Last Updated: January 1, 2026

Zephyros Inc. (hereinafter referred to as "Zephyros"), including its product Polira (hereinafter referred to as "Polira"), as well as its subsidiaries and affiliates (hereinafter collectively referred to as "Company," "we," "us," or "our"), is committed to protecting your privacy. We take data protection seriously, and this Privacy Policy explains what information we collect, how we collect it, why we collect it, how we use it, and whom we share it with. If you have any questions about your personal data, please contact us at support@polira.ai.

This Privacy Policy may be updated or changed from time to time as laws and regulations change. When we update this Privacy Policy, we will post the updated version on our website and indicate the effective date of the update.

1. Our Services

This Privacy Policy applies to personal information we collect through our Platform and other products and services we offer at Polira. It covers data collection, use, storage, and disclosure practices across all our services.

2. Collection of Information

2.1 Automatically Collected Information When you visit our website, use our services, or due to our service infrastructure, certain information may be automatically collected. This includes how and when you use the services, prompts you enter, and resulting outputs. We also use cookies, pixel tags, and other tracking technologies to automatically collect information about how you use our services. Cookies are small data files transferred from websites to your hard drive. Cookies can be "persistent" or "session" cookies. We use cookies for the following purposes: • Essential Cookies: User authentication and prevention of fraudulent account use • Cookie Policy/Notice Acceptance Cookies: To verify if you have accepted cookie usage • Functionality Cookies: To remember login details and language preferences • Tracking and Performance Cookies: To track website traffic and service usage 2.2 Universal Opt-Out Mechanism You may install a Universal Opt-Out Mechanism (UOOM) in your browser. UOOM is a browser signal indicating your intent to opt out of certain uses of your personal information on websites you visit. 2.3 Do Not Track We do not change our data collection and use practices when we detect a Do Not Track signal from your browser. 2.4 Information You Provide Directly We collect information you provide directly, which may include personal information. When you create an account, submit content through our services, request customer support, submit payment for paid services, or communicate with us through our website, we collect certain information including your username, email address, and other information you choose to provide. "Personal Information" means any information relating to an identified or identifiable individual, including but not limited to personal email addresses. 2.5 Information We Do Not Collect We do not collect sensitive personal information, including details about race or ethnicity, political opinions, religious beliefs, or health conditions.

3. Use of Information

We use the information we collect to: (1) Provide, maintain, and improve our services; (2) Process transactions and send related information; (3) Send you technical notices, updates, and administrative messages; (4) Respond to your comments and questions; (5) Analyze usage patterns and trends; and (6) Detect, investigate, and prevent fraudulent activities.

4. Sharing of Information

We may share information about you in the following circumstances: (1) With vendors and service providers who need access to perform services for us; (2) In response to a request for information if we believe disclosure is required by law; (3) If we believe your actions are inconsistent with our user agreements or policies; (4) To protect our rights, privacy, safety, or property; and (5) In connection with, or during negotiations of, any merger, sale of company assets, or acquisition.

5. Third-Party Analytics and Advertising

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites.

6. Other Sites and Services

The Services may contain links to other websites and services that are not owned or controlled by us. We are not responsible for the privacy practices or content of these third-party websites and services.

7. Security

We take reasonable measures to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. However, no internet or email transmission is ever fully secure or error free.

8. Data Retention

We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it or as otherwise permitted or required by law. We may also retain certain information in anonymized or aggregated form.

9. Face Data

If you use features that involve face detection or recognition, we process this data only to provide the requested service. We do not use face data for advertising purposes and do not sell or share face data with third parties except as necessary to provide our services.

10. Children

Our Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take steps to delete such information.

11. Data Subject Rights (Rights under Personal Information Protection Act)

We comply with the Republic of Korea's Personal Information Protection Act ("PIPA"). Data subjects may exercise the following rights under PIPA. 11.1 Your Personal Information Protection Rights As a data subject, you have the following rights: • Right to request access: The right to request access to your personal information held by us • Right to request correction or deletion: The right to request correction or deletion of errors in your personal information • Right to request suspension of processing: The right to request suspension of processing of your personal information • Right to withdraw consent: The right to withdraw consent to the collection and use of personal information 11.2 Exercising Personal Information Protection Rights To exercise these rights, please email support@polira.ai, Attention: Personal Information Protection Officer. When you close your account, your personal information will be deleted. Upon receiving your request, we will respond within 10 business days and let you know if we need additional information to verify your request. Under PIPA, requests will be processed within 10 days (for access) or without delay (for correction, deletion, or suspension of processing).

12. International User Rights

If you are located outside of the Republic of Korea, please note that information you provide to us may be transferred to and stored in countries other than your home country. By using the Services, you consent to such transfers.

13. Personal Information Protection Officer

We have designated a Personal Information Protection Officer to oversee our privacy practices and ensure compliance with applicable laws. You can contact our Privacy Officer at support@polira.ai.

14. Contact Us

If you have any questions about this Privacy Policy, please contact us at support@polira.ai.