Z≡NS
ZENSBUDS LIMITED
Room 715, 78-84 Kwai Cheong Road
Kwai Chung, New Territories, Hong Kong
cs@zenstech.com
This Privacy Policy explains how ZENS collects and processes personal data when you use the ZENS application on Android, iPhone, iPad, Mac and Windows, ZENSBUDS-compatible features, AI Notes, Translation, Ask AI, Lily, Voice Clone, and related cloud services (collectively, the “Service”).
The Service is operated by ZENSBUDS LIMITED, Room 715, 78-84 Kwai Cheong Road, Kwai Chung, New Territories, Hong Kong, unless the app, store listing, purchase flow or local terms identify another ZENS entity as the provider for your region, including 株式会社ZENS in Japan where stated. The applicable ZENS entity is the controller of personal data for the purposes described in this Policy, except where a service provider acts as an independent controller under applicable law. Privacy and support enquiries may be sent to cs@zenstech.com.
This Policy applies globally. Additional rights may apply depending on where you live, including under the EU General Data Protection Regulation (“GDPR”), UK GDPR, California Consumer Privacy Act as amended by the CPRA (“CCPA”), Japan’s Act on the Protection of Personal Information (“APPI”), Taiwan’s Personal Data Protection Act (“PDPA”), and Korea’s Personal Information Protection Act (“PIPA”).
### 2.1 Account and profile information
ZENS does not use SMS verification for account access. Registered accounts use email-based authentication and/or supported third-party sign-in.
### 2.2 Audio, meetings, translations and AI content
### 2.3 Contacts, contact cards, speaker IDs and memory
The contacts permission (Android `READ_CONTACTS`; the Contacts permission on iPhone, iPad and Mac) is used only when you ask Lily to find a person in your device contacts so that you can call or message that person. Your device address book remains on your device and is not uploaded to ZENS for this function. Separately, if you photograph, import or create a contact card, speaker label or memory item, ZENS may process the specific information you choose to save or attach to a meeting, translation or memory. ZENS does not access contacts for advertising or marketing purposes.
### 2.4 Voice Clone data
If you purchase or enable Voice Clone, you read a short passage of approximately 10–15 seconds. ZENS sends the sample to the selected voice-generation provider to create a synthetic voice for your account. Voice Clone is restricted to supported translation functions. ZENS does not use your Voice Clone to authenticate or uniquely identify you.
### 2.5 Device, app and usage information
The current releases on every platform do not include an analytics SDK or crash-reporting SDK. ZENS does not receive app-open counts, screen-view analytics, session-length analytics, button-tap analytics or automatic crash stack traces from the app. The only routine usage figures held by ZENS are the server-side counts needed to operate plan allowances, such as AI Notes minutes, translation minutes and AI-request counts.
### 2.6 Location information
Depending on your platform and operating-system version, the app may request approximate or precise location. Location may be needed for weather, nearby places and directions, and on older Android versions Bluetooth scanning may also require location permission. ZENS uses location only when a location-dependent function is requested or when Android requires it for Bluetooth operation. Where approximate location is sufficient, ZENS uses or transmits approximate location rather than unnecessarily precise coordinates. Location access is not required for core AI Notes or text-only functions, and you can deny or withdraw it in your device's settings.
Each platform controls certain access through its own permissions or privacy settings. ZENS requests only the access needed for features you choose to use, and asks when you first use such a feature. The tables below list what the app may request on each platform.
### 3.1 Android
Depending on your Android version and enabled features, the app may request the following:
| Permission / access | Purpose | Optional? |
|---|---|---|
| Microphone / audio settings | Recording meetings; live and call translation; voice input; Voice Clone. | Required only for audio features |
| Bluetooth scan / connect | Find, connect to and control compatible ZENSBUDS. | Required for earbuds features |
| Location (coarse / fine) | Weather, nearby places, directions; and Bluetooth scanning on Android versions that require location permission for scanning. | Optional by feature / Android version |
| Contacts | Let Lily find a person in your on-device contacts when you ask to call or message them. Contacts remain on the device for this function. | Optional |
| Photos / files / media audio / storage | Import recordings, documents, images or contact cards that you choose to use with the Service. | Optional by feature |
| Notifications | Show recording status, transcript-ready notices and other enabled service notifications. | Optional |
| Background microphone / foreground service / wake lock | Keep a recording or translation session that you deliberately started running while the screen is off or the app is not foregrounded, subject to Android controls and visible indicators. | Optional by feature |
| Display over other apps | Show floating translated subtitles over another app. The overlay draws text only; it cannot read the underlying screen or press controls. | Optional; separately enabled |
| MediaProjection / audio capture | Capture audio played by another app for video translation or online-meeting recording. Only audio is captured; no image of the screen is captured, retained or sent. Android displays its own consent prompt each time and a persistent indicator while active. | Optional; user-initiated each time |
The Android app does not request or use Android Accessibility services, does not use call-log permission, and cannot use accessibility access to read or act inside other apps. Bluetooth permissions are requested only as required by the Android version and earbuds functionality.
### 3.2 iPhone and iPad
| Permission | Purpose | Optional? |
|---|---|---|
| Microphone | Recording meetings; live and call translation; voice input; Voice Clone. | Required only for audio features |
| Bluetooth | Find, connect to and control compatible ZENSBUDS; detect when a call's audio is on them. | Required for earbuds features |
| Location (approximate) | Weather, nearby places, directions. | Optional by feature |
| Contacts | Let Lily find a person's number when you ask to call or text them. Contacts remain on the device for this function. | Optional |
| Calendars (add only) | Let Lily add the reminders you ask for to your calendar. | Optional |
| Camera | Photograph text so it can be translated. | Optional by feature |
| Photos | Choose a photo so text in it can be translated. | Optional by feature |
| Notifications | Recording status, transcript-ready notices and other enabled service notifications. | Optional |
The iPhone and iPad app may keep using the microphone and Bluetooth in the background only to continue a recording or translation session that you deliberately started. It does not capture the screen or the audio of other apps, does not display over other apps, and does not use accessibility or assistive-technology interfaces.
### 3.3 Mac
| Permission | Purpose | Optional? |
|---|---|---|
| Microphone | Recording meetings; live and call translation; voice input; Voice Clone. | Required only for audio features |
| Bluetooth | Find, connect to and control compatible ZENSBUDS; detect when a call's audio is on them. | Required for earbuds features |
| Location (approximate) | Weather, nearby places, directions. | Optional by feature |
| Contacts | Let Lily find a person's number when you ask to call or text them. Contacts remain on the device for this function. | Optional |
| Files you choose | Import recordings, documents or images you select; save exports where you choose. | Optional by feature |
| Printing | Print a transcript or summary, or save it as PDF. | Optional |
| Notifications | Recording status, transcript-ready notices and other enabled service notifications. | Optional |
The Mac app runs inside Apple's App Sandbox. It reaches no file you have not chosen, does not capture the screen or the audio of other apps, does not display over other apps, and does not use accessibility or assistive-technology interfaces.
### 3.4 Windows
Windows governs microphone and location access through its own privacy settings rather than per-app prompts, and Bluetooth pairing is done in Windows Settings. The app uses:
| Access | Purpose | Optional? |
|---|---|---|
| Microphone | Recording meetings; live and call translation; voice input. | Required only for audio features |
| Bluetooth (paired ZENSBUDS) | Control compatible ZENSBUDS that you have paired in Windows Settings; detect when a call's audio is on them. | Required for earbuds features |
| Location | Weather, nearby places, directions. | Optional by feature |
| Files you choose | Import recordings, documents or images you select; save exports where you choose. | Optional by feature |
| Printing | Print a transcript or summary, or save it as PDF. | Optional |
| Notifications | Windows notifications for recording status and transcript-ready notices. | Optional |
The Windows app does not capture the screen or the audio of other apps, does not display over other apps, and does not use assistive-technology interfaces.
ZENS uses personal data for the following purposes:
### 4.1 Legal bases for EEA/UK users
Where GDPR or UK GDPR applies, ZENS relies on one or more of the following legal bases depending on the processing: performance of a contract (to provide features you request); consent (for certain optional permissions, Voice Clone and other processing where consent is required); legitimate interests (such as security, fraud prevention, service reliability and limited product-improvement analysis using aggregated or de-identified server-side usage patterns that do not override your rights); and legal obligation (where processing is required by law).
| No third-party foundation-model training on your content ZENS configures its AI service providers so that recordings, transcripts, translations, prompts and other Service content sent through ZENS are not used by those providers to train their general-purpose models for unrelated customers, subject to the provider terms applicable to ZENS business/API use. |
|---|
Today, ZENS does not use the content of your private recordings, transcripts, translations, Lily conversations or Voice Clone sample to train third-party foundation models. ZENS may analyse aggregated or de-identified usage patterns, feature statistics, error patterns and quality signals to improve the Service.
ZENS is developing its own offline translation technology. If ZENS begins using user content or identifiable data to train, fine-tune or evaluate a ZENS-owned translation model in a manner that is materially different from this Policy, ZENS will update this Policy and provide any notice, consent or control required by applicable law before that processing begins. Where practical and legally required, users will be given a choice regarding use of their content for model-development purposes.
Voice Clone is an optional paid or entitled feature. To create a clone, you read a short ZENS-provided passage of approximately 10–15 seconds. The sample and necessary account reference are transmitted to Alibaba Cloud Model Studio/Qwen or a successor provider identified in the app to generate the voice profile.
ZENS uses service providers to operate the Service. Depending on the feature, language, model or engine you choose, personal data may be processed by:
| Provider / category | Purpose |
|---|---|
| Alibaba Cloud Model Studio (Qwen) | Speech recognition, translation, synthetic voices, Voice Clone, selected AI processing and Auto engine functions. |
| OpenAI | Meeting transcription and/or ChatGPT-based features when selected or used by the feature. |
| Anthropic (Claude) | AI processing when you select or use a Claude-powered function. |
| Google (Gemini) | AI processing when you select or use a Gemini-powered function; Google Sign-In authentication where enabled. |
| Microsoft Azure Speech | Speech processing for supported languages or speech functions. |
| Apple | Apple Sign-In authentication and App Store-related services where applicable. |
| Brave Search | Web search results for Lily or Ask AI when a web-search function is used. |
| OpenStreetMap / Overpass | Nearby-place and map-related data when requested. |
| Open-Meteo | Weather data when requested. |
| Google Play Billing | Android subscription billing, purchases and entitlement confirmation. Google may process purchase/account information and its own Play diagnostic telemetry. |
| Google Play Services - Sign-In | Google authentication when you choose “Continue with Google”. |
| Google Play Services - Location | Device location for weather, nearby places and directions when those functions are used. |
| Hosting, security and infrastructure vendors | Cloud hosting, network delivery, logging, abuse prevention, backup and security operations. |
ZENS may also disclose information when required by law, legal process or a valid governmental request; to protect the rights, safety and security of users, ZENS or others; in connection with a merger, acquisition, financing or sale of assets subject to appropriate confidentiality and legal requirements; or with your direction or consent.
ZENS does not sell personal information for money. ZENS does not use Service content for cross-context behavioural advertising.
ZENS’s primary cloud infrastructure for the Service is hosted in Japan using Amazon Web Services. Because ZENS operates globally and uses international service providers, information may be processed in countries other than where you live.
Where required, ZENS uses lawful transfer mechanisms and contractual safeguards appropriate to the relevant jurisdiction, such as standard contractual clauses, data-processing agreements, adequacy mechanisms or consent where applicable. For Japan, Korea, Taiwan, the EEA/UK and other jurisdictions with cross-border transfer rules, ZENS will provide additional information or obtain consent where required by local law.
Content stored in the ZENS cloud is generally retained until you delete it or delete your account, unless a shorter retention period applies to a specific feature or a longer period is required for legal, security, fraud-prevention, dispute or financial-record purposes.
Backup copies are retained only for the period reasonably necessary for resilience, security and legal obligations, then deleted or overwritten in accordance with ZENS backup schedules.
ZENS uses technical and organisational safeguards designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures may include encrypted transport, access controls, authentication, segregated environments, logging, vendor security controls and restricted administrative access. No system can guarantee absolute security, and users should protect account credentials and devices from unauthorised access.
Depending on the feature and your jurisdiction, you can:
To exercise privacy rights that are not available directly in the app, email cs@zenstech.com. ZENS may need to verify your identity before completing certain requests.
### 12.1 European Economic Area and United Kingdom
EEA and UK users may have rights to access, correct, erase, restrict or object to processing, receive certain data in portable form, withdraw consent where processing is based on consent, and lodge a complaint with a competent data-protection authority. Some rights are subject to legal conditions and exceptions. Cross-border transfers are handled using applicable safeguards described above.
### 12.2 California
If the CCPA applies to ZENS and you are a California resident, you may have rights to know/access, delete, correct and obtain information about categories of personal information collected, sources, purposes and disclosures; to opt out of sale or sharing; to limit certain uses of sensitive personal information; and to receive non-discriminatory treatment for exercising privacy rights. ZENS does not sell personal information for monetary consideration and does not use Service content for cross-context behavioural advertising. If ZENS introduces practices that constitute “sale” or “sharing” under California law, ZENS will provide the required opt-out mechanisms.
### 12.3 Japan
Where APPI applies, users may request disclosure, correction, suspension of use or deletion in circumstances provided by law. ZENS will provide required information regarding foreign transfers and entrusted processing, and will maintain appropriate safeguards for personal data handled outside Japan.
### 12.4 Taiwan
Where Taiwan’s PDPA applies, ZENS will provide legally required notice regarding the purposes and categories of data processed, the period, region, recipients and methods of use, and available data-subject rights. Users may exercise rights granted by the PDPA subject to applicable conditions and exceptions.
### 12.5 Republic of Korea
Where Korea’s PIPA applies, ZENS will provide legally required information regarding purposes, items processed, retention, processors and overseas transfers. Where separate consent is required for sensitive information, optional processing or cross-border transfer, ZENS will request that consent through the app or another appropriate interface.
### 12.6 Other jurisdictions
Users in other jurisdictions may have additional privacy rights under local law. ZENS will honour legally applicable rights and mandatory consumer protections even where this Policy does not list every local rule by name.
The Service is intended for users aged 18 or older. ZENS does not knowingly permit anyone under 18 to create an account or use the Service. If ZENS learns that personal data was collected from a user under 18, ZENS will take appropriate steps to delete or restrict the account and related data.
ZENS may update this Privacy Policy to reflect product, legal, security or operational changes. If a change materially affects how ZENS uses personal data, ZENS will provide reasonable notice in the app or through another appropriate channel before the change takes effect where required. The “Effective date” at the beginning of the Policy shows the latest version.
Privacy questions and rights requests may be sent to:
ZENSBUDS LIMITED Room 715, 78-84 Kwai Cheong Road Kwai Chung, New Territories Hong Kong Email: cs@zenstech.com
If a different ZENS entity is expressly identified as the controller for your region, the app, store listing or local terms may provide additional local contact information.