NDPA);

·       Applicable privacy and data protection laws in jurisdictions where Zyntra operates.

This Policy applies to all products and services provided by Zyntra through:

·       The Zyntra core social network;

·       Lounge Spaces;

·       Hubs and Clubs;

·       Marketplace and Deals;

·       Pulse;

·       FundIt;

·       WorkZYN;

·       SkillZYN;

·       Zyntra Wallet systems;

·       Affiliate Program;

·       Verification Program;

·       API services;

·       Official websites and mobile applications;

·       All other services provided under the Zyntra brand (collectively, the “Zyntra Platform”).

By accessing or using the Zyntra Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection, use, and processing of your Personal Data as described herein.

If you do not agree to this Policy, you should not access or use the Zyntra Platform.

FULL TABLE OF CONTENTS

1. Introduction and Overview

2. Scope of This Privacy Policy

3. Definitions

4. Types of Personal Data We Collect

5. How We Collect Personal Data

6. Legal Bases for Processing Personal Data

7. Purposes for Which We Process Personal Data

8. Automated Processing, Profiling, and AI Usage

9. Disclosure of Personal Data to Third Parties

10. International Data Transfers

11. Data Retention and Deletion

12. Data Security and Integrity

13. User Rights and Data Subject Rights

14. Exercising Your Rights

15. Use of Cookies and Tracking Technologies

16. Third-Party Services and Integrations

17. Children’s Privacy and Minimum Age

18. Community and Public Content Considerations

19. Financial Transactions and Wallet Data

20. Verification and KYC Data

21. Monetization Programs and Earnings Data

22. Affiliate Program Data

23. Marketplace and Deals Data

24. Fundit and Pulse Events Data

25. Lounge Spaces Data

26. Data Sharing in Clubs and Hubs

27. User-Generated Content and Intellectual Property

28. Business Account Data

29. Behavioral Analytics and Personalization

30. Marketing Communications and Opt-Out Options

31. Data Breach Notification and Response

32. Changes to This Privacy Policy

33. Contact Information and Enforcement

INTRODUCTION AND OVERVIEW

1.1 Statement of Commitment to Data Privacy

At Zyntra, we understand that data privacy is fundamental to building and maintaining user trust.
We are committed to upholding the highest standards of privacy protection and transparency in our handling of personal data.
We recognize that our users, as individuals, expect clarity and control over how their personal data is used.

Zyntra is built on the principles of:

• User empowerment

• Community trust

• Transparency

• Accountability

• Fairness

• Respect for privacy rights

We are dedicated to providing a safe, trusted, and compliant environment for our diverse global user base.

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1.2 Nature of the Zyntra Platform

Zyntra is an advanced, multi-layered social ecosystem that provides users with a dynamic, customizable experience.
Unlike traditional social networks, Zyntra integrates a wide range of modules and services into a unified platform.

Key features include:

• Lounge Spaces: Real-time conversation spaces supporting text, audio, and video interactions

• Clubs: Interest-based communities for collaborative engagement

• Hubs: Public and private branded spaces for organizations, movements, and fanbases

• Marketplace: Digital and physical goods and services marketplace

• Deals: Promotional and time-sensitive offers posted by users and businesses

• Pulse: Event discovery and management system

• FundIt: Crowdfunding for personal, creative, and community causes

• WorkZYN: Job and gig marketplace

• SkillZYN: Platform for online courses and professional learning

• Zynts: Platform-based reward system that allows users to earn for participation and engagement

• Honors: Community recognition system

• Affiliate Program: Revenue-sharing through user-driven referrals

• Monetization Programs: Various avenues for earning income through content, community building, and services

• Wallets: Dual Wallet System (Social Network Wallet and Lounge Wallet) supporting payments, earnings, and financial transactions

Because of this broad functionality, Zyntra processes a wide range of personal data across multiple contexts and user interactions.

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1.3 Core Privacy Principles

Zyntra adheres to the following core privacy principles:

1. Lawfulness, Fairness, and Transparency: We process personal data lawfully, fairly, and in a transparent manner.

2. Purpose Limitation: We collect personal data for explicit, specified, and legitimate purposes only.

3. Data Minimization: We limit personal data collection to what is necessary for those purposes.

4. Accuracy: We take steps to ensure that personal data is accurate and up to date.

5. Storage Limitation: We retain personal data only as long as necessary for the purposes for which it was collected, subject to applicable legal requirements.

6. Integrity and Confidentiality: We ensure that personal data is processed in a manner that maintains security and confidentiality.

7. Accountability: We take responsibility for compliance with these principles and can demonstrate compliance upon request by data protection authorities or users.

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1.4 Scope of this Privacy Policy

This Privacy Policy applies to personal data processed in connection with:

• Your use of Zyntra’s website and mobile applications

• Your interactions with Zyntra’s various modules and features, including but not limited to:

  • Lounge Spaces

  • Clubs

  • Hubs

  • Marketplace

  • Deals

  • Pulse

  • FundIt

  • WorkZYN

  • SkillZYN

  • Zynts and Honors systems

  • Affiliate Program

  • Monetization Programs

  • Verification Program

• Your use of Zyntra Wallets: Social Network Wallet and Lounge Wallet

• Your communications with Zyntra Support & Help Center

• Your interactions with Zyntra’s APIs or third-party integrations

• Zyntra’s use of cookies and tracking technologies

• Zyntra’s marketing and advertising communications

• Business Accounts on Zyntra

This Privacy Policy also applies to personal data collected from:

• Users who browse public-facing Zyntra content without creating an account

• Business partners, advertisers, and affiliates who engage with Zyntra’s platform

This Privacy Policy does not apply to:

• Third-party websites, services, or apps linked to or integrated with Zyntra, where Zyntra does not control the data collection or processing practices

• Processing performed by third-party services that operate independently of Zyntra

Users are encouraged to consult the privacy policies of third-party services they choose to engage with through or in connection with Zyntra.

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1.5 Global Platform, Cross-Border Data Processing

Zyntra is a global platform, operated by a UK-registered entity with operations in multiple jurisdictions and users worldwide.

Because of the nature of internet-based services, Zyntra’s systems may transfer, store, or process personal data in:

• The United Kingdom

• The European Economic Area (EEA)

• Nigeria

• Other jurisdictions where Zyntra or its partners operate

Zyntra implements appropriate safeguards for international data transfers, including:

• Standard Contractual Clauses (SCCs)

• Data processing agreements

• Adequacy decisions (where applicable)

• Additional technical and organizational measures to ensure data security

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1.6 Evolving Platform and Continuous Improvement

Zyntra is an evolving platform. As new features are developed and released, and as legal frameworks change, this Privacy Policy will be updated to reflect:

• New data collection and processing practices

• Enhanced user controls and transparency features

• Updates to legal obligations and compliance measures

We are committed to continuous privacy improvement and invite users to review this Policy regularly to stay informed.

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1.7 User Trust and Engagement

At Zyntra, we view privacy not just as a compliance requirement but as a core part of our user value proposition.

We believe that:

• Transparent communication builds trust

• User control empowers individuals

• Accountability fosters responsible innovation

This Privacy Policy is one element of our broader Trust and Safety commitment, which also includes:

• A clear Terms of Service

• Published Community Guidelines

• Monetization Policy

• Verification Rules

• Security Policy

• Data Deletion Request Policy

We encourage users to explore these resources to fully understand their rights and responsibilities on Zyntra.

DATA CONTROLLER AND LEGAL ENTITIES

2.1 Purpose of this Section

This section defines the scope and applicability of the Zyntra Privacy Policy ("Policy") and establishes the legal and operational boundaries within which this Policy governs the collection, use, processing, sharing, and storage of personal data by Zyntra.

This section clarifies:

• What services are covered by this Policy;

• What types of users and data subjects the Policy applies to;

• The geographical applicability of this Policy;

• Limitations of this Policy with respect to third-party services and integrations;

• The relationship between this Policy and other Zyntra legal documents.

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2.2 Services and Features Covered by this Policy

This Privacy Policy applies to all personal data processed by Zyntra in connection with any and all of the following services and features provided directly by Zyntra or under the Zyntra brand:

A. Core Zyntra Platform Services

• The Zyntra social platform accessible via https://zyntra.social and related domains and subdomains;

• Zyntra’s official mobile applications for iOS, Android, and other supported platforms;

• Zyntra’s desktop applications (if any);

• Zyntra’s web-based user interfaces and administrative portals.

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B. Specific Modules and Functional Areas of the Platform

This Policy covers personal data processing arising from user interactions with, or participation in, the following core modules and features of Zyntra:

• Lounge Spaces (text, audio, video-based real-time community spaces);

• Clubs (interest-based groups and communities);

• Hubs (public or private branded or organizational spaces);

• Marketplace (for the buying and selling of physical and digital goods and services);

• Deals (short-term, time-sensitive promotional offers);

• Pulse (event organization, promotion, ticketing, and participation);

• FundIt (community-driven crowdfunding for personal, creative, or community causes);

• WorkZYN (job listings, gig opportunities, and employment-related features);

• SkillZYN (learning, course offerings, and educational content);

• Zynts (reward system for platform engagement and monetization activities);

• Honors (peer-recognition and community status system);

• Affiliate Program (user-driven referral and revenue sharing program);

• Monetization Programs (various platform-supported earning opportunities);

• Verification Program (identity verification, Know Your Customer (KYC) processes, and platform trust features).

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C. Zyntra Financial and Transactional Systems

This Policy applies to personal data processed in connection with Zyntra’s dual wallet system, including:

• The Social Network Wallet (used for general platform monetization, earnings, payments, subscriptions, and tips);

• The Lounge Wallet (used for monetization and financial activity specific to Lounge Spaces).

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D. Zyntra User Support and Communications Channels

This Policy applies to personal data collected through:

• Zyntra’s Support & Help Center accessible via https://support.zyntra.social;

• All user-initiated communications with Zyntra support teams;

• Zyntra’s moderation and trust & safety channels.

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E. Zyntra API and Developer Ecosystem

This Policy applies to:

• Personal data processed via Zyntra’s APIs (Application Programming Interfaces);

• Zyntra’s developer platform (if applicable);

• Third-party integrations and applications authorized by users to access their data through Zyntra’s API ecosystem.

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F. Business and Enterprise Services

This Policy applies to personal data processed in connection with:

• Zyntra’s Business Accounts;

• Zyntra’s advertising services (if applicable);

• Zyntra’s brand partnerships;

• Participation in Zyntra’s affiliate, sponsorship, or promotional programs.

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2.3 Categories of Users Covered by this Policy

This Policy applies to the following categories of data subjects (collectively referred to as “users” unless otherwise specified):

A. Registered Users

• Individuals who create and maintain a Zyntra user account (including Pro Membership tiers);

• Business users operating Business Accounts or managing Hubs.

B. Unregistered Users and Visitors

• Individuals who browse public portions of the Zyntra platform without creating an account;

• Individuals who receive marketing or informational communications from Zyntra.

C. Contributors to Platform Features

• Content creators, Marketplace sellers, FundIt campaign owners, Pulse event organizers, SkillZYN course providers, and Affiliate Program participants.

D. Support Interactions

• Individuals who contact Zyntra’s Support & Help Center (whether or not they are registered users).

E. Legal Representatives

• Individuals acting on behalf of organizations or minors in accordance with applicable laws.

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2.4 Geographical Applicability of this Policy

This Privacy Policy is designed to comply with the data protection laws of all jurisdictions in which Zyntra operates or where its users are located, including but not limited to:

• United Kingdom (UK GDPR);

• European Economic Area (EU GDPR);

• Nigeria (NDPA);

• Other applicable national, federal, state, or provincial privacy laws.

Where required, Zyntra provides:

• Localized Privacy Notices or supplements to this Policy;

• Localized user rights mechanisms;

• Localized legal bases for processing personal data.

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2.5 Relationship with Other Zyntra Legal Documents

This Privacy Policy should be read in conjunction with, and is subject to, the following legal documents:

• Zyntra Terms of Service;

• Zyntra Monetization Policy;

• Zyntra Verification Rules;

• Zyntra Community Guidelines;

• Zyntra DMCA / Copyright Policy;

• Zyntra Cookie Policy;

• Other official policies published by Zyntra from time to time.

In the event of any conflict between this Privacy Policy and the Terms of Service, the provision that is more protective of the user’s personal data will prevail.

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2.6 Third-Party Services and Limitations of this Policy

This Privacy Policy does not apply to the data practices of:

• Third-party websites, applications, or services linked to or integrated with Zyntra;

• External API partners not controlled by Zyntra;

• Payment processors acting as independent controllers (though Zyntra seeks to work with trusted partners);

• Social login providers (e.g., Google, Facebook, LinkedIn, X/Twitter).

Users should review the privacy policies of such third parties before engaging with them.

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2.7 Modifications to this Scope

As Zyntra evolves and expands:

• The scope of this Policy may be updated;

• New features and services may be added to the list of covered services;

• Users will be notified of material changes as described in Section 32 (Changes to This Privacy Policy).

3. DEFINITIONS

For the purposes of this Privacy Policy, the following definitions shall apply:

“Affiliate Program” means Zyntra’s program allowing users and Marketplace sellers to earn commissions by referring new users, members, and subscribers.

“API” means Application Programming Interface, enabling controlled external access to certain Zyntra platform services.

“Business Account” means an account registered and operated on behalf of a business, organization, or other legal entity, rather than an individual natural person.

“CCPA” means the California Consumer Privacy Act of 2018, as amended.

“Children” means natural persons under the age of 16, or such higher minimum age as may be imposed by local law.

“Club” means an interest-based group within Zyntra.

“Cookie” means a small text file placed on a user’s device by Zyntra or authorized third parties to enable certain platform functions or collect data.

“Data Controller” has the meaning defined in the UK GDPR and EU GDPR.

“Data Processor” means any party that processes Personal Data on behalf of the Data Controller.

“EU GDPR” means the European Union General Data Protection Regulation (Regulation (EU) 2016/679).

“FundIt” means Zyntra’s community-driven crowdfunding feature.

“Hub” means a public or private page on Zyntra representing a movement, organization, brand, or community.

“KYC” means Know Your Customer — a verification process required for certain monetization and financial features.

“Lounge Spaces” or “Spaces” means real-time interactive chat environments on the Zyntra Platform.

“Marketplace” means Zyntra’s e-commerce platform for listing, selling, and purchasing physical and digital goods and services.

“Monetization Programs” means programs enabling users to earn income through participation on the Zyntra Platform.

“NDPA” means the Nigerian Data Protection Act.

“Personal Data” means any information relating to an identified or identifiable natural person.

“Platform” or “Zyntra Platform”** means the entirety of services and features offered under the Zyntra brand, including the core social network, Lounge Spaces, Hubs, Clubs, Marketplace, Deals, Pulse, FundIt, WorkZYN, SkillZYN, Wallet systems, Affiliate Program, Verification Program, APIs, official websites, and apps.

“PreciousX” means the parent company of BrainX.

“Processing” means any operation performed on Personal Data, whether automated or not.

“Pro Membership” means Zyntra’s paid membership tiers (Creator, Elite, Patron).

“Pulse” means Zyntra’s event promotion and management functionality.

“SkillZYN” means Zyntra’s platform for educational courses and learning content.

“UK GDPR” means the United Kingdom General Data Protection Regulation.

“User” means any natural person or Business Account that accesses or uses the Zyntra Platform.

“Verification Program” means Zyntra’s identity verification (KYC) processes for enhanced trust and eligibility in monetization programs.

“Wallet” means Zyntra’s integrated payment and financial system, including both Social Network Wallet and Lounge Wallet.

“WorkZYN” means Zyntra’s job marketplace feature.

“Zynts” means Zyntra’s merit-based internal earning system.

CATEGORIES OF PERSONAL DATA WE COLLECT

4.1 General Statement of Scope

Zyntra is a complex multi-functional platform offering a wide variety of features — including social networking, e-commerce, learning, monetization, real-time collaboration, API access, and financial services — all of which necessarily involve the collection and processing of significant volumes of Personal Data from users.

The categories of Personal Data we collect may vary depending on:

·       The services you use;

·       The device(s) and technologies you interact with;

·       The manner and frequency of your platform engagement;

·       The applicable legal requirements in your jurisdiction;

·       The level of identity verification (e.g., Pro Membership, Monetization Program participation, Business Account operation);

·       Your participation in optional programs such as the Affiliate Program or API partnerships.

We maintain strict internal data classification standards to ensure that the scope of data collection is proportionate, lawful, and purpose-driven in alignment with the principles of transparency and data minimization as required by global privacy laws.

4.2 Categories of Personal Data Collected

Without limitation, Zyntra may collect and process the following categories of Personal Data:

A. Account Registration and Profile Data

·       Full legal name

·       Username or handle

·       Email address

·       Date of birth

·       Phone number

·       Country of residence

·       Preferred language(s)

·       Profile picture, avatar, or banner image

·       Short biography or “about me” section

·       Links to personal or business websites and social profiles

·       Account creation timestamp and status

·       Referral data (Affiliate Program)

·       Membership tier and subscription status (Trial, Creator, Elite, Patron)

B. Identity Verification (KYC) and Verification Program Data

When required (e.g., to access Monetization Programs, withdraw Zynts, or operate a Business Account), Zyntra may collect:

·       Government-issued identification (passport, national ID, driver’s license, etc.)

·       Proof of address (utility bill, bank statement, lease document, etc.)

·       Selfie or biometric verification for identity confirmation

·       Identity verification result and audit trail

·       KYC verification status

·       Date and method of verification

C. User-Generated Content Data

Throughout the use of the Zyntra Platform, users may post and interact with various forms of content, which may involve:

·       Text posts (e.g., Insights, comments, replies)

·       Images

·       Videos (including Zyntra TV, Zeels, and Lounge Spaces video feeds)

·       Audio recordings

·       Live-streamed content

·       File attachments (where permitted by feature)

·       Metadata associated with uploaded content (e.g., location, device data, timestamps)

D. Platform Activity and Usage Data

Zyntra collects detailed data on user interaction with the Platform, including but not limited to:

·       Login and logout timestamps

·       Device and browser fingerprints

·       IP address and geolocation data

·       Page views and session duration

·       Navigation paths within the Platform

·       Content viewed or interacted with (including engagement metrics)

·       Participation in Lounge Spaces, Clubs, Hubs

·       Creation, joining, and leaving of Clubs and Lounge Spaces

·       Use of Marketplace and Deals features

·       Participation in Pulse events or FundIt campaigns

·       Interactions with other users (friends, followers, subscribers, moderators, etc.)

·       Participation in Affiliate Program

·       Participation in API integration programs

E. Financial and Wallet Data

As a platform offering various forms of monetization, financial transactions, and Wallet services, Zyntra collects:

·       Wallet balances (Social Network Wallet and Lounge Wallet)

·       Transaction history

·       Payout requests and payout processing data

·       Bank account or crypto wallet information (as required for payouts)

·       Subscription and membership payment records

·       Marketplace sales and purchases

·       FundIt campaign contributions

·       Tips received and sent

·       Zynts earning history

·       Affiliate earnings and commission history

·       Payment method information (via third-party processors)

F. Communications Data

In providing both public and private communication channels, Zyntra collects:

·       Messages sent within Lounge Spaces

·       Private messages between users

·       Comments and replies on public content

·       Direct user-to-user communications

·       Support tickets and user inquiries to the Support & Help Center

·       Emails sent to/from Zyntra regarding account and services

·       Moderator actions and user reports

G. Device and Technical Data

To operate, secure, and optimize the Platform, Zyntra collects:

·       Device type (desktop, mobile, tablet, other)

·       Operating system and version

·       Browser and version

·       Device model and manufacturer

·       Unique device identifiers

·       Screen resolution and display settings

·       Network and connectivity data

·       Diagnostic and crash reports

·       Device language and locale settings

H. Cookies and Tracking Technologies

Through its Cookie Policy and consent mechanisms, Zyntra collects:

·       Cookie identifiers

·       Session cookies

·       Persistent cookies

·       Third-party tracking pixels (where lawful)

·       Behavioral data for personalization

·       Analytics data

·       Advertising and retargeting data

·       A/B testing and feature usage data

I. Sensitive Data (with Explicit Consent)

In certain use cases, and only with explicit user consent where required by law, Zyntra may process:

·       Biometric data (for verification and fraud prevention)

·       Location data (for personalized content, safety features, local regulations)

·       Special categories of Personal Data (where the user voluntarily provides it, such as in profile fields, content, or community participation)

4.3 Data Relating to Non-Registered Users

Where lawful, Zyntra may collect limited Personal Data about:

·       Visitors to public portions of the Platform

·       Third parties mentioned in public user content

·       Individuals interacting with content shared externally (e.g., via public links)

4.4 Aggregated and Anonymized Data

Zyntra also processes aggregated, anonymized, and pseudonymized data for:

·       Analytics;

·       Business intelligence;

·       Platform optimization;

·       Research and development;

·       Regulatory reporting.

Such data is not considered Personal Data under applicable law when it no longer identifies an individual.

4.5 Data Minimization and Purpose Limitation

Zyntra adheres to the principles of data minimization and purpose limitation, ensuring that Personal Data is:

·       Collected only for specific, explicit, and legitimate purposes;

·       Adequate, relevant, and limited to what is necessary;

·       Processed lawfully, fairly, and transparently.

SOURCES OF PERSONAL DATA

5.1 Direct Collection from Users

The vast majority of Personal Data processed by Zyntra is collected directly from users when they:

·       Register an account;

·       Complete or update their profile;

·       Interact with Platform features;

·       Create or publish content;

·       Participate in monetization or verification programs;

·       Engage in financial transactions on the Platform;

·       Communicate with other users or Zyntra;

·       Respond to surveys or feedback requests.

5.2 Automatically Collected Data

Certain data is collected automatically through:

·       Server logs;

·       Cookies and tracking technologies;

·       Device and browser interactions;

·       API usage telemetry;

·       Platform security systems.

5.3 Third-Party Sources

Zyntra may also obtain Personal Data from:

·       Social login providers (Google, Facebook, X, LinkedIn), with your authorization;

·       Verification service providers (KYC partners);

·       Payment processors;

·       API partners;

·       Affiliate Program partners;

·       Publicly available sources (where lawful);

·       Business partners and service providers.

5.4 User-Generated Personal Data about Others

When users post content mentioning or depicting others, they may generate Personal Data about third parties.
Users are responsible for ensuring that:

·       They have the legal right to share such data;

·       Such sharing complies with Zyntra Community Guidelines and Terms of Service.

5.5 Combination of Data

Zyntra may combine Personal Data from:

·       Multiple sources;

·       Different Platform features;

·       Internal analytics systems;

·       User engagement profiles.

Such combinations are used for:

·       Security and fraud detection;

·       Personalization;

·       Feature optimization;

·       Legal compliance.

LEGAL BASIS FOR PROCESSING PERSONAL DATA

6.1 General Principles

Zyntra operates in full compliance with global data protection regulations, including but not limited to:

·       The United Kingdom General Data Protection Regulation (UK GDPR);

·       The European Union General Data Protection Regulation (EU GDPR);

·       The California Consumer Privacy Act (CCPA);

·       The Nigerian Data Protection Act (NDPA);

·       Other applicable data protection and privacy laws.

The lawful basis on which Zyntra processes Personal Data varies depending on:

·       The specific category of Personal Data involved;

·       The purpose of processing;

·       The jurisdiction of the user;

·       The features and services the user engages with.

6.2 Primary Legal Bases

A. Performance of Contract

Zyntra processes Personal Data as necessary to fulfill its obligations under the Terms of Service, which constitute a binding contract between Zyntra and each user.

Examples of processing under this basis include:

·       Account registration and management;

·       Provision of core Platform features (Lounge Spaces, Hubs, Clubs, Marketplace, Deals, Pulse, FundIt, WorkZYN, SkillZYN);

·       Processing financial transactions and Wallet operations;

·       Facilitating content sharing and communications;

·       Providing customer support;

·       Managing user preferences;

·       Administering the Affiliate Program and Monetization Programs.

B. Compliance with Legal Obligations

Zyntra is subject to numerous legal obligations that require the processing of Personal Data, including but not limited to:

·       KYC (Know Your Customer) and identity verification under financial regulations;

·       Tax reporting and compliance;

·       Anti-money laundering (AML) and counter-terrorist financing (CTF) obligations;

·       Consumer protection laws;

·       Data retention and audit requirements;

·       Responding to valid legal process (e.g., subpoenas, court orders, regulatory investigations).

Where required, Zyntra may retain certain Personal Data even after a user account is closed to satisfy legal obligations.

C. Legitimate Interests

Zyntra also processes Personal Data where necessary to further its legitimate interests, provided that such interests are not overridden by the user’s rights and freedoms.

Legitimate interests include:

·       Ensuring platform integrity and security;

·       Detecting and preventing fraud, abuse, or illegal activity;

·       Protecting users and the broader Zyntra community;

·       Operating and improving platform features;

·       Personalizing content and recommendations;

·       Conducting business analytics;

·       Supporting product innovation;

·       Facilitating corporate governance and compliance monitoring.

Where required by law, Zyntra conducts balancing tests to ensure that its legitimate interests do not disproportionately impact user privacy.

D. Consent

Certain forms of Personal Data processing are conducted only with the explicit, informed, and unambiguous consent of the user.

These may include:

·       Processing of sensitive Personal Data (e.g., biometrics for verification);

·       Use of cookies and tracking technologies (where consent is required);

·       Personalized advertising (in jurisdictions requiring opt-in);

·       Location-based services;

·       Participation in optional features (e.g., Beta features, partner programs).

Users have the right to withdraw consent at any time, without affecting the lawfulness of prior processing based on consent.

E. Vital Interests

In rare cases, Zyntra may process Personal Data to protect the vital interests of the user or another person — for example:

·       Responding to safety threats or emergencies;

·       Cooperating with emergency services in life-critical situations.

6.3 Jurisdictional Variations

Zyntra adapts its legal bases to comply with jurisdiction-specific requirements, including:

·       “Sale of personal information” restrictions under CCPA;

·       Consent obligations under NDPA and other African privacy frameworks;

·       Special processing rules under EU GDPR and UK GDPR;

·       Sector-specific obligations (e.g., financial services, online marketplaces, content moderation).

PURPOSES FOR WHICH PERSONAL DATA IS USED

7.1 General Statement

Zyntra uses Personal Data in a purpose-driven and proportionate manner, consistent with:

·       The platform’s mission and legitimate business interests;

·       The user’s expectations and consent;

·       The applicable legal and regulatory framework;

·       Industry best practices for data protection.

7.2 Detailed Purposes

A. Account Creation, Identity Verification, and User Management

·       To register user accounts and manage account lifecycles;

·       To verify user identity where required (e.g., Monetization Programs, Wallet withdrawals);

·       To determine eligibility for certain services and features;

·       To maintain accurate and secure account records;

·       To support account recovery and authentication;

·       To enforce minimum age requirements and protect minors.

B. Provision of Platform Features and Services

·       To deliver core Zyntra services, including Lounge Spaces, Clubs, Hubs, Marketplace, Deals, Pulse, FundIt, WorkZYN, SkillZYN;

·       To enable user-generated content creation and sharing;

·       To support real-time communications (text, audio, video);

·       To process Marketplace transactions and payments;

·       To administer FundIt campaigns and donations;

·       To manage membership subscriptions and Pro Membership tiers.

C. Platform Personalization

·       To provide personalized content recommendations;

·       To adapt user experiences based on preferences, interactions, and behavioral patterns;

·       To optimize search, discovery, and feed algorithms;

·       To personalize notifications and alerts;

·       To deliver localized services where lawful.

D. Community Governance and Content Moderation

·       To enforce Zyntra Terms of Service and Community Guidelines;

·       To detect, investigate, and prevent violations, abuse, and illegal conduct;

·       To administer content moderation workflows;

·       To maintain user safety and platform integrity;

·       To support appeals processes and transparency reporting.

E. Monetization Programs and Financial Transactions

·       To administer Zynts earning mechanisms;

·       To calculate and manage Wallet balances;

·       To process payouts to users;

·       To manage Affiliate Program earnings;

·       To process Marketplace sales and purchases;

·       To calculate transaction fees;

·       To issue financial statements and reports to users;

·       To comply with tax reporting obligations.

F. Verification and Compliance

·       To perform KYC checks and verify user identities;

·       To monitor compliance with AML/CTF regulations;

·       To support risk management and fraud prevention;

·       To retain required records for audit and regulatory reporting.

G. Communications with Users

·       To send transactional notifications (e.g., purchase confirmations, payout notices);

·       To send security and account alerts;

·       To notify users of policy changes or platform updates;

·       To respond to support requests;

·       To conduct user surveys and feedback collection.

H. Marketing and Promotions

·       To promote platform features and membership upgrades;

·       To send personalized offers (where lawful);

·       To manage Affiliate Program marketing;

·       To conduct A/B testing and campaign optimization.

Users may opt out of marketing communications as provided by law.

I. Analytics, Research, and Innovation

·       To conduct platform analytics and business intelligence;

·       To develop new features and services;

·       To measure platform performance and growth;

·       To understand user engagement and behavior;

·       To support research partnerships and innovation projects.

J. Security, Integrity, and Legal Obligations

·       To protect against unauthorized access, hacking, and fraud;

·       To monitor system integrity and service availability;

·       To cooperate with law enforcement and regulators;

·       To respond to legal process and compliance requests;

·       To defend against legal claims.

7.3 Purpose Limitation and Transparency

Zyntra adheres to strict purpose limitation:

·       Personal Data is not used for purposes that are incompatible with those stated in this Policy, unless required by law or with the user’s explicit consent;

·       Any new purposes will be disclosed transparently and lawfully communicated.

SECTION 8 — AUTOMATED PROCESSING, PROFILING, AND AI USAGE

8.1 Overview

As part of its modern, feature-rich ecosystem, Zyntra leverages various forms of automated data processing, including profiling and the use of artificial intelligence (AI).

Such processing is subject to:

·       The legal bases outlined in Section 6;

·       The purposes detailed in Section 7;

·       The principles of transparency, fairness, and accountability;

·       Compliance with applicable data protection laws, including GDPR, CCPA, and NDPA.

8.2 What Is Automated Processing?

“Automated processing” refers to:

·       The use of software algorithms;

·       The use of AI systems;

·       The application of machine learning models;

·       The use of rule-based engines;

·       The use of data-driven statistical models;

to process Personal Data without human intervention, either partially or fully, in order to:

·       Facilitate certain platform functionalities;

·       Personalize user experience;

·       Optimize operational efficiency;

·       Protect users and platform integrity.

8.3 What Is Profiling?

“Profiling” refers to:

·       The automated processing of Personal Data;

·       For the purpose of evaluating, analyzing, or predicting aspects concerning a natural person’s:

o   Behavior;

o   Preferences;

o   Interests;

o   Economic status;

o   Reliability;

o   Location;

o   Movements;

o   Reputation;

o   Communication patterns.

8.4 Use of AI on Zyntra (WorldX.AI)

Zyntra utilizes WorldX.AI-powered systems for multiple processing purposes across its platform.
Such AI systems are deployed within controlled environments and are subject to strict internal governance to ensure:

·       Legal compliance;

·       Ethical alignment;

·       Data minimization;

·       Fair outcomes;

·       User trust and transparency.

8.5 Purposes of Automated Processing and Profiling on Zyntra

Zyntra conducts automated processing and profiling for the following purposes:

A. Content Moderation and Safety

·       Automated detection of potentially harmful, illegal, or policy-violating content;

·       Automated flagging of hate speech, harassment, graphic violence, exploitation, or spam;

·       Contextual analysis of user-generated content to assist human moderation;

·       Fraud and abuse prevention.

B. Personalized Content Recommendations

·       Personalization of feeds and content discovery;

·       Prioritization of relevant Clubs, Hubs, Lounge Spaces, and events;

·       Tailored search results.

C. Monetization Optimization

·       Analysis of content engagement patterns;

·       Recommendation of monetization opportunities;

·       Fraud prevention in Monetization Programs.

D. Advertising Relevance (where applicable and lawful)

·       Ad targeting optimization;

·       Retargeting strategies (opt-in, cookie-based where applicable);

·       Frequency capping and delivery optimization.

E. Security and Fraud Detection

·       Device fingerprinting and risk scoring;

·       Detection of bot activity or automated misuse;

·       Anti-money laundering profiling (KYC-verified users).

F. Operational Efficiency

·       Load balancing and content caching optimization;

·       Predictive capacity planning;

·       Feature testing (e.g., A/B testing with automated analysis).

8.6 Rights Regarding Automated Decision-Making

In jurisdictions where applicable (e.g., under GDPR), users have the right not to be subject to decisions based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning them.

Zyntra does not engage in such fully automated decision-making with legal or significant personal impact, except:

·       Where necessary for the performance of a contract;

·       Where authorized by law;

·       Where based on the user’s explicit consent.

When such processing occurs, Zyntra will:

·       Provide meaningful information about the logic involved;

·       Provide information about the significance and consequences;

·       Offer the opportunity for human intervention and review.

8.7 Governance of AI and Automated Processing

Zyntra’s deployment of AI is governed by:

·       Internal AI ethics and governance policies;

·       Technical safeguards (robustness, accuracy, reliability);

·       Regular risk assessments;

·       Privacy impact assessments (where required);

·       Transparent user communication.

Zyntra continuously monitors AI-driven systems for bias, discrimination, accuracy, and fairness.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

9.1 General Statement

Zyntra does not sell Personal Data for profit.

However, to operate its global services effectively, Zyntra does disclose Personal Data to certain categories of third parties, under strict contractual and legal controls.

Such disclosures are:

·       Proportionate;

·       Purpose-driven;

·       Subject to strict confidentiality and data protection agreements;

·       Conducted only with trusted and vetted partners.

9.2 Categories of Third Parties

Zyntra may disclose Personal Data to:

A. Service Providers and Processors

·       Cloud hosting and infrastructure providers;

·       Data storage services;

·       Content delivery networks (CDNs);

·       Payment processors (e.g., Stripe, Flutterwave, PayPal, Paveway, 2Checkout, Crypto processors);

·       KYC/identity verification partners;

·       Analytics service providers;

·       Fraud prevention and security vendors;

·       Customer support tools.

B. Affiliate and Partner Programs

·       Affiliate Program tracking and payment partners;

·       API partners (only with user opt-in and authorization).

C. Business Account Administrators

·       Where a user accesses the Platform via a Business Account or enterprise contract, certain account-level Personal Data may be shared with the associated Business Account administrator(s).

D. Regulatory and Legal Authorities

·       Courts, law enforcement agencies, and regulatory bodies;

·       Other government entities, pursuant to valid legal process.

Such disclosures may be required:

·       To comply with legal obligations;

·       To respond to lawful requests;

·       To prevent or address fraud, abuse, or illegal conduct;

·       To enforce platform rights.

E. Corporate Group Entities

·       BrainX corporate affiliates and subsidiaries;

·       PreciousX (parent company);

·       Other entities under common control, for lawful corporate purposes.

F. Prospective Business Transferees

·       In the event of a merger, acquisition, reorganization, asset sale, or similar transaction, Personal Data may be disclosed to prospective and actual business transferees, subject to appropriate safeguards.

9.3 Conditions of Disclosure

In all cases:

·       Zyntra maintains strict contractual controls on third-party recipients;

·       Personal Data is disclosed only as necessary for the stated processing purpose;

·       Third parties are prohibited from using the data for their own independent purposes without proper legal basis and consent.

9.4 International Disclosures

Personal Data may be disclosed across national borders as part of:

·       Global service delivery;

·       Cross-jurisdictional Platform features (e.g., Marketplace, Lounge Spaces, Affiliate Program);

·       Corporate operations of BrainX. and PreciousX.

Such transfers are governed by:

·       Applicable data protection law;

·       Appropriate safeguards (e.g., Standard Contractual Clauses, adequacy decisions, intra-group agreements).

9.5 No Unauthorized Disclosure

Zyntra does not:

·       Sell Personal Data to data brokers;

·       Share Personal Data with advertisers in identifiable form, unless based on valid consent (where applicable);

·       Publicly expose sensitive Personal Data without lawful basis.

INTERNATIONAL DATA TRANSFERS

10.1 General Statement

Zyntra is a global platform, with users, infrastructure, and operations spanning multiple jurisdictions.

Consequently, Personal Data processed by Zyntra may be transferred, stored, or processed outside of the country in which it was originally collected, including:

·       The United Kingdom;

·       The European Economic Area (EEA);

·       Nigeria;

·       The United States;

·       Other jurisdictions in which Zyntra operates or engages service providers.

10.2 Lawful Basis for International Transfers

All international transfers of Personal Data conducted by Zyntra are:

·       Lawful;

·       Transparent;

·       Subject to appropriate safeguards;

·       Consistent with applicable data protection laws.

Depending on the jurisdiction, such legal bases may include:

·       Adequacy decisions issued by relevant data protection authorities;

·       Standard Contractual Clauses (SCCs) adopted by the European Commission or UK Information Commissioner’s Office;

·       Binding Corporate Rules (where applicable);

·       Explicit user consent (where required);

·       Other legally recognized transfer mechanisms.

10.3 Transfers Within the Corporate Group

Personal Data may be transferred within the corporate group of BrainX. and its parent company, PreciousX.

Such intra-group transfers are subject to:

·       Intra-group data transfer agreements incorporating required safeguards;

·       Uniform corporate data protection policies;

·       Group-wide data governance standards.

10.4 Transfers to Processors and Service Providers

Personal Data may be transferred to:

·       Processors and sub-processors providing cloud hosting, payment processing, identity verification, analytics, support, and other services;

·       Third-party API partners, only where explicitly authorized by the user.

Such transfers are governed by:

·       Data Processing Agreements (DPAs) incorporating SCCs (where applicable);

·       Contractual clauses ensuring that service providers uphold comparable data protection standards.

10.5 Data Localization Requirements

Where local laws require data localization (e.g., certain financial data or regulatory records):

·       Zyntra complies with such localization obligations;

·       Zyntra implements hybrid data architectures (e.g., localized storage + global backup with encryption).

10.6 User Transparency

Zyntra provides clear notice to users regarding:

·       The possibility of international transfers;

·       Applicable legal safeguards;

·       User rights in relation to such transfers.

DATA RETENTION AND DELETION

11.1 General Retention Principles

Zyntra retains Personal Data only for as long as is:

·       Necessary to fulfill the purposes for which it was collected;

·       Necessary to comply with legal, regulatory, or contractual obligations;

·       Necessary to enforce rights or defend legal claims;

·       Permitted under applicable data protection laws.

11.2 Retention Periods by Data Category

Zyntra applies granular retention periods based on the category of Personal Data:

A. Account and Profile Data

·       Retained for the duration of the user’s active account;

·       If an account is closed, data is typically retained for a defined grace period (e.g., 30–90 days) to enable account recovery, after which it is deleted or anonymized.

B. Financial and Transactional Data

·       Retained as required by applicable financial regulations (e.g., 5–7 years);

·       Includes Wallet transaction records, payouts, Marketplace sales, Zynts earnings, Affiliate Program earnings.

C. Verification and KYC Data

·       Retained for the legally mandated period (e.g., as required under AML/CTF laws);

·       May vary by jurisdiction (typically 5–10 years post-verification or post-account closure).

D. User-Generated Content

·       Retained for as long as it remains published by the user;

·       If deleted by the user, subject to grace period caching, after which it is removed or anonymized;

·       Backups and archival copies subject to secure deletion schedules.

E. Support and Communications Data

·       Retained to ensure service quality and legal compliance (typically 3–5 years).

F. Analytical Data

·       Retained in aggregated and anonymized form beyond user account closure where legally permissible.

11.3 User-Initiated Deletion

Users may request deletion of their Personal Data via:

·       Account settings;

·       Data Deletion Request under Zyntra’s Data Deletion Request Policy;

·       Support & Help Center.

Zyntra honors such requests in accordance with:

·       Legal rights of the user;

·       Legal obligations of Zyntra;

·       Applicable data retention exemptions (e.g., fraud prevention, legal defense).

11.4 Backup and Archival Retention

Zyntra maintains secure backups for disaster recovery and business continuity.

Data in backups:

·       Is protected by state-of-the-art encryption;

·       Is subject to limited retention windows;

·       Is not accessed except for security, integrity, or legal restoration purposes.

11.5 Deletion Upon Account Termination

When a user’s account is:

·       Voluntarily closed by the user; or

·       Terminated by Zyntra under Terms of Service;

Zyntra applies its standard data deletion schedule, with:

·       User data flagged for secure deletion;

·       Residual data handled in compliance with legal obligations.

SECTION 12 — DATA SECURITY AND INTEGRITY

12.1 Commitment to Security

Zyntra implements a comprehensive Data Security Program designed to:

·       Protect Personal Data against unauthorized access, disclosure, alteration, and destruction;

·       Ensure confidentiality, integrity, and availability of Personal Data;

·       Align with international security frameworks and industry standards.

12.2 Security Governance

The Data Security Program is:

·       Overseen by dedicated security leadership (e.g., Chief Information Security Officer or equivalent);

·       Supported by a cross-functional security team;

·       Regularly reviewed and updated;

·       Subject to executive oversight and compliance audits.

12.3 Technical Security Measures

Zyntra employs:

·       End-to-end encryption for data in transit (TLS/SSL);

·       Encryption at rest for stored data (AES-256 or comparable);

·       Segregated data environments (production, testing, development);

·       Role-based access controls (RBAC);

·       Multi-factor authentication (MFA) for sensitive systems;

·       Intrusion detection and prevention systems (IDPS);

·       Security event monitoring and SIEM;

·       Network segmentation;

·       Regular vulnerability scanning and penetration testing.

12.4 Organizational Security Measures

·       Employee background checks (where legally permissible);

·       Security awareness training for all personnel;

·       Restricted data access based on “need to know”;

·       Confidentiality agreements with employees and contractors;

·       Vendor security due diligence and oversight.

12.5 Data Integrity

Zyntra maintains:

·       Audit trails for data changes and access events;

·       Integrity checks for critical data;

·       Data quality and accuracy controls;

·       Automated detection of anomalies.

12.6 Incident Response and Breach Notification

Zyntra maintains a formal Incident Response Plan, including:

·       24/7 monitoring for security incidents;

·       Defined escalation protocols;

·       Timely containment and remediation;

·       Root cause analysis;

·       Notification to regulators and affected users in accordance with applicable law (e.g., GDPR 72-hour breach notification rule).

12.7 User Responsibilities

Zyntra encourages users to:

·       Choose strong, unique passwords;

·       Enable multi-factor authentication (where available);

·       Exercise caution when sharing Personal Data publicly;

·       Immediately report suspected security incidents to the Support & Help Center.

12.8 Continuous Improvement

Zyntra’s Data Security Program is:

·       Continuously updated to reflect evolving threats;

·       Informed by threat intelligence and industry best practices;

·       Regularly tested via internal audits and third-party assessments.

USER RIGHTS AND DATA SUBJECT RIGHTS

13.1 General Principles

Zyntra recognizes that users — as Data Subjects under applicable privacy laws — have important rights with respect to the processing of their Personal Data.

These rights are:

·       Fundamental to user trust;

·       Integral to Zyntra’s platform values of transparency, fairness, and accountability;

·       Fully supported and facilitated in accordance with applicable legal frameworks, including:

o   UK GDPR;

o   EU GDPR;

o   CCPA;

o   NDPA;

o   Other jurisdictional privacy laws.

13.2 Applicability of Rights

The availability and scope of Data Subject rights may vary depending on:

·       The user’s location and governing law;

·       The specific type of Personal Data involved;

·       The legal basis for processing (see Section 6);

·       Any applicable legal exemptions (e.g., regulatory retention obligations, law enforcement investigations).

Zyntra applies these rights globally, aiming to extend GDPR-level transparency and control standards across its platform wherever technically and legally feasible.

13.3 Summary of User Rights

A. Right of Access

Users have the right to obtain:

·       Confirmation as to whether their Personal Data is being processed;

·       Access to their Personal Data;

·       Information about:

o   The purposes of processing;

o   Categories of data;

o   Recipients or categories of recipients;

o   Data retention periods;

o   Sources of data (if not collected directly);

o   Automated processing and profiling (see Section 8).

B. Right to Rectification

Users have the right to request:

·       Correction of inaccurate Personal Data;

·       Completion of incomplete Personal Data.

C. Right to Erasure (“Right to be Forgotten”)

Users may request the deletion of Personal Data where:

·       The data is no longer necessary for its original purpose;

·       The user withdraws consent (where consent is the legal basis);

·       The user objects to processing and no overriding legitimate grounds exist;

·       The data was unlawfully processed;

·       The data must be deleted to comply with legal obligations.

Exemptions may apply where deletion would conflict with:

·       Legal obligations (e.g., financial regulations, fraud prevention);

·       Freedom of expression and information;

·       Public interest considerations;

·       The exercise or defense of legal claims.

D. Right to Restrict Processing

Users may request restriction of processing where:

·       Data accuracy is contested (pending verification);

·       Processing is unlawful, and the user opposes deletion;

·       The data is no longer needed, but required by the user for legal claims;

·       The user has objected to processing, pending legitimate interest assessment.

E. Right to Data Portability

Where technically feasible, users may request:

·       A copy of their Personal Data in a structured, commonly used, machine-readable format;

·       The direct transmission of such data to another controller, where legally required.

This right applies primarily where:

·       Processing is based on consent or contract;

·       Processing is carried out by automated means.

F. Right to Object

Users may object to processing:

·       Based on Zyntra’s legitimate interests;

·       For direct marketing purposes.

Zyntra will cease such processing unless it demonstrates compelling legitimate grounds or processing is required for legal claims.

G. Rights in Relation to Automated Decision-Making

Users may request:

·       Not to be subject to decisions based solely on automated processing (Section 8);

·       Human intervention in such decisions;

·       An explanation of the logic involved;

·       The ability to contest the decision.

H. Right to Withdraw Consent

Where processing is based on consent, users may withdraw consent:

·       At any time;

·       Without affecting the lawfulness of prior processing.

Withdrawal is facilitated via:

·       Platform controls (e.g., cookie preferences, marketing opt-outs);

·       Support & Help Center.

I. Right to Lodge a Complaint

Users have the right to:

·       Lodge a complaint with a Data Protection Authority in their jurisdiction;

·       Seek judicial remedies where they believe their rights have been infringed.

13.4 Non-Discrimination

Zyntra will not discriminate against users for exercising their privacy rights, including:

·       Denying access to services;

·       Charging different prices or rates;

·       Providing a different level of service or quality.

13.5 User Responsibility

Users are responsible for:

·       Providing accurate and truthful Personal Data;

·       Maintaining the security of their account credentials;

·       Exercising rights in a lawful and reasonable manner.

EXERCISING YOUR RIGHTS

14.1 How to Submit a Request

Users may exercise their rights by:

·       Using platform self-service tools (where available);

·       Contacting Zyntra’s Support & Help Center: https://support.zyntra.social;

·       Submitting a Data Rights Request via designated online forms or verified communication channels.

14.2 Verification of Identity

To protect users and prevent unauthorized access:

·       Zyntra verifies the identity of each requestor;

·       May request additional information as needed to confirm identity.

Verification requirements vary based on:

·       Sensitivity of the data involved;

·       Nature of the request;

·       Applicable legal requirements.

14.3 Response Timeframes

Zyntra endeavors to:

·       Respond to valid requests without undue delay;

·       Typically within one month under GDPR;

·       Extended by an additional two months where necessary (with notice).

Response times may vary under:

·       CCPA (typically 45 days, extendable to 90 days);

·       NDPA and other local frameworks.

14.4 Limitations and Exceptions

Certain requests may be subject to:

·       Legal exemptions (e.g., law enforcement, legal claims);

·       Technical feasibility limitations;

·       Conflict with rights and freedoms of others (e.g., intellectual property, freedom of expression).

Zyntra will:

·       Clearly explain the basis for any refusal or restriction;

·       Offer users avenues for further recourse (e.g., complaints to authorities).

14.5 Fees

Zyntra will process most rights requests free of charge.

However, Zyntra reserves the right to:

·       Charge a reasonable fee for:

o   Manifestly unfounded requests;

o   Excessive or repetitive requests;

o   Requests requiring disproportionate technical effort.

14.6 Accessibility

Zyntra is committed to:

·       Ensuring its rights request processes are accessible to all users;

·       Offering alternative submission channels where required by accessibility needs.

USE OF COOKIES AND TRACKING TECHNOLOGIES

15.1 General Statement

Zyntra uses Cookies and tracking technologies to:

·       Enable and optimize platform functionality;

·       Personalize user experiences;

·       Analyze usage patterns;

·       Support advertising and monetization (where applicable and lawful);

·       Ensure platform security and integrity.

15.2 What Are Cookies?

Cookies are:

·       Small text files stored on a user’s device by a website or service;

·       Used to store information about the user’s session, preferences, and interactions.

Cookies may be:

·       Session cookies (deleted when browser is closed);

·       Persistent cookies (remain on device until expiration or manual deletion).

15.3 Categories of Cookies Used

A. Strictly Necessary Cookies

Essential for:

·       Basic platform functionality;

·       User authentication;

·       Security protections;

·       Compliance with legal obligations (e.g., age verification).

B. Performance and Analytics Cookies

Used to:

·       Measure platform performance;

·       Understand user behavior;

·       Improve user experience;

·       Support research and innovation.

C. Functional Cookies

Used to:

·       Remember user preferences (e.g., language settings);

·       Enable enhanced features.

D. Advertising and Marketing Cookies

Used to:

·       Personalize advertising (where lawful and with consent);

·       Limit ad frequency;

·       Measure campaign effectiveness;

·       Support retargeting strategies.

Zyntra deploys advertising cookies only:

·       In compliance with applicable law (e.g., GDPR consent requirements);

·       With explicit user consent where required.

15.4 Third-Party Cookies

Some cookies may be set by:

·       Third-party service providers (e.g., analytics vendors, advertising networks);

·       API partners (where the user integrates third-party features).

Zyntra:

·       Conducts due diligence on third-party partners;

·       Requires contractual data protection commitments.

15.5 Managing Cookie Preferences

Users can manage cookie preferences via:

·       Zyntra’s Cookie Consent Manager;

·       Browser settings (blocking or deleting cookies);

·       “Do Not Track” signals (where legally recognized).

Blocking cookies may impact:

·       Platform functionality;

·       Personalization;

·       User experience.

15.6 Legal Basis for Cookie Use

Depending on the jurisdiction:

·       Strictly necessary cookies are used based on legitimate interests;

·       Analytics and marketing cookies are used based on consent (opt-in model under GDPR).

15.7 Transparency

Zyntra provides:

·       A comprehensive Cookie Policy at https://zyntra.social/cookie-policy;

·       Clear disclosures about:

o   The types of cookies used;

o   Their purposes;

o   How users can manage preferences.

THIRD-PARTY SERVICES AND INTEGRATIONS

16.1 Overview

Zyntra offers a highly integrated, modular platform that supports:

·       APIs;

·       Third-party services;

·       External integrations;

·       Cross-platform functionality.

Such integrations are provided:

·       To enhance user experience;

·       To enable platform extensibility;

·       To foster innovation and developer partnerships;

·       To support ecosystem interoperability.

16.2 Nature of Third-Party Services

Third-party services on Zyntra include, but are not limited to:

A. Social Login Providers

Zyntra supports account creation and login via:

·       Google;

·       Facebook;

·       X (formerly Twitter);

·       LinkedIn.

When users authenticate via social login:

·       Zyntra receives certain Personal Data from the selected provider;

·       The scope of data is disclosed at login (e.g., name, email, profile picture, etc.);

·       The provider’s own privacy policy applies to their processing of data.

B. API Partners and Developer Integrations

Zyntra provides APIs that enable:

·       External apps to access selected Platform services (with user authorization);

·       Business Accounts to build integrations;

·       Marketplace sellers to automate workflows;

·       Affiliate Program partners to track referrals.

Zyntra:

·       Requires API partners to obtain explicit user authorization for any data access;

·       Enforces rate limiting and scope restrictions;

·       Audits API usage for compliance and security.

C. Payment Processors

Zyntra integrates with trusted third-party payment providers to process:

·       Membership fees;

·       Marketplace transactions;

·       Wallet deposits and payouts.

Current processors include:

·       Stripe;

·       Flutterwave;

·       PayPal;

·       Paveway;

·       2Checkout;

·       Crypto partners (as applicable).

These providers operate as separate data controllers for certain aspects of payment processing.
Users are encouraged to review their privacy policies.

D. Identity Verification (KYC) Providers

For compliance and security purposes, Zyntra integrates with:

·       Third-party KYC vendors;

·       AML/CTF screening providers.

Such partners:

·       Collect identity documents and verification data;

·       Perform automated checks;

·       Return verification status to Zyntra.

Zyntra ensures that:

·       Data minimization principles are observed;

·       Partners comply with stringent privacy and security standards.

E. Analytics Providers

Zyntra leverages trusted analytics providers to:

·       Monitor platform performance;

·       Understand user engagement;

·       Support feature optimization.

Data shared with such providers is:

·       Pseudonymized or aggregated where feasible;

·       Subject to contractual data protection obligations.

F. Advertising Partners (where applicable)

Where advertising is offered on Zyntra:

·       Advertising partners may receive limited Personal Data;

·       Only with user consent where required (e.g., GDPR jurisdictions);

·       Under strict contractual safeguards.

G. Third-Party Content Embeds

Zyntra may allow:

·       Embedded content from third-party platforms (e.g., videos, widgets);

·       Social sharing tools.

Such embeds:

·       May place cookies or tracking pixels;

·       Are governed by the third party’s privacy practices.

16.3 User Responsibility for Third-Party Integrations

Users should exercise care when:

·       Authorizing third-party apps via API integrations;

·       Linking social accounts;

·       Engaging with third-party content on Zyntra.

Zyntra is not responsible for:

·       The privacy practices of third-party services beyond its control.

16.4 Due Diligence and Oversight

Zyntra conducts:

·       Vendor due diligence;

·       Security assessments;

·       Privacy impact evaluations;

prior to integrating any significant third-party service.

CHILDREN’S PRIVACY AND MINIMUM AGE

17.1 Overview

Zyntra is a platform designed for general audiences and professional users.
It is not directed to children under the age of 16.

17.2 Minimum Age for Use

To create a Zyntra account, a user must:

·       Be at least 16 years of age;

·       Or such higher minimum age as may be mandated in their jurisdiction.

17.3 Verification of Age

Zyntra implements:

·       Age gates during registration;

·       Identity verification (KYC) where required for Monetization Programs.

If Zyntra becomes aware that a user:

·       Is under the minimum age;

·       Has misrepresented their age;

Zyntra will:

·       Promptly terminate the account;

·       Take appropriate steps to delete associated Personal Data.

17.4 Parental Consent

Zyntra:

·       Does not knowingly collect Personal Data from children without verifiable parental consent;

·       Does not offer child-directed services.

17.5 Regulatory Compliance

Zyntra’s policies regarding children’s privacy are designed to comply with:

·       GDPR (Articles 8, Recitals 38–39);

·       UK GDPR;

·       CCPA/CPRA (Children under 13);

·       NDPA;

·       Other applicable children’s privacy laws.

17.6 User Responsibility

Users must:

·       Provide accurate information about their age;

·       Comply with minimum age requirements.

Parents or guardians who become aware that a child has used Zyntra in violation of this Policy should:

·       Contact Zyntra via the Support & Help Center to request account closure.

COMMUNITY AND PUBLIC CONTENT CONSIDERATIONS

18.1 Nature of the Platform

Zyntra is fundamentally a community-driven platform, offering:

·       Public-facing content spaces;

·       User-generated content;

·       Interactive community features.

Examples include:

·       Public Hubs;

·       Public Clubs;

·       Marketplace listings;

·       Deals;

·       Pulse event pages;

·       Public Lounge Spaces;

·       User profiles (where configured as public).

18.2 Public Content Visibility

Content posted in public areas:

·       May be visible to non-logged-in visitors;

·       May be indexed by search engines;

·       May be reshared within or beyond the Zyntra ecosystem.

Users are responsible for:

·       Choosing appropriate privacy settings;

·       Being mindful of what they share publicly.

18.3 User Control Over Content Visibility

Zyntra provides users with tools to:

·       Choose visibility settings (public, members-only, private);

·       Edit or delete their own content (subject to platform policies);

·       Control profile visibility.

18.4 Content Moderation and Enforcement

Zyntra maintains:

·       Community Guidelines governing public content;

·       Content moderation systems (see Section 8);

·       Appeals processes for moderation decisions.

Users are encouraged to:

·       Report violations;

·       Participate in building a safe and respectful community.

18.5 Data Subject Rights and Public Content

Even where content is publicly posted:

·       Data Subject rights (Section 13) still apply;

·       Zyntra facilitates removal or de-indexing of Personal Data where legally required (e.g., GDPR Article 17).

18.6 Residual Data and Shared Content

When users delete content:

·       It may persist in backups for a limited time (see Section 11);

·       It may remain visible to users who previously interacted with it (e.g., shared posts).

Zyntra encourages users to:

·       Use caution when posting sensitive information publicly.

SECTION 19 — FINANCIAL TRANSACTIONS AND WALLET DATA

19.1 Overview

Zyntra provides an integrated financial ecosystem designed to support:

·       Monetization of content and community engagement;

·       Marketplace commerce;

·       Affiliate earnings;

·       Fundraising and tipping;

·       Subscription-based services;

·       Withdrawal and payout capabilities.

Central to this ecosystem are Zyntra’s Wallet systems, which enable:

·       Secure storage of earned and deposited funds;

·       Seamless transactions across multiple platform features;

·       Transparent reporting to users;

·       Regulatory compliance with financial and data protection laws.

19.2 Wallet Systems

Zyntra operates two distinct, interoperable Wallet systems:

A. Social Network Wallet (Main Zyntra Wallet)

Used for:

·       Earnings from content monetization;

·       Marketplace sales;

·       FundIt campaigns;

·       Affiliate Program earnings;

·       Payments for Pro Membership tiers;

·       Tipping other users.

B. Lounge Wallet (Spaces Wallet)

Used for:

·       Lounge Spaces-specific monetization;

·       Tips within Lounge chats;

·       Subscription-based Lounge Spaces;

·       Purchase of Lounge digital goods (e.g., stickers, badges).

19.3 Wallet Data Collected

Zyntra processes the following Wallet-related data:

·       Wallet balances (Social Network Wallet and Lounge Wallet);

·       Transaction history (including timestamps, amounts, and counterparties);

·       Deposits and withdrawals;

·       Payment method information (via third-party processors);

·       Payout destination data (e.g., bank account, crypto wallet, Paveway wallet);

·       Associated tax and compliance records;

·       Affiliate earnings and commission records;

·       Transaction fee records;

·       Refunds and chargebacks (where applicable).

19.4 Legal Basis for Processing Wallet Data

Wallet data is processed primarily based on:

·       Performance of contract (Terms of Service);

·       Compliance with legal obligations (e.g., tax, AML/CTF laws);

·       Legitimate interests (platform security, fraud prevention);

·       User consent (where applicable, e.g., saving preferred payment methods).

19.5 Payment Processing

Zyntra integrates with third-party payment processors, including:

·       Stripe;

·       Flutterwave;

·       PayPal;

·       Paveway;

·       2Checkout;

·       Crypto partners.

These processors:

·       Operate as separate data controllers for certain aspects of processing;

·       Are responsible for securing payment information;

·       Share transaction confirmations and reconciliation data with Zyntra.

Users are encouraged to review the privacy policies of these processors.

19.6 Payouts and Withdrawals

Zyntra facilitates payouts to users through supported channels:

·       Bank transfers (via integrated processors);

·       Paveway wallet;

·       Crypto wallet (where supported).

Payout data is:

·       Subject to KYC/AML checks;

·       Retained per regulatory requirements.

19.7 Transactional Transparency

Users may view:

·       Wallet balances;

·       Detailed transaction history;

·       Payout history;

·       Applicable fees.

19.8 Fraud Prevention and Security

Wallet data is subject to:

·       Fraud detection algorithms;

·       Automated and manual reviews;

·       Behavioral analysis to detect abuse.

19.9 Tax Compliance

Zyntra may be legally required to:

·       Report certain earnings to tax authorities;

·       Collect tax identification data;

·       Issue tax forms (e.g., where required in user jurisdiction).

19.10 Data Retention for Wallet Data

Wallet data is retained:

·       For the duration of the user’s account;

·       For legally mandated periods (typically 5–7 years for financial records);

·       Longer where required for audit, legal defense, or compliance.

VERIFICATION AND KYC DATA

20.1 Purpose of Verification

Zyntra implements Verification and KYC (Know Your Customer) processes to:

·       Support platform trust and safety;

·       Enable Monetization Program participation;

·       Facilitate payouts;

·       Comply with AML/CTF regulations;

·       Mitigate fraud and identity misuse.

20.2 Scope of Verification

Verification may be required for:

·       Pro Membership users accessing Monetization Programs;

·       Marketplace sellers;

·       FundIt campaign owners;

·       High-volume Affiliate Program participants;

·       High-value transaction thresholds.

20.3 Verification Data Collected

Verification processes may collect:

·       Government-issued ID (passport, national ID, driver’s license);

·       Proof of address (utility bill, bank statement);

·       Selfie or biometric verification (for identity confirmation);

·       Verification metadata (timestamps, source, device info);

·       Sanctions screening results;

·       AML/CTF risk scoring;

·       Verification status.

20.4 Legal Basis for Processing Verification Data

Processing is based on:

·       Legal obligations (AML/CTF, KYC laws);

·       Performance of contract (where Verification is a condition of service access);

·       Legitimate interests (fraud prevention, platform integrity).

20.5 Third-Party Verification Providers

Zyntra partners with trusted KYC vendors.
Such vendors are:

·       Contractually bound to data protection obligations;

·       Subject to security and privacy assessments.

20.6 User Rights and Verification Data

Users have rights to:

·       Access their verification data;

·       Correct inaccuracies;

·       Request deletion (subject to legal retention obligations).

20.7 Retention of Verification Data

Verification data is retained:

·       For statutory periods under applicable laws (typically 5–10 years post-verification);

·       Longer if required to:

o   Comply with legal obligations;

o   Defend legal claims;

o   Support law enforcement requests.

MONETIZATION PROGRAMS AND EARNINGS DATA

21.1 Overview

Zyntra enables eligible users to earn real money through:

·       Content monetization;

·       Marketplace sales;

·       FundIt campaigns;

·       Affiliate Program;

·       Tips and community support;

·       Lounge Spaces monetization.

21.2 Earnings Data Collected

To administer these programs, Zyntra processes:

·       Earnings records (amounts, sources, dates);

·       Zynts conversion records;

·       Payout requests and processing;

·       Tax identification information;

·       Affiliate tracking data;

·       Revenue share calculations;

·       Performance analytics (for fraud prevention and optimization).

21.3 Legal Basis for Processing Earnings Data

Processing is based on:

·       Performance of contract (Terms of Service);

·       Compliance with legal obligations (tax laws, financial regulations);

·       Legitimate interests (platform sustainability, fraud prevention).

21.4 Disclosure of Earnings Data

Earnings data may be:

·       Shared with payment processors;

·       Reported to tax authorities (where legally required);

·       Provided to users via earnings dashboards.

21.5 Tax Compliance

Zyntra may be required to:

·       Collect tax documentation;

·       Report earnings to tax authorities;

·       Withhold taxes where mandated.

21.6 Fraud Prevention in Monetization Programs

Zyntra employs:

·       Automated fraud detection;

·       Manual review of suspicious patterns;

·       Behavioral analytics.

21.7 Transparency for Users

Zyntra provides:

·       Earnings dashboards;

·       Transaction-level reporting;

·       Tax documents (where applicable).

21.8 Retention of Earnings Data

Earnings data is retained:

·       For statutory financial recordkeeping periods;

·       Longer where necessary for legal compliance or defense of claims.

AFFILIATE PROGRAM DATA

22.1 Overview

Zyntra operates an Affiliate Program that enables eligible users to:

·       Refer new users to the platform;

·       Earn commissions on:

o   New user registrations;

o   Pro Membership subscriptions;

o   Other qualifying transactions.

Participation in the Affiliate Program is:

·       Subject to the Terms of Service and specific Affiliate Program terms;

·       Designed to reward genuine community growth and organic promotion.

22.2 Data Collected for the Affiliate Program

To operate the Affiliate Program, Zyntra collects and processes:

·       Affiliate registration data (including user ID, application details);

·       Referral codes and tracking links;

·       Click-through data on referral links;

·       Conversion events (e.g., account creation, subscription);

·       Earnings data (commissions accrued, paid, and pending);

·       Affiliate communications (e.g., program updates, compliance notices);

·       Compliance and anti-fraud data.

22.3 Legal Basis for Processing

Processing of Affiliate Program data is based on:

·       Performance of contract (Affiliate Program agreement);

·       Legitimate interests (platform growth, fraud prevention, program integrity);

·       Compliance with legal obligations (e.g., tax reporting).

22.4 Data Sharing and Disclosure

Affiliate data may be shared with:

·       Payment processors (for commission payouts);

·       Tax authorities (as required by law);

·       Platform security teams (for anti-fraud monitoring).

22.5 Fraud Prevention and Program Integrity

Zyntra implements:

·       Click fraud detection;

·       Conversion verification;

·       Affiliate pattern analysis;

·       Manual review of suspicious activity.

22.6 User Rights in Relation to Affiliate Data

Affiliate Program participants may:

·       Access their Affiliate data;

·       Request correction of inaccuracies;

·       Request deletion (subject to legal retention obligations).

22.7 Data Retention

Affiliate Program data is retained:

·       For the duration of participation in the program;

·       For statutory periods thereafter (typically 5–7 years for financial and tax records).

MARKETPLACE AND DEALS DATA

23.1 Overview

Zyntra provides:

·       A fully integrated Marketplace for:

o   Selling physical goods;

o   Selling digital goods;

o   Offering services.

·       A separate Deals feature for:

o   Promoting time-limited offers;

o   Driving immediate user engagement.

These features are subject to:

·       Zyntra’s Terms of Service;

·       Marketplace guidelines;

·       Community Guidelines.

23.2 Data Collected in the Marketplace

For Marketplace sellers, Zyntra collects:

·       Seller profile information;

·       Business verification data (where applicable);

·       Product/service listings;

·       Inventory data;

·       Order records;

·       Transaction history;

·       Shipping and delivery data;

·       Buyer feedback;

·       Dispute resolution records.

For Marketplace buyers, Zyntra collects:

·       Purchase records;

·       Shipping addresses (where required);

·       Communication with sellers;

·       Payment method data (via third-party processors);

·       Feedback and ratings.

23.3 Data Collected in Deals

For Deals posters, Zyntra collects:

·       Deal listing data;

·       Engagement metrics (clicks, views, redemptions);

·       Attribution data (e.g., conversions via external links).

23.4 Legal Basis for Processing

Processing of Marketplace and Deals data is based on:

·       Performance of contract (Terms of Service, purchase contracts);

·       Compliance with legal obligations (e.g., consumer protection laws, tax reporting);

·       Legitimate interests (platform operations, fraud prevention).

23.5 Data Sharing and Disclosure

Marketplace and Deals data may be shared with:

·       Payment processors;

·       Shipping and logistics partners (where applicable);

·       Buyers and sellers (limited to transaction-relevant data);

·       Tax authorities (where required);

·       Regulators (pursuant to legal process).

23.6 Fraud Prevention

Zyntra employs:

·       Order fraud detection;

·       Account pattern analysis;

·       Behavioral analytics;

·       Dispute and chargeback monitoring.

23.7 Transparency for Users

Buyers and sellers may access:

·       Order history;

·       Transaction details;

·       Dispute records.

23.8 Data Retention

Marketplace and Deals data is retained:

·       For contractual and legal obligations;

·       For consumer protection recordkeeping;

·       For audit and compliance purposes (typically 5–7 years).

FUNDIT AND PULSE EVENTS DATA

24.1 Overview

Zyntra offers:

·       FundIt, a community-driven crowdfunding feature;

·       Pulse, an event promotion and management feature.

These features allow users to:

·       Organize and promote campaigns or events;

·       Contribute to campaigns;

·       Purchase tickets or register for events.

24.2 Data Collected in FundIt

For campaign owners, Zyntra collects:

·       Campaign profile data;

·       Campaign content (title, description, media);

·       Fundraising goals;

·       Contribution history;

·       Payout and compliance data;

·       KYC verification (where required).

For contributors, Zyntra collects:

·       Contribution amount;

·       Payment method (via third-party processors);

·       Optional contributor message;

·       Attribution data (source of referral);

·       Refund records (if applicable).

24.3 Data Collected in Pulse

For event organizers, Zyntra collects:

·       Event listing data (title, description, media, schedule);

·       Ticket inventory (if applicable);

·       Registration and attendance data;

·       Transaction history (for paid events);

·       Attendee communications.

For event attendees, Zyntra collects:

·       Registration details;

·       Ticket purchases;

·       Payment data (via third-party processors);

·       Event check-in records.

24.4 Legal Basis for Processing

Processing of FundIt and Pulse data is based on:

·       Performance of contract (Terms of Service, event or campaign terms);

·       Compliance with legal obligations (e.g., financial regulations, AML/CTF);

·       Legitimate interests (platform operations, fraud prevention).

24.5 Data Sharing and Disclosure

FundIt and Pulse data may be shared with:

·       Payment processors;

·       Event organizers (for attendee lists);

·       Campaign owners (for contributor reports);

·       Regulators (where legally required).

24.6 Fraud Prevention

Zyntra employs:

·       Contribution pattern analysis;

·       Campaign vetting;

·       Event integrity checks;

·       AML/CTF screening.

24.7 Transparency for Users

Campaign owners and event organizers receive:

·       Contribution reports;

·       Registration and attendance data.

Contributors and attendees receive:

·       Transaction confirmations;

·       Receipts;

·       Refund notices (if applicable).

24.8 Data Retention

FundIt and Pulse data is retained:

·       For financial recordkeeping;

·       For compliance with legal obligations;

·       For audit purposes (typically 5–7 years).

LOUNGE SPACES DATA

25.1 Overview

Zyntra’s Lounge Spaces feature provides a real-time conversational environment for:

·       Community engagement;

·       Thematic discussions;

·       Team collaboration;

·       Audio and video interaction;

·       Digital community building.

Lounge Spaces supports:

·       Text chat;

·       Audio chat;

·       Video chat;

·       File sharing;

·       Roles and permissions;

·       Monetization options (subscription-based Spaces, tips).

Given the dynamic and interactive nature of Lounge Spaces, Zyntra collects and processes a distinct set of Personal Data related to Lounge participation.

25.2 Data Collected in Lounge Spaces

For all participants, Zyntra may collect:

·       User profile data (e.g., display name, avatar);

·       Participation history (Spaces joined, roles held);

·       Messages sent in text chats;

·       Audio participation metadata (timestamps, speaker role);

·       Video participation metadata (timestamps, device info);

·       Uploaded files (subject to moderation and storage policies);

·       Interaction data (reactions, replies, mentions);

·       Monetization transactions (subscriptions, tips);

·       Lounge Wallet data (see Section 19).

25.3 Recording and Archiving

By default:

·       Text chats are stored and remain visible in Spaces (subject to moderation or deletion);

·       Audio and video streams are not recorded by Zyntra unless:

o   Explicitly configured by Space owners (with participant notice);

o   Required for moderation investigations.

Users are notified when:

·       Recording is active;

·       Consent is required (depending on jurisdiction).

25.4 Roles and Permissions

Lounge Spaces allow for:

·       Granular role assignment (owner, moderator, member, guest);

·       Different levels of:

o   Visibility;

o   Posting rights;

o   Administrative actions.

Role changes and assignments are logged for:

·       Transparency;

·       Abuse prevention;

·       Moderation oversight.

25.5 Moderation and Enforcement

Lounge Spaces are subject to:

·       Zyntra’s Community Guidelines;

·       Content moderation systems (see Section 8);

·       Reporting and appeals mechanisms.

Moderator actions (e.g., bans, mutes, content removal) are:

·       Logged;

·       Auditable;

·       Subject to oversight by Zyntra Trust & Safety teams.

25.6 Monetization Data

Where Spaces are subscription-based or tip-enabled, Zyntra processes:

·       Subscriber lists (visible to Space owners);

·       Transaction records (for Lounge Wallet);

·       Earnings reports (to Space owners);

·       Payout data (see Section 19).

25.7 Data Sharing

Lounge data may be shared:

·       Internally within Zyntra for:

o   Security;

o   Trust & Safety;

o   Feature improvement.

·       With:

o   Payment processors (for Lounge transactions);

o   Law enforcement, where legally required.

25.8 Data Retention

Lounge Spaces data is retained:

·       For active Spaces;

·       In accordance with moderation and legal requirements;

·       In line with Section 11 (Data Retention).

DATA SHARING IN CLUBS AND HUBS

26.1 Overview

Zyntra’s Clubs and Hubs are:

·       Central to community building on the platform;

·       Designed for:

o   Interest-based groups (Clubs);

o   Public or branded communities (Hubs).

These spaces facilitate:

·       User interaction;

·       Content sharing;

·       Community governance;

·       Optional monetization.

26.2 Data Collected in Clubs and Hubs

For members and visitors, Zyntra may collect:

·       Membership status (joined, invited, pending);

·       Content posted (text, images, videos);

·       Reactions and engagement data;

·       Participation in polls or events;

·       Interaction history (comments, replies, mentions);

·       Role assignments (admin, moderator, member).

For Club or Hub owners:

·       Profile and verification data;

·       Monetization settings;

·       Subscriber lists (for paid Clubs);

·       Earnings records.

26.3 Visibility and Sharing of Member Data

In public Clubs and Hubs:

·       Member participation is visible to other members and visitors.

In private or invitation-only Clubs and Hubs:

·       Visibility is restricted to approved members.

26.4 Content Moderation

Clubs and Hubs are governed by:

·       Zyntra’s Community Guidelines;

·       Club/Hub-specific rules (where allowed);

·       Moderation actions are auditable.

26.5 Monetization Data

For monetized Clubs and Hubs:

·       Zyntra processes:

o   Subscriber payments;

o   Earnings reports;

o   Payout data.

·       Data is shared with:

o   Club/Hub owners (limited to what is necessary for operation);

o   Payment processors.

26.6 Data Sharing and Disclosure

Club and Hub data may be shared:

·       Internally within Zyntra for:

o   Analytics;

o   Feature improvement;

o   Security.

·       Externally only as required by:

o   Legal obligations;

o   User consent.

26.7 Data Retention

Club and Hub data is retained:

·       As long as the Club/Hub is active;

·       In line with Data Retention policies (Section 11);

·       Subject to legal and regulatory obligations.

USER-GENERATED CONTENT AND INTELLECTUAL PROPERTY

27.1 Overview

Zyntra empowers users to create and share:

·       Original content;

·       Multimedia contributions;

·       Community knowledge;

·       Creative works.

Respect for user intellectual property rights and platform integrity is central to Zyntra’s values.

27.2 Scope of User-Generated Content (UGC)

UGC includes:

·       Text posts;

·       Comments and replies;

·       Images;

·       Videos (Zyntra TV, Zeels);

·       Audio;

·       Files shared in Lounge Spaces;

·       Content in Clubs, Hubs, Marketplace, Deals, Pulse, and FundIt.

27.3 Ownership of UGC

Users retain ownership of:

·       Copyright;

·       Intellectual property rights;

in their original UGC, subject to:

·       The license granted to Zyntra (per Terms of Service);

·       Compliance with Community Guidelines.

27.4 License to Zyntra

By posting UGC, users grant Zyntra:

·       A worldwide, non-exclusive, royalty-free, transferable, and sublicensable license to:

o   Use;

o   Reproduce;

o   Modify (for technical purposes);

o   Distribute;

o   Display;

o   Perform;

such UGC:

·       In connection with providing, promoting, and improving the Zyntra Platform.

27.5 Public Visibility of UGC

Public UGC:

·       May be visible to non-logged-in visitors;

·       May be indexed by search engines;

·       May be reshared by other users.

27.6 Content Moderation

UGC is subject to:

·       Community Guidelines;

·       Automated and manual moderation (Section 8);

·       Takedown and appeals procedures.

27.7 User Responsibility

Users are responsible for:

·       Ensuring they have the right to post any content shared;

·       Avoiding infringement of:

o   Copyright;

o   Trademarks;

o   Privacy rights;

o   Publicity rights.

27.8 Takedown Requests and DMCA Compliance

Zyntra honors:

·       Copyright takedown requests;

·       DMCA-compliant notices (for US users);

·       Equivalent processes under other applicable laws.

Zyntra provides:

·       Counter-notice mechanisms where applicable.

27.9 Retention and Removal of UGC

Upon content deletion by the user:

·       UGC is:

o   Flagged for removal;

o   Subject to backup retention (per Section 11);

o   May remain in caches for a limited time.

Zyntra may retain UGC where required by:

·       Law enforcement requests;

·       Legal obligations;

·       Litigation holds.

27.10 Use of UGC in Platform Promotion

Zyntra may feature public UGC in:

·       Platform promotions;

·       Community highlights;

·       Internal showcases;

subject to:

·       The license granted by the user;

·       Platform and community norms.

SECTION 28 — BUSINESS ACCOUNT DATA

28.1 Overview

Zyntra provides functionality for Business Accounts to:

·       Represent companies, organizations, brands, and public figures;

·       Operate Hubs and Marketplace storefronts;

·       Participate in advertising;

·       Use APIs and third-party integrations;

·       Engage with Pro features.

Business Accounts are distinct from personal user accounts in:

·       Their purpose;

·       Their visibility;

·       Their legal obligations.

28.2 Business Account Registration

When registering a Business Account, Zyntra collects:

·       Business name;

·       Business category;

·       Country of incorporation;

·       Business registration number (where applicable);

·       Primary contact name;

·       Primary contact email;

·       Phone number;

·       Business address;

·       Proof of registration (where required);

·       Tax identification number (TIN), where applicable.

28.3 Additional Business Verification

For certain Business Accounts (e.g., advertisers, Marketplace sellers), Zyntra may also collect:

·       Bank account details for payouts;

·       Business licenses;

·       Proof of domain ownership (for branded Hubs);

·       Trademark verification (for intellectual property claims).

28.4 Business Account Content and Public Visibility

Business Account content (e.g., in Hubs, Marketplace listings) may be:

·       Publicly visible;

·       Indexed by search engines;

·       Used in Zyntra platform promotions.

28.5 Legal Basis for Processing Business Account Data

Processing is based on:

·       Performance of contract (Terms of Service, Business Account agreement);

·       Compliance with legal obligations (e.g., tax, AML/CTF laws);

·       Legitimate interests (platform integrity, community trust).

28.6 Data Sharing and Disclosure

Business Account data may be shared with:

·       Payment processors;

·       Tax authorities;

·       Regulatory agencies;

·       Other users (to the extent necessary for Marketplace transactions, public visibility, or Hub interactions).

28.7 Responsibilities of Business Account Holders

Business Account holders are responsible for:

·       Ensuring accuracy and currency of provided information;

·       Complying with applicable laws and regulations;

·       Respecting third-party intellectual property.

28.8 Data Retention

Business Account data is retained:

·       For the duration of account operation;

·       Thereafter, for legally mandated periods (typically 5–7 years for financial and regulatory compliance).

BEHAVIORAL ANALYTICS AND PERSONALIZATION

29.1 Overview

Zyntra employs behavioral analytics to:

·       Understand user engagement;

·       Optimize platform performance;

·       Deliver personalized experiences.

Such processing is:

·       Designed to enhance user satisfaction;

·       Conducted in a privacy-respecting and transparent manner.

29.2 Data Collected for Behavioral Analytics

Zyntra may collect:

·       Page views and navigation paths;

·       Clickstream data;

·       Time spent on different content types;

·       Interaction data (likes, comments, shares, reactions);

·       Search queries;

·       Session length and frequency;

·       Engagement with features (Lounge, Clubs, Hubs, Marketplace, Deals, etc.);

·       Device and browser metadata.

29.3 Legal Basis for Behavioral Analytics

Processing is based on:

·       Legitimate interests (platform improvement, user experience optimization);

·       Consent (where required, e.g., for cookies in GDPR jurisdictions).

29.4 Use of Behavioral Analytics

Analytics data is used to:

·       Improve platform navigation;

·       Optimize feature discoverability;

·       Personalize feed ranking and recommendations;

·       Inform product development;

·       Detect and prevent abuse.

29.5 Personalization Practices

Personalization may include:

·       Content recommendations (e.g., Clubs to join, Lounge Spaces to explore);

·       Marketplace recommendations;

·       Suggested users to follow;

·       Event and FundIt campaign suggestions;

·       Advertising relevance (where permitted).

29.6 Transparency and User Control

Zyntra provides:

·       A Cookie Policy explaining tracking practices;

·       Settings to opt out of certain personalization features (where required);

·       Transparency about the use of AI-driven recommendations (Section 8).

29.7 Data Sharing

Behavioral analytics data may be shared:

·       Internally within Zyntra;

·       With analytics service providers under strict data protection terms.

29.8 Data Retention

Analytics data is retained:

·       In pseudonymized or aggregated form;

·       For as long as necessary to support platform optimization;

·       Subject to legal and technical considerations.

MARKETING COMMUNICATIONS AND OPT-OUT OPTIONS

30.1 Overview

Zyntra may send marketing communications to users about:

·       Platform features;

·       Membership offers;

·       Community events;

·       Partner opportunities.

Such communications are:

·       Consent-based where legally required;

·       Respectful of user preferences.

30.2 Data Used for Marketing Communications

Zyntra may use:

·       User profile data (name, email, preferences);

·       Behavioral analytics (e.g., engagement patterns);

·       Membership status;

·       Geographic location (where relevant).

30.3 Legal Basis for Marketing Communications

Processing is based on:

·       Consent (opt-in, where required — e.g., GDPR jurisdictions);

·       Legitimate interests (for existing users in permitted jurisdictions — e.g., promoting similar services).

30.4 User Choices and Opt-Out

Users can manage marketing preferences via:

·       Account settings;

·       Email unsubscribe links;

·       Support & Help Center.

30.5 Affiliate and Partner Marketing

Zyntra may offer:

·       Affiliate-driven promotions;

·       Partner offers (where permitted).

Users may opt out of:

·       Partner marketing;

·       Third-party communications.

30.6 Data Sharing for Marketing

Zyntra does not:

·       Sell Personal Data to advertisers;

·       Share identifiable user data for third-party marketing without user consent.

Where marketing partners are used:

·       Contractual safeguards are implemented;

·       Data sharing is minimized.

30.7 Marketing Analytics

Zyntra may analyze:

·       Campaign performance;

·       Engagement rates;

·       Conversion tracking.

30.8 Retention of Marketing Preferences

Marketing preferences are retained:

·       To respect user choices;

·       To comply with legal obligations (e.g., suppression list maintenance).

DATA BREACH NOTIFICATION AND RESPONSE

31.1 Overview

Zyntra is committed to ensuring the security, integrity, and confidentiality of the Personal Data it processes.
Despite best efforts and industry-leading security measures (Section 12), no system can be guaranteed to be completely immune to security incidents or breaches.

This Section sets forth:

·       Zyntra’s policies;

·       Processes;

·       Obligations;

·       And user rights;

in the event of a Personal Data breach.

31.2 Definition of a Personal Data Breach

For purposes of this Policy, a “Personal Data Breach” means:

·       A breach of security leading to:

o   The accidental or unlawful:

§  Destruction;

§  Loss;

§  Alteration;

§  Unauthorized disclosure of;

§  Or access to;

·       Personal Data transmitted, stored, or otherwise processed by Zyntra.

This includes (but is not limited to):

·       Hacking incidents;

·       Malware infections;

·       Data exfiltration;

·       Physical data loss;

·       Unintended exposure of Personal Data.

31.3 Internal Breach Response Program

Zyntra maintains a comprehensive Data Breach Response Program, including:

·       Incident detection and real-time monitoring;

·       Incident reporting workflows;

·       Incident classification (severity, scope, data impacted);

·       Containment and mitigation procedures;

·       Root cause analysis;

·       Remediation actions;

·       Documentation and audit trails.

31.4 Notification Obligations

Where a Personal Data Breach occurs that:

·       Is likely to result in a risk to the rights and freedoms of natural persons;

Zyntra will:

·       Notify competent supervisory authorities (e.g., ICO for UK GDPR, NDPC for Nigeria, others) within applicable statutory deadlines (typically 72 hours of breach awareness);

·       Notify affected users without undue delay, where required by law.

31.5 User Notification

User notification will:

·       Be provided directly (e.g., via email, platform message);

·       Describe in clear and plain language:

o   The nature of the breach;

o   The likely consequences;

o   The measures taken (or proposed) by Zyntra;

o   The recommended actions users should take;

o   Contact details for further information.

31.6 No Notification Requirement

In certain cases, user notification is not required, such as:

·       Where technical and organizational protections (e.g., encryption) render data unintelligible to unauthorized parties;

·       Where subsequent measures eliminate any risk of harm to data subjects;

·       Where notification would involve disproportionate effort — in which case, Zyntra will use public communication instead.

31.7 Ongoing Communication

In the event of a major breach, Zyntra commits to:

·       Providing updates as remediation progresses;

·       Ensuring transparent communication with users and authorities.

31.8 Liability Limitations

While Zyntra maintains industry-best security:

·       It is not liable for breaches caused by:

o   Third-party processors acting as independent data controllers (except to the extent required by applicable law);

o   Acts of God, armed conflict, force majeure events;

o   User negligence (e.g., compromised credentials due to phishing).

CHANGES TO THIS PRIVACY POLICY

32.1 Overview

This Privacy Policy is a living document.
As Zyntra evolves:

·       New features may be introduced;

·       Regulatory environments may change;

·       Industry standards may shift.

Accordingly, Zyntra may need to:

·       Update or amend this Privacy Policy from time to time.

32.2 Types of Changes

Updates may include:

·       Clarifications of existing content;

·       New disclosures about:

o   Data categories collected;

o   Processing purposes;

o   Sharing practices;

o   User rights;

·       Adjustments to reflect new features (e.g., new monetization options, new API capabilities);

·       Changes required to comply with new laws or regulations;

·       Editorial corrections.

32.3 User Notification of Changes

Material changes to this Privacy Policy will be communicated to users via:

·       Platform announcements;

·       Email notification (where appropriate);

·       Prominent in-platform notices.

32.4 User Rights in Relation to Changes

Where required by law:

·       Users will have an opportunity to review and accept material changes;

·       Certain changes (e.g., new processing based on consent) will be implemented only after user opt-in.

32.5 Versioning and History

Zyntra will:

·       Maintain an archive of prior versions of this Policy;

·       Indicate the effective date of the current version.

CONTACT INFORMATION AND ENFORCEMENT

33.1 Data Controller

For purposes of applicable data protection laws, the Data Controller is:

BrainX.
Registered in: England and Wales
Headquarters: London, United Kingdom
Operational presence: Lagos, Nigeria
Parent company: PreciousX.

33.2 Data Protection Officer (DPO)

Zyntra has appointed a Data Protection Officer (DPO) responsible for:

·       Monitoring compliance;

·       Advising on privacy matters;

·       Acting as point of contact for:

o   Supervisory authorities;

o   Data subjects.

Contact: [email protected] (example — to be finalized).

33.3 User Rights Requests

Users may exercise their privacy rights by contacting:

·       Zyntra Support & Help Center: https://support.zyntra.social

·       DPO email (for GDPR-specific requests);

·       Online Data Subject Request forms (where implemented).

33.4 Complaints to Authorities

Users have the right to:

·       Lodge complaints with:

o   UK ICO (for UK-based users);

o   NDPC (Nigeria Data Protection Commission);

o   Other relevant supervisory authorities based on jurisdiction.

Zyntra encourages users to:

·       First contact Zyntra’s DPO to seek an amicable resolution.

33.5 Enforcement of This Privacy Policy

Zyntra will:

·       Take violations of this Policy seriously;

·       Investigate breaches of privacy obligations;

·       Impose disciplinary actions where appropriate (e.g., against employees or partners);

·       Cooperate fully with regulators.

33.6 Jurisdiction and Governing Law

This Privacy Policy shall be:

·       Governed by the laws of England and Wales (primary jurisdiction);

·       Subject to compliance with:

o   EU GDPR (for EEA users);

o   NDPA (for Nigerian users);

o   CCPA/CPRA (for eligible US users);

o   Other applicable national laws.