This Privacy Policy ("Policy") describes how Esprito Tech QFZ LLC ("Esprito Tech QFZ LLC," "Zeono," "Company," "we," "us," or "our"), a company incorporated under the laws of the State of Qatar and registered in the Ras Bufontas Free Zone, collects, uses, stores, shares, and protects information obtained from and about users ("User," "you," or "your") of the Zeono platform, including the website at zeono.app, mobile applications, APIs, and all related services (collectively, the "Platform" or "Services").
We are committed to protecting your privacy and handling your data with transparency. By accessing or using the Platform, you acknowledge that you have read, understood, and consent to the practices described in this Policy. If you do not agree with this Policy, please do not use the Services.
The data controller responsible for the processing of your personal data is:
Esprito Tech QFZ LLC
Registered Address: Office 62, Ras Bufontas Admin Building, Building 43, Street 517, Zone 49, Ras Bufontas Free Zone, Doha, Qatar
Email: support@esprito.app
If you are located in the European Economic Area (EEA) or the United Kingdom (UK), or another jurisdiction that requires the appointment of a data protection representative, our representative can be contacted at: support@esprito.app.
This Policy applies to all personal data processed in connection with your use of the Platform, regardless of how you access it (web browser, mobile application, or API). This Policy does not apply to the practices of third parties that we do not own or control, including but not limited to Brokerage Providers, market data providers, and AI service providers. We encourage you to review the privacy policies of any third-party services you interact with through the Platform.
When you connect a Brokerage Account, the Platform may access the following information via authorized API, depending on the permissions you grant:
We process your information for the following purposes:
If you are located in the EEA, the UK, or another jurisdiction that requires a legal basis for processing personal data, we rely on the following legal bases:
We may share your information with the following categories of recipients:
We do not sell your personal data to third parties for their own marketing purposes.
When you connect your Brokerage Account, the Platform accesses account data and submits Orders through the Brokerage Provider's API. Data shared with your Brokerage Provider is governed by its own privacy policy and regulatory obligations. US Brokerage Providers are subject to SEC Regulation S-P, which governs the protection of customer information.
Your text commands are processed by AI models hosted by third-party providers. We send the minimum data necessary for command interpretation and do not include personally identifiable information such as your name, email, or brokerage credentials in AI processing requests. We have data processing agreements with our AI providers.
Market Data displayed on the Platform is sourced from third-party providers and Exchanges. These providers may have their own terms regarding the use of their data.
Information accessed from your connected Brokerage Account (portfolio holdings, balances, order history) is treated as sensitive financial data. We implement enhanced security measures for this data, including encryption, access controls, and audit logging.
As a platform that facilitates interaction with securities markets, we may be required to provide information to securities regulators (including the SEC, FINRA, or equivalent foreign regulators) in connection with regulatory examinations, investigations, or enforcement proceedings. We will comply with lawful regulatory requests and may be prohibited from notifying you of such requests in certain circumstances.
Zeono does not issue tax documents (such as Forms 1099). Tax reporting for your Securities transactions is the responsibility of your Brokerage Provider. However, we may retain transaction-related data that could be relevant to your tax obligations.
When you submit a text command to the Platform, the AI Agent processes your input to understand your intent and generate the appropriate response or action. This processing involves transmitting your command text (and potentially recent conversational context and relevant portfolio data) to AI model providers for inference. We do not include your name, email, brokerage credentials, or other directly identifying information in AI processing requests.
We may use anonymized and aggregated data derived from User commands to improve the Platform's AI models and command interpretation accuracy. We do not use your personal data or identifiable trading commands to train third-party AI models without your explicit consent.
The Platform uses automated processing to interpret your commands, generate market analysis, and prepare Orders. However, Order submission to your Brokerage Provider requires your explicit confirmation. You have the right not to be subject to a decision based solely on automated processing which produces legal effects or similarly significant effects on you, except where authorized by law or based on your explicit consent.
When required by applicable law (e.g., in the EEA/UK), we will obtain your consent before placing non-essential cookies. You can manage your cookie preferences through the cookie consent banner on the Platform or through your browser settings. Disabling certain cookies may limit the functionality of the Platform.
The Platform does not currently respond to "Do Not Track" (DNT) signals transmitted by web browsers. However, you can manage tracking through the cookie and privacy controls described above.
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law:
| Data Type | Retention Period |
|---|---|
| Account Data | Duration of active use + 5 years (or as required by law) |
| Trading Commands & AI Interaction Logs | 12 months, then anonymized or deleted |
| Order and Transaction Data | 7 years (securities record-keeping requirements) |
| Brokerage Account Connection Data | While connected; promptly revoked and deleted upon disconnection |
| Support Communications | 3 years from date of resolution |
| Analytics and Usage Data (identifiable) | 24 months; anonymized/aggregated data retained indefinitely |
| Payment Data | As required by applicable tax and accounting regulations |
We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:
While we strive to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure. You are responsible for maintaining the security of your account credentials and connected Brokerage Account.
Your personal data may be transferred to, stored, and processed in countries other than your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction. When we transfer personal data internationally, we implement appropriate safeguards, which may include:
By using the Platform, you consent to the transfer of your information to jurisdictions outside your country of residence, subject to the safeguards described above.
Depending on your location and applicable data protection laws (including the GDPR, UK GDPR, CCPA/CPRA, and other applicable legislation), you may have the following rights:
To exercise any of these rights, please contact us using the information provided in Section 18. We will respond within the timeframe required by applicable law (typically 30–45 days). We may need to verify your identity before processing your request.
You also have the right to lodge a complaint with your local data protection supervisory authority if you believe that our processing of your personal data violates applicable data protection laws.
The Platform is not intended for, and we do not knowingly collect personal data from, individuals under the age of eighteen (18) or the age of legal majority in their jurisdiction, whichever is higher. If we become aware that we have collected personal data from a minor without appropriate parental or guardian consent, we will take reasonable steps to delete such data. If you believe that we may have collected data from a minor, please contact us immediately.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by posting the updated Policy on the Platform with a revised "Last Updated" date and, where required by law, by providing additional notice (e.g., in-app notification or email). Your continued use of the Platform after the effective date of the updated Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us at:
Esprito Tech QFZ LLC
Office 62, Ras Bufontas Admin Building, Building 43, Street 517, Zone 49, Ras Bufontas Free Zone, Doha, Qatar
Email: support@esprito.app
Website: zeono.app
If you are located in the EEA or the UK and wish to contact our Data Protection Officer, please reach out to: support@esprito.app