Privacy Policy

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• passwords
• contact preferences
• contact or authentication data
• billing addresses
• business name, business registration information, business address, business contact information, and other information provided when creating or managing a business account.
• information provided when connecting business accounts and communication channels such as whatsapp and instagram, including account identifiers and information required to authenticate and operate the integration.
• information that business users choose to provide or upload about their customers, such as customer names, phone numbers, email addresses, delivery addresses, order information, and customer conversation data.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://zella.com.ng/cookie-policy.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Information collected from other sources

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
• To provide AI-powered customer communication. To process customer messages and business information in order to provide AI-assisted customer service, generate responses, manage conversations, and assist businesses with customer enquiries.
• To manage connected communication channels. To connect, authenticate, operate, and maintain integrations with third-party communication platforms such as WhatsApp and Instagram on behalf of businesses.
• To maintain and improve AI systems. To monitor, evaluate, troubleshoot, and improve the performance, reliability, safety, and quality of Zella's AI-powered features.
• To process business and customer data. To organize and process business, customer, product, order, and conversation information necessary to provide Zella's services.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work.

The third parties we may share personal information with are as follows:

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements or to tailor advertisements to your interests. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://zella.com.ng/cookie-policy.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, ‘AI Products’). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers (‘AI Service Providers’), including OpenAI, Anthropic, and Groq. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in ‘WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?’. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• Customer service / customer support
• Generating responses / conversational AI

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

How to Opt Out

We believe in giving you the power to decide how your data is used. To opt out, you can:

• Contact us using the contact information provided
• Log in to your account settings and update your user account

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@zella.com.ng.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.
• You may request deletion of your Zella account and associated personal information by visiting our Personal Data Request portal or contacting us using the contact information provided on our website. We may retain certain information where required by law, for legitimate business purposes, or to comply with our legal and regulatory obligations.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

Zella uses artificial intelligence to generate automated responses to customer messages on behalf of the businesses that use our platform. When you message a business using Zella, you may be communicating with an AI system rather than a human. Automated responses are generated based on the business's product catalogue, configured preferences, and your message content.

Zella may also take automated actions such as creating an order or, in some cases, confirming a payment without human review by the business owner. If you believe an automated decision has affected you unfairly, you have the right to request human review by contacting the business directly or by reaching out to us at privacy@zella.com.ng.

Where a business uses Zella's receipt forwarding feature, Zella acts solely as an administrative intermediary that relays a photograph of a payment receipt to the business owner. This feature does not constitute financial verification, does not guarantee that funds have been received, and is not a payment processing service. The business owner is solely responsible for independently confirming receipt of funds in their own bank account before releasing goods or services. Zella is not liable for losses arising from a business's reliance on an unverified receipt.

Some of your personal data is processed by service providers located outside Nigeria, including artificial intelligence processing providers (used to generate automated responses to your messages), Meta Platforms, Inc. (for WhatsApp and Instagram message delivery), and email service providers used for transactional communications. Where such transfers occur, we rely on appropriate legal safeguards, including contractual protections with our processors, to ensure your data continues to receive a level of protection consistent with the Nigeria Data Protection Act 2023 and its implementing directives.

When you or a business using Zella requests deletion of personal data, we deactivate the associated account and data immediately becomes inaccessible through normal use of the platform. Underlying data is retained for a limited period thereafter to allow for the resolution of any pending disputes, fraud investigations, or legal obligations, after which it is permanently deleted. Where data is subject to an active legal process, safety investigation, or law enforcement request, we may retain it for as long as necessary to fulfill that obligation, consistent with applicable law.

Zella Labs LTD processes personal data in accordance with the Nigeria Data Protection Act 2023 and the General Application and Implementation Directive (GAID) 2025, as enforced by the Nigeria Data Protection Commission (NDPC).

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated ‘Revised’ date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at privacy@zella.com.ng, or contact us by post at:

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please visit our online portal: https://app.zella.com.ng/data-request.