Privacy Policy

App Name: Sherlock Owner: Zen Tech LLC Last Updated: June 9, 2026

Table of Contents

Introduction
Information We Collect
Biometric Data and Facial Recognition
How We Collect Information
How We Use Your Information
How We Share Your Information
Data Retention
Your Privacy Rights and Choices
Children's Privacy
Security
International Data Transfers
Third-Party Services and Links
California Privacy Rights
European Privacy Rights (GDPR)
State Biometric Privacy Rights
Changes to This Privacy Policy
Contact Us
Introduction
Zen Tech LLC ("we," "us," "our," or "Zen Tech") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application "Sherlock," our websites, and related services (collectively, the "Services").

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please do not access or use the Services. This Privacy Policy applies to information we collect through our mobile application, our websites, through email, text, and other electronic communications, and when you interact with our advertising.

Information We Collect
We collect information about you in various ways when you use our Services. To comply with Apple App Store and Google Play Store data-safety requirements, we categorize data collection as follows:

2.1 Information You Provide Directly

Search Images: Photographs you upload, capture, or submit in order to run a facial-recognition search. See Section 3 for how this image data and the facial templates derived from it are handled.
Account Information (if you create an account): name, email address, username and password, profile picture, date of birth, and phone number (optional).
User Content: messages, feedback, reviews, ratings, survey responses, and customer-support communications.
Payment Information: transaction history. We do not store complete payment card numbers or CVV; all payment processing is handled by Apple, Google, or other secure third-party processors that comply with PCI-DSS standards.

2.2 Information Collected Automatically

Device Information: device type and model, operating system and version, unique device identifiers (IDFA, Android Advertising ID), device settings, and IP address.
Usage Information: screens viewed, features used, searches performed, time spent, navigation paths, interactions, and error logs and crash reports.
Approximate Location: derived from IP address. We do not collect precise GPS location unless you grant explicit permission, which you may revoke at any time in your device settings.
Cookies and Similar Technologies: we and our partners use cookies, pixels, and similar technologies on our websites.

2.3 Information from Third Parties

Social Login: if you connect a social account (e.g., Apple, Google, Facebook), we receive your name, picture, and associated email address.
Search Providers: publicly available results returned by the third-party facial-recognition search providers described in Section 3.

2.4 Biometric Information
To perform a search, the Services generate a facial template (a mathematical representation of facial geometry) from the image you upload. This is "biometric information." Because of its sensitivity, it is governed by the specific terms in Section 3.

Biometric Data and Facial Recognition
This Section is our publicly available written policy governing biometric data, including for purposes of the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act (CUBI), and the Washington biometric privacy law.
3.1 What We Process. When you upload a photograph to run a search, the Services analyze the facial geometry in ary "facial template" or "faceprint."3.2 Purpose. The facial template is created and used for one purpose only: to perform the facial-recognition see, and the image you submit, are transmitted to one or more third-party search providers that index publiclyavailable images across the open web and public social-media profiles in order to return possible matches.3.3 Consent. We do not generate or use a facial template without your consent. By accepting our Terms of Servic provide your informed written consent to the collection, generation, transmission, and storage (as describedbelow) of facial templates derived from the images you submit, solely to perform your requested search. You may by ceasing to use the search feature and contacting us at support@zentecapps.com.

3.4 No Sale or Profit. We do not sell, lease, trade, or otherwise profit from your biometric identifiers or bio not disclose them except to the third-party search providers necessary to perform your search, or as required
by law.

3.5 Retention and Destruction Schedule. We retain biometric data only as long as needed to perform your search.plate and uploaded image are processed transiently and are permanently destroyed upon completion of the search,
and in no event later than 24 hours after the search is performed. In accordance with BIPA, in no case will we or biometric information longer than (a) the date on which the initial purpose for collection has been
satisfied, or (b) three (3) years after your last interaction with us, whichever occurs first. Upon expiration eriod, biometric data is permanently and irreversibly destroyed.

3.6 Your Image Rights. You represent that you have the legal right to submit each image you upload and, for any yourself, that you have obtained that person's consent or are otherwise legally permitted to submit it.

How We Collect Information
We collect information through: (4.1) direct collection — information you voluntarily provide; (4.2) automatic ication, server logs, and analytics tools (such as Google Analytics or Firebase); and (4.3) third-party sources
— social platforms (with your permission), analytics providers, advertising networks, and our facial-recognitio
How We Use Your Information

To Provide the Services: create and manage your account, perform searches, process transactions, and provide
To Improve and Personalize: understand usage, develop features, and personalize content.
For Marketing: send promotional communications (you may opt out at any time) and provide advertising complianransparency where applicable.
For Analytics and Performance: analyze trends and track performance and crashes.
For Safety and Security: detect fraud, prevent unauthorized access, and enforce our Terms of Service.
For Legal Compliance: comply with applicable laws and regulations.

We do not use facial templates for any purpose other than performing your requested search, as described in Section 3.

How We Share Your Information

Facial-Recognition Search Providers: to perform your search, we transmit your uploaded image and the derived y search providers. They process this data to return publicly available matches and are contractually limited to that purpose.
Service Providers: analytics (Google Analytics, Firebase), advertising (Google AdMob, Facebook Audience Network), cloud infrastructure (e.g., Supabase, Amazon Web Services), payment processors (Apple, Google), and customer support.
Business Transfers: if Zen Tech LLC is involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction.
Legal Requirements: we may disclose information if required by law, court order, or to protect the rights andublic.
We may update this Privacy Policy from time to time. We will notify you of changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. Please review it periodically.

Contact Us
If you have any questions about this Privacy Policy, please contact us:
Zen Tech LLC
Email: support@zentecapps.com
Subject Line: Privacy Inquiry - Sherlock App