EFFECTIVE DATE: 22 July 2026

This Privacy Policy explains how we collect and process your personal data when you access or use our App, our Services or any related services (such as email communications or our social media channels). At ZELUS ( “we”, “us” or “our”), we are committed to protecting your privacy and processing your personal data in a transparent, fair and secure manner. We process your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and all other applicable data protection laws.

This Privacy Policy should be read together with our Terms and Conditions, which govern your use of the App and the Services. By accessing or using the App and the Services, you acknowledge that you have been informed about the processing of your personal data as described in this Privacy Policy. If you do not agree with this Privacy Policy, you should discontinue your use of the App and the Services.

1. DATA CONTROLLER 
When you create an account, access and or use our app and  services, ZELUS having its registered office at 56 Michalaokopoulou str., p.c. 11528, Athens, with registration number 150686103000, acts as the controller of your personal data.
If you have any questions about this Privacy Policy or the way we process your personal data, or if you wish to exercise any of your rights under applicable data protection laws, you may contact us at vong@zelus.gr.

2. PERSONAL DATA WE COLLECT
We collect and process different categories of personal data depending on how you interact with the App and the Services. The personal data described below may be provided directly by you or collected automatically through your use of the App and the Services.

• • User account (when you create an account with us): Your name, email address, username, account authentication information (such as login credentials or information received from a third-party authentication provider), profile picture. Optionally, you may also provide your top size, bottom size, shoe size and country.
  • Electronic Identification Data and Technical Information (when you access and use the App and the Services): IP address, unique device identifiers, browser type, date and time of access, and other technical information necessary for the operation, security and maintenance of the App.
  • Usage and Interaction Data : Information relating to your use of the App and your interaction with its features, including the duration of your sessions, the features you use, content and recommendations displayed to you, products viewed, your interactions with content made available through the App, clicks on products or external links, navigation within the App, and other interactions with the Services.
  • User Content: Content that you upload, submit or otherwise make available through the App, including photos of your clothes, shoes and accessories, your daily outfits, your styling preferences, information about the users you follow, connect with or otherwise interact with, and any other content or links you choose to share or interact with through the App.
  • Location Data: Certain features of the App are available only if location information is enabled. Where you choose to use those features, we may use GPS technology to determine your current location, provided that you have given your explicit consent to the processing of your location data.
  • Metadata: Metadata relating to your User Content, such as the date and time the content was created and the type of content (e.g., photo or text).

Unless otherwise indicated, the personal data requested for the provision of the App and the Services is mandatory. Failure to provide mandatory personal data may prevent us from providing some or all of the App and the Services. Where the provision of personal data is optional, this will be clearly indicated, and you are free to decide whether to provide such data.

3. WHY WE PROCESS YOUR PERSONAL DATA
We process your personal data only where we have a lawful basis for doing so and for the following purposes:
(a) To create and manage your account and provide you with the App and the Services.
(b) To communicate with you regarding the App and the Services, including responding to your enquiries, sending service-related communications, updates, security notifications and, where you have given your consent, marketing communications, newsletters and promotional materials.
(c) To operate, maintain, monitor, evaluate, improve and develop the App and the Services, personalization features and other technologies used to enhance your experience.
(d) To analyse how the App and the Services are used, generate internal analytics and statistics, better understand user interactions and preferences, and improve the functionality, performance and overall user experience of the App.
(e) To ensure the security, integrity and proper functioning of the App and the Services,
(f) to facilitate or support a merger, acquisition, investment, corporate restructuring or other business transaction involving all or part of our business;
(g) To comply with our legal and regulatory obligations and to respond to lawful requests, court orders or other binding requests from judicial, regulatory or other competent public authorities.

4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
For the purpose set out in point (a), we process your personal data because such processing is necessary to provide you with the App and the Services. Where required by applicable law, we will ask for your consent before accessing certain features or permissions on your device. For example, we will request your permission before accessing your device’s location to provide location-based functionalities or before accessing photographs and other media stored on your device when you choose to upload them through the App. You may withdraw your consent at any time by changing your device or App settings. Withdrawal of your consent will not affect the lawfulness of any processing carried out prior to such withdrawal.

For the purpose set out in point (b), we process your personal data where such processing is necessary to communicate with you regarding the App and the Services, including responding to your enquiries and sending you service-related communications, updates and security notifications. We rely on your consent to send you marketing communications, newsletters and other promotional materials.

For the purposes set out in points (c) to (f), we process your personal data on the basis of our legitimate interests, where such processing is necessary to maintain, secure and improve the App and the Services, better understand how Users interact with the App and its functionalities, generate internal usage statistics and analytics, and enhance the overall user experience.

For the purpose set out in point (g), we process your personal data where such processing is necessary to comply with our legal obligations.

5. RECIPIENTS OF DATA
To provide, operate and improve the App and the Services, we may disclose your personal data, where necessary and in accordance with applicable data protection laws, to the following categories of recipients:

• Service Providers (Processors). We engage carefully selected third-party service providers that process personal data on our behalf. These service providers process personal data in accordance with our contractual arrangements and documented instructions, solely for the purposes of providing the services for which they have been engaged. We require them to implement appropriate technical and organisational measures to protect personal data and to comply with applicable data protection laws, including the GDPR.
  Currently,, our principal service providers include:
  • • Hetzner Online GmbH (Germany), which provides our hosting and data centre infrastructure; and
    • Google Cloud Platform (Firebase), with personal data stored in the europe-west1 (Belgium) region, which provides cloud hosting, storage and application support services.
• Corporate Transactions. Your personal data may be disclosed to prospective purchasers, investors, successors, professional advisers or other parties participating in a merger, acquisition, restructuring, financing transaction or the sale of all or part of our business or assets, subject to appropriate confidentiality obligations.
• Public Authorities and Legal Obligations. We may disclose your personal data where required by law or where we reasonably believe such disclosure is necessary to comply with a legal obligation, respond to lawful requests or decisions of competent public authorities, or establish, exercise or defend our legal rights.

We do not sell or rent your personal data. We disclose your personal data only in the circumstances described in this Privacy Policy, where you have instructed or authorised us to do so, or where disclosure is required or permitted by applicable law.

Please note that certain functionalities of the App allow you to share content with other Users. Any content that you voluntarily publish or otherwise share through the App may become visible to other Users. We therefore encourage you to exercise caution and avoid including personal data or other confidential or sensitive information in any content that you choose to share.

6. RETENTION
We retain your personal data only for as long as necessary to fulfil the purposes described in the section “WHY WE PROCESS YOUR PERSONAL DATA”. We will delete your personal data when they are no longer necessary for those purposes unless:

• we are required to retain them to comply with a legal or regulatory obligation, a court order or a lawful request from a competent public authority;
• retention is necessary for the establishment, exercise or defence of legal claims; or
• continued retention is otherwise required or permitted under applicable law.

7. DATA PROTECTION
The security of your personal data is important to us. We implement appropriate technical and organisational measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, taking into account the nature of the personal data, the risks associated with the processing and the requirements of applicable data protection laws.

Access to personal data is limited to our authorised personnel and the recipients referred to in Section 5 of this Privacy Policy, only to the extent necessary for the fulfilment of the relevant processing purposes.

Your personal data are primarily processed and stored within the European Economic Area (“EEA”). However, certain service providers or their affiliated entities may access or process personal data from outside the EEA. Where personal data are transferred outside the EEA, we ensure that an appropriate transfer mechanism is in place in accordance with applicable data protection laws. This may include reliance on an adequacy decision adopted by the European Commission or, where no such decision exists, the implementation of appropriate safeguards, such as the European Commission’s Standard Contractual Clauses or another lawful transfer mechanism.

8. YOUR RIGHTS 
Under applicable data protection laws, and subject to the conditions and limitations set out therein, you have the following rights in relation to your personal data:

• Right of access – to obtain confirmation as to whether we process your personal data and, where that is the case, to access your personal data and receive certain information relating to the processing.
• Right to rectification – to request the correction of inaccurate personal data and the completion of incomplete personal data.
• Right to erasure – to request the deletion of your personal data where the conditions set out in applicable data protection laws are met. Please note that this right is not absolute and may be limited where we are required to retain your personal data to comply with a legal obligation or for the establishment, exercise or defence of legal claims.
• Right to restriction of processing – to request that we restrict the processing of your personal data in certain circumstances, including where you contest the accuracy of your personal data, where the processing is unlawful, or where the personal data are required for the establishment, exercise or defence of legal claims.
• Right to object – to object, on grounds relating to your particular situation, to processing based on our legitimate interests, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defence of legal claims.
• Right to data portability – to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format and, where technically feasible, to request that such data be transmitted directly to another controller.
• Right to withdraw consent – where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing carried out before such withdrawal.

When submitting your request, please clearly indicate the right you wish to exercise and provide sufficient information to enable us to process your request. Where necessary, we may request additional information solely for the purpose of verifying your identity.

We will respond to your request without undue delay and, in any event, within the time limits prescribed by applicable data protection laws.

If you have any questions or concerns regarding the processing of your personal data, we encourage you to contact us first so that we have the opportunity to address your concerns.

You also have the right to lodge a complaint with the competent supervisory authority, including the Hellenic Data Protection Authority, if you consider that the processing of your personal data infringes applicable data protection laws.

9. THIRD PARTY WEBSITES
Our App may contain links to third-party websites, online stores or other services, including those of our Partner Brands. If you select a product, click on an external link or otherwise leave the App to access a third-party website or service, your interaction with that website or service, including any processing of your personal data, will be governed solely by that third party’s applicable privacy policy, terms and conditions and other relevant policies.

We do not control and are not responsible for the privacy practices, policies, content or availability of any third-party website or service. We encourage you to review the applicable privacy policy and terms and conditions before providing any personal data or entering into any transaction with such third party.

10. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is effective as of the date indicated at the beginning of this document. We may update this Privacy Policy from time to time to reflect changes to our Services, applicable law or our personal data processing practices. Where appropriate, we will make reasonable efforts to notify you of any material changes. We encourage you to review this Privacy Policy periodically to stay informed about how we process and protect your personal data. The “Last Updated” date at the beginning of this Privacy Policy indicates when it was most recently revised.

11. CONTACT US
If you have any questions, comments or concerns about this Privacy Policy or the way we process your personal data, or if you wish to exercise any of your rights under applicable data protection laws, you may contact us via email at vong@zelus.gr