Privacy Policy and Data Security

Informed Consent: We only process data after your express authorization.

Data Quality: Information will be accurate, current, and truthful.

Security: We implement technical and organizational measures to prevent loss or unauthorized access.

Confidentiality: Personnel with access to your data are bound by professional secrecy.

Identification: Full name, ID number (individual or corporate), email address, and phone number.

Financial Data: Information about assets, income, expenses, debts, and investment goals necessary for financial analysis.

Credentials: Usernames and encrypted passwords for platform access.

Billing: subscription plan, status and payment history, provider customer/payment references, and payment-method summaries when returned by the payment provider, such as card brand, last four digits, expiry and holder name. Zenloth uses these records to manage subscriptions, show payment methods and resolve billing issues.

Registration eligibility: we process your date of birth to check the minimum age of 18, then retain only the eligibility decision, applicable minimum age, policy version and verification time. New registration submissions do not retain the full birthdate or collect gender. Previously stored birthdate and gender records remain subject to the existing access and deletion rights. An optional insurance quote is a separate request that retains the full policyholder birthdate, as explained below.

Technical Data: IP address, browser type, operating system, and access times.

Product analytics: after sign-in, Zenloth records session starts, page views and feature interactions in the web and native apps, together with an account reference, session identifier, time, route, language and platform. These records help us understand usage and improve the service. Event metadata is filtered to exclude sensitive financial details, credentials and free-text input; account-linked usage records are not anonymous.

Cookies and Tracking: We use cookies to improve user experience and analyze platform performance.

Website measurement: the Zenloth website also uses Meta Pixel to send page-view, registration and subscription events to Meta for advertising measurement. This website integration is separate from the account-linked product analytics described above.

Contact and coverage: first and last name, email, phone/WhatsApp number, insurance type, who the coverage is for, and the full date of birth of the policyholder. The full birthdate is stored with this request, separately from the limited eligibility evidence retained for new registrations.

Quote details: health coverage preference (local or international); life insurance sum insured and plan; vehicle brand and year for auto insurance; or property type, province and canton for home insurance. The health quote form asks for a coverage preference, not a medical history.

Request records: your account reference, permission version and acceptance time, request status, forwarding and creation/update times, and, when provided, the page address and browser/device information associated with the request.

Purpose and recipient: Zenloth staff review the request and manually forward the quote information by email to Prointel, the insurance partner that receives it so an advisor can prepare the quote and contact you. Submitting the form records the request with Zenloth; it does not automatically send an email or transfer it to Prointel.

Retention and your choices: Zenloth keeps quote requests for review, manual forwarding and follow-up while your account is active. Confirmed account deletion deactivates your account and automatically removes the quote records stored in the Zenloth application database, including contact details, full birthdate and quote contents. No separate quote-deletion request is needed. The seven-day target for remaining background cleanup starts when your account is deactivated through confirmed deletion, not when you submit a quote. Automatic deletion covers records stored in Zenloth; it does not recall sent emails or erase separately held follow-up copies or copies already received by Prointel. Prointel controls the retention and deletion of its copies under its own procedures. Section 6A explains confirmation and limited retention.

Providing financial advice through our technology platform.

Personalizing your user experience and improving our analysis tools.

Processing transactions and managing your account.

Complying with legal obligations for money laundering prevention (Law 7786 and amendments).

Sending administrative or promotional communications, unless you have opted out.

Reviewing and following up optional insurance quote requests and, with the separate insurance permission, forwarding the quote details to Prointel.

Encryption: Sensitive data is transmitted using secure protocols (SSL/TLS).

Access Control: We restrict access to personal information only to employees and contractors who need to know it.

Monitoring: We conduct periodic audits of our systems to detect potential vulnerabilities.

Service Providers: Companies that help us operate the platform (cloud hosting, payment processing), who act as Data Processors under strict confidentiality contracts.

Insurance requests: with your separate permission, Zenloth staff manually share your quote information with Prointel as described in section 2A.

Legal Compliance: When required by a competent judicial or administrative authority in Costa Rica.

International Transfer: If we use servers outside Costa Rica, we ensure that the destination country offers adequate protection levels according to the criteria of the Data Protection Agency (PRODHAB).

Data accessed: Google account email address, provider account identifier, OAuth access and refresh tokens, Gmail message identifiers, sender, subject, received date, and the body/content of bank notification emails that match our supported sender rules.

Data created from Gmail: parsed transaction details such as amount, currency, transaction date, merchant/payee, reference number, source message identifier, import status, and related transaction records.

Data use: we use this data to verify your mailbox, read bank notification emails, import and categorize transactions, prevent duplicate imports, show sync status, reconnect your mailbox, troubleshoot the email import feature, and protect the service.

Data we do not change: Zenloth does not send, modify, archive, delete, label, or permanently delete messages in your Gmail account.

Data protection: OAuth tokens and provider credentials are stored encrypted at rest, and Google data is transmitted using secure protocols.

Data sharing: we do not sell, rent, or transfer Google user data to advertising platforms, data brokers, information resellers, or parties that use it for credit-worthiness, lending, retargeting, personalized advertising, or interest-based advertising.

Service providers: Google user data may be processed by infrastructure and service providers only as needed to operate, secure, maintain, or improve the user-facing Zenloth features described in this policy, subject to confidentiality and security obligations.

AI/ML restrictions: Zenloth does not use raw or derived Google Workspace API data to develop, improve, or train generalized or non-personalized AI/ML models. We do not transfer raw or derived Gmail data to third-party AI/ML services for those services to train their models.

Limited Use statement: Zenloth's use and transfer of information received from Google Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements.

Retention and deletion: Zenloth processes matching message bodies transiently and stores only a content-free source marker for deduplication after parsing; raw Gmail bodies are not retained in the ingestion record. Disconnecting a mailbox requests revocation of the Google OAuth grant, removes the stored connection credentials, stops future Gmail access, and deletes source identifiers, per-message metadata, and intermediate import candidates from Zenloth. If you choose to keep imported transactions, the resulting transaction records remain available for your budgets and reports; you can instead choose to delete those transactions during mailbox deletion.

Account deletion: deleting your account permanently removes user-owned profile, financial, Gmail-derived and mailbox-credential records from the application database and schedules remaining AI, sign-in and provider cleanup. Section 6A explains timing, the retained trial-abuse fingerprint and other limited retention. Original emails in your mailbox are not deleted.

Outlook / Microsoft 365: we request basic account identity and read-only mail access, plus permission to maintain access. We process your mailbox address and provider account identity and store OAuth access/refresh tokens and connection information. You authorize access with Microsoft; Zenloth does not ask for your Microsoft account password.

iCloud Mail: we use the mailbox address, Apple app-specific password and IMAP connection settings. Yahoo Mail: we use the mailbox address, Yahoo app password and IMAP connection settings.

Other supported IMAP mailboxes: we use the mailbox address, server, port and security settings, and the password or access token you provide. Password-based credentials may allow more actions at the provider; Zenloth uses them to read matching notifications and does not send, change or delete your messages.

Message processing: we read matching notification identifiers, sender, subject, received date and message content. Message bodies are processed transiently; stored source markers contain no raw message body. We retain source identifiers, per-message/import metadata, sync progress and intermediate transaction candidates to process notifications and prevent duplicates.

Financial records: imported records can include amount, currency, transaction date, merchant/payee, reference and transaction/account/category information. These records support your budgets and reports. Email permission alone does not authorize AI sharing; relevant imported financial records are shared with Zenny only under the separate AI permission described above.

Protection and sharing: stored connection credentials are encrypted. Infrastructure and service providers process the information needed to operate and secure email import. We do not sell mailbox data or use it for advertising.

Disconnecting: removing a mailbox stops future access and deletes the stored connection credentials, source markers, per-message metadata and import intermediates from Zenloth. You can keep the imported transactions for budgets and reports or choose to delete them when removing the mailbox. This does not delete the original messages in your mailbox.

Provider access: deleting stored credentials from Zenloth does not automatically revoke a Microsoft authorization, app password or other IMAP credential at the provider. You can also revoke that authorization or password in your provider account settings. The Google-specific revocation request described above applies to Gmail.

Account deletion: the account-deletion workflow removes the connected-mailbox credentials and user-owned imported financial/source records for these providers, subject to the timing and limited retained records in section 6A. Insurance quote records stored in Zenloth are also deleted; section 2A explains separately held follow-up and partner copies.

Access: Right to know what data we have about you.

Rectification: Right to update inaccurate or incomplete data.

Cancellation/Deletion: Right to have your data deleted when no longer necessary for the purpose collected.

Opposition: Right to object to the processing of your data for specific purposes.

You have been informed of the existence of a personal database owned by 3-101-946648 S.A.

You understand the mandatory or optional nature of your responses and the consequences of refusing to provide data.

You authorize the processing of your data for the purposes described herein.

Company Name: 3-101-946648 SOCIEDAD ANÓNIMA

Email: support@zenloth.tech

Address: San José, Mata Redonda, from Canal Siete, 200m west and 150m south.