ZUUPPA

Privacy Policy

Last updated: June 16, 2026  ·  Effective: June 16, 2026

This Privacy Policy explains how Zuuppa Inc., a Delaware corporation (“Zuuppa,” “we,” “us,” or “our”), collects, uses, and shares information when you use the Zuuppa mobile application, websites, and related services (collectively, the “Platform”). By using the Platform, you agree to this Privacy Policy. If you do not agree, do not use the Platform.

Zuuppa provides a self-custodial wallet and does not control or hold your crypto assets or private keys. Information recorded on a public blockchain (such as wallet addresses and transactions) is public and outside our control.

1. Information We Collect

1.1 Information you provide

1.2 Information collected automatically

1.3 Wallet and transaction information

1.4 Social graph

We do not intentionally collect sensitive personal information (such as precise location, government IDs, biometric data, or financial account numbers). We do not perform identity verification (KYC).

2. How We Use Information

We do not send marketing or promotional emails or push notifications. We do not sell your personal information or share it for cross-context behavioral advertising.

3. How We Share Information

We share information only as described below:

4. Service Providers

We use the following categories of third-party processors to operate the Platform. These providers process information on our behalf and are authorized to use it only to provide their services:

ProviderPurpose
SupabaseAuthentication and database
Cloudflare R2Media and file storage
TurnkeySelf-custodial wallet infrastructure
Firebase Cloud Messaging (Google)Push notifications
HeliusSolana blockchain (RPC) connectivity
SentryError monitoring and diagnostics
JupiterToken swap routing
Apple WalletTicket passes

This list may change as our service evolves.

5. Data Storage and International Transfers

Our servers and data are located in the United States. If you access the Platform from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where data-protection laws may differ from those in your country. Where required, we rely on appropriate safeguards for international transfers.

6. Data Retention

We retain personal information for as long as your account is active and as needed to provide the Platform. When you delete your account, we delete or de-identify your personal information within approximately 30 days, except where we must retain certain information to comply with legal, tax, accounting, or regulatory obligations, to resolve disputes, or to enforce our agreements (for example, transaction and financial records). Information recorded on the public blockchain cannot be deleted by us.

7. Security

We use reasonable technical and organizational measures designed to protect your information, including encryption in transit and access controls. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. Because your wallet is self-custodial, you are responsible for safeguarding your account credentials and wallet access.

8. Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information. We honor the following rights for all Users to the extent applicable:

To exercise your rights, contact us at support@zuuppa.com. We will not discriminate against you for exercising your rights. We may need to verify your identity before responding.

9. EU/UK (GDPR) Disclosures

If you are in the European Economic Area or the United Kingdom, Zuuppa is the controller of your personal data. We process your data on the following legal bases: performance of a contract (to provide the Platform), legitimate interests (such as security, fraud prevention, and improving the Platform), consent (where required, such as for certain device permissions), and legal obligation. You have the rights described in Section 8, and you may lodge a complaint with your local supervisory authority. You may also withdraw consent at any time where processing is based on consent. We have not appointed a Data Protection Officer or EU/UK representative; please direct all requests to support@zuuppa.com.

10. California (CCPA/CPRA) Disclosures

If you are a California resident, you have the right to know what personal information we collect, to access and delete it, to correct it, and to opt out of the “sale” or “sharing” of personal information. We do not sell your personal information and do not share it for cross-context behavioral advertising. We do not use or disclose sensitive personal information for purposes that require an opt-out. The categories of information we collect and the purposes for which we use them are described in Sections 1–3. We will not discriminate against you for exercising your rights. To submit a request, contact us at support@zuuppa.com.

11. Children’s Privacy

The Platform is intended only for users who are at least 18 years old. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a person under 18, we will delete it. If you believe a minor has provided us information, contact us at support@zuuppa.com.

12. Cookies and Tracking

Our website does not use advertising or tracking cookies, and the mobile app does not use cookies for tracking. We use only the device identifiers and diagnostic data described in Section 1 to operate the Platform.

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the “Last updated” date above and may provide additional notice through the Platform. Your continued use of the Platform after changes take effect constitutes acceptance of the updated policy.

14. Contact

Questions about this Privacy Policy or your information? Contact us at support@zuuppa.com.

Zuuppa Inc., a Delaware corporation. c/o Registered Agent: Legalinc Corporate Services Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, USA.