Privacy Policy

Effective date: June 17, 2026

1. Introduction

This Privacy Policy explains how Zafka (“we”, “us”, or “our”) collects, uses, stores, and protects your personal data when you use the Zafka mobile application (the “App”). This Policy is governed by the laws of Germany and the General Data Protection Regulation (GDPR) where applicable.

2. Information We Collect

We collect and process the following categories of information:

• Account information: a user identifier, username, and avatar preferences.
• Decision scenarios: the titles, descriptions, and branching storylines you create in the App.
• Usage data: information about how you interact with the App, such as scenario counts and exploration depth, used only to provide in-app features like pattern analysis.
• Purchase history: records of Token purchases you make through the App.

We do not require you to provide your real name, email address, or phone number to use the App.

3. How We Use Your Information

We use your data to:

• provide, maintain, and improve the App;
• generate branching storylines and outcome illustrations;
• process in-app purchases and maintain your Token balance;
• anonymously analyze usage patterns to improve the service.

4. Legal Basis for Processing (GDPR)

We process your personal data based on one or more of the following legal grounds:

• Performance of a contract: to provide the App and its features to you.
• Consent: where you expressly agree, for example to personalized features.
• Legitimate interests: to improve our service and ensure security, balanced against your rights.
• Legal obligation: to comply with applicable laws.

5. Third-Party Service Providers

We may use trusted third-party providers to help operate the App, such as AI generation services that process scenario descriptions to create storylines. These providers act on our instructions and are contractually bound to protect your data. No personally identifiable information is intentionally shared with them beyond what is necessary to perform the service.

6. Data Storage and Security

Your decision scenarios, branching storylines, and preferences are stored primarily on your device. We implement reasonable technical and organizational measures to protect your data from unauthorized access, loss, or alteration. However, no method of electronic storage is completely secure.

7. Data Retention

We retain your personal data only for as long as necessary to provide the App or as required by law. If you delete your account, we will delete or anonymize your data unless legal obligations require us to keep it.

8. Your Rights

Under the GDPR and other applicable laws, you have the right to:

• access the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request erasure of your personal data (“right to be forgotten”);
• request restriction of processing or object to processing;
• request data portability;
• withdraw consent at any time, where processing is based on consent.

To exercise these rights, please contact us at [email protected].

9. Children’s Privacy

The App is not directed to children under the age of 13, and we do not knowingly collect personal data from children under 13. If you believe we have inadvertently collected such data, please contact us and we will promptly delete it.

10. International Transfers

Your data is processed in Germany and, where necessary, by service providers in other jurisdictions. When data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place in accordance with applicable data protection laws.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted with a revised effective date. We encourage you to review this Policy periodically.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at [email protected].