ZELCAFE PRIVACY POLICY Effective date: September 8, 2026 Version: 1.0 Application: ZelCafe (iPhone, iOS) Developer and data controller: Rocheston Contact: via the Support link on the ZelCafe App Store listing This Privacy Policy describes how the ZelCafe application ("ZelCafe", "the app", "we", "us", "our") treats information when you download, install and use it. It is written to be read by ordinary people and to satisfy the disclosure requirements of the Apple App Store, the General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Children's Online Privacy Protection Act (COPPA), Brazil's LGPD, Canada's PIPEDA, and similar privacy laws worldwide. By installing or using ZelCafe you acknowledge this policy. If you do not agree with it, please do not use the app. SECTION 1. SUMMARY 1.1 ZelCafe collects no personal data. It does not collect, store, transmit, sell, share, rent or otherwise process any personal information about you. 1.2 Nothing you do inside ZelCafe is sent anywhere. The app contains no account system, no login, no analytics, no advertising, no crash reporting, no tracking technologies, no cloud synchronization, no push notification service, and no developer-operated server. 1.3 Everything runs on your device. All game content, background scenes, music, sound effects, meditation and relaxation audio, motivation quote cards and the complete CyberZel 3079 Audiobook are bundled inside the app package delivered by the App Store. The app does not download or stream any content and works fully in airplane mode. 1.4 The only network activity the app can ever perform is an optional, user-initiated coffee tip processed by Apple through StoreKit. That transaction is handled by Apple under Apple's privacy policy. ZelCafe never receives your payment details or identity. 1.5 App Store "App Privacy" label: Data Not Collected. ZelCafe does not collect any data linked to you, any data not linked to you, or any data used to track you. SECTION 2. DEFINITIONS "Personal data" or "personal information" means any information relating to an identified or identifiable natural person, as defined by applicable law, including identifiers, contact details, device identifiers, location data, online identifiers, usage data and inferences. "Processing" means any operation performed on personal data, whether or not by automated means, including collection, recording, storage, use, disclosure, transmission and deletion. "Tracking" has the meaning used in Apple's App Tracking Transparency framework: linking data collected from the app with data collected from other companies' apps, websites or offline properties for targeted advertising or measurement, or sharing data with data brokers. "Local storage" means the private, sandboxed storage area on your own iPhone that iOS reserves for the app. SECTION 3. INFORMATION WE DO NOT COLLECT ZelCafe does not collect or process any of the following categories of information, whether entered by you, generated by your use of the app, or obtained from your device or from third parties: 3.1 Contact information: name, email address, phone number, physical address, or any other contact detail. 3.2 Account information: usernames, passwords, credentials, profile information. ZelCafe has no accounts. 3.3 Identifiers: user ID, device ID, Identifier for Advertisers (IDFA), Identifier for Vendors (IDFV), serial number, MAC address, IMEI, IP address, or any other persistent or derived identifier. 3.4 Location: precise location, coarse location, region, time zone inferred for profiling, or any geolocation data. 3.5 Health and fitness: mindfulness minutes, sleep records, mood, stress, heart rate, or any data from the Health app or HealthKit. ZelCafe does not integrate with HealthKit. 3.6 Financial information: payment card numbers, billing information, bank details, credit information, purchase history. Optional tips are processed by Apple (see Section 6). 3.7 Sensitive information: racial or ethnic origin, religious or philosophical beliefs, political opinions, sexual orientation, trade union membership, genetic or biometric data, disability, immigration status. 3.8 Contacts, photos, videos, audio recordings, calendar, reminders, files or documents. ZelCafe does not request access to any of these. 3.9 Camera, microphone, Bluetooth, local network, motion sensors, Siri or speech recognition. ZelCafe does not request access to any of these. 3.10 Usage data: product interaction, screens viewed, features used, taps, session length, scores as telemetry, audiobook or music listening history, timer usage, or any behavioral data. 3.11 Diagnostics: crash logs, performance data, energy diagnostics, error reports. 3.12 Browsing or search history, messages, emails, or content of any communication. 3.13 Inferences: any profile, prediction, characterization or inference about you. 3.14 Data from other sources: ZelCafe does not obtain information about you from data brokers, advertising networks, social networks, analytics providers or any other third party. SECTION 4. INFORMATION STORED LOCALLY ON YOUR DEVICE 4.1 To remember your choices between sessions, ZelCafe writes a small amount of non-personal preference and score information to its own sandboxed local storage on your iPhone. This information is not personal data in the sense of identifying you, is not transmitted, is not accessible to us, and is under your sole control. 4.2 The complete list of locally stored items is: (a) Settings: Visual Mode (Simple or Animated); Background Scenes (Animated, Retro or Cafe); Music toggle (On or Off); Sound Type (Music or Rain Sounds); Flying Donuts toggle (On or Off); Sleep Timer selection (Off, 5, 10, 20, 30 minutes or 1 hour); and whether the hidden Autoplay setting has been unlocked by tapping the top heart three times. (b) Score Dashboard: best score, best level achieved, and number of games played. (c) Session state: whether the sleep screen is currently active after a timer has expired. 4.3 ZelCafe does not store your name, any identifier, any timestamped activity log, or any record of what you listened to or when. 4.4 You control this information completely: (a) The Score Dashboard includes a Reset Scores control that permanently erases best score, best level and games played. (b) Changing any setting overwrites the previous value. (c) Deleting ZelCafe from your iPhone permanently deletes all locally stored information. We retain no copy, because we never had one. 4.5 Device backups. If you have enabled iCloud Backup or back up your iPhone to a computer, iOS may include the app's local files as part of the backup of your entire device. Those backups are created, encrypted, stored and controlled by you and by Apple under Apple's terms and privacy policy. ZelCafe does not initiate, manage or access backups and cannot read them. SECTION 5. NETWORK ACTIVITY 5.1 ZelCafe has no developer-operated server, API, database, content delivery network, remote configuration service, feature flag service, or telemetry endpoint. There is no address inside the app for it to send information to Haja Mo or to Rocheston. 5.2 ZelCafe does not download or stream content. Every asset, including all animated background videos, retro and cafe artwork, music tracks composed by Haja Mo, rain and snow audio, the meditation video and audio, The Ring of Heaven tracks, the CyberZel Audiobook files, motivation quote cards, sound effects, splash artwork and the app icon, is contained in the application bundle installed from the App Store. 5.3 Because of 5.1 and 5.2, the app performs no network requests in ordinary use. You may verify this by enabling airplane mode: the complete game and all bundled media continue to function without change. 5.4 The single exception is described in Section 6. SECTION 6. OPTIONAL COFFEE TIPS (APPLE STOREKIT) 6.1 ZelCafe is completely free. The full experience, including every game mode, scene, track, quote card, the audiobook and the sleep timer, is included at no cost. There are no subscriptions, plans, tiers, paywalls or paid unlocks. 6.2 The About page offers three optional, voluntary tips, presented as "Buy Me a Coffee": Small Coffee, Coffee and Big Coffee. Tips are consumable in-app purchases. They do not unlock features or content and are purely a way to support the developer. 6.3 If, and only if, you choose to tap a tip option, the purchase is initiated and completed through Apple's StoreKit framework and Apple's in-app purchase system. In that process: (a) Apple presents its own payment sheet, authenticates you, and charges your Apple Account payment method. (b) ZelCafe never receives, sees, stores or transmits your name, Apple ID, email address, payment method, card number, billing address or any other payment or identity information. (c) ZelCafe receives from Apple only a transaction result indicating that a purchase of a given product succeeded, failed or was cancelled, so that the app can display a thank-you message. ZelCafe does not store a purchase history. (d) Apple retains a record of the transaction in your Apple Account purchase history and may use it in accordance with Apple's Privacy Policy, available at apple.com/legal/privacy. Apple acts as an independent controller of that information. Refund requests are handled by Apple. 6.4 The StoreKit connection to Apple is the only network communication ZelCafe is capable of, and it occurs only when you deliberately start a tip. If you never tip, the app never contacts Apple's purchase servers. 6.5 Purchases by minors are subject to Apple's Ask to Buy, Family Sharing and Screen Time controls, which are configured by the parent or guardian in iOS. SECTION 7. APPLE OPERATING SYSTEM FEATURES 7.1 Certain ZelCafe features rely on capabilities built into iOS that operate on your device: (a) Now Playing, lock screen and Control Center controls. When The Ring of Heaven or the CyberZel Audiobook is playing, ZelCafe provides the track title, artist name, album name and artwork to the iOS Now Playing system so you can see and control playback from the lock screen or Control Center. This information describes the bundled content, not you, and is displayed locally on your device. ZelCafe does not transmit it. (b) Audio playback uses the iPhone's native audio frameworks. (c) Local storage uses the standard iOS application sandbox. 7.2 iOS itself, the App Store, iCloud, Screen Time, Family Sharing and other Apple services may process information about your device and your use of apps in general, under Apple's Privacy Policy. ZelCafe does not receive any such information from Apple about you. SECTION 8. PERMISSIONS ZelCafe requests no iOS privacy permissions. It does not ask for access to location, contacts, calendars, reminders, photos, camera, microphone, Bluetooth, local network, motion and fitness, health, speech recognition, Siri, or tracking. It does not display the App Tracking Transparency prompt because it performs no tracking. It does not request permission to send notifications and does not send notifications. SECTION 9. THIRD PARTIES 9.1 ZelCafe integrates no third-party software development kits for advertising, analytics, attribution, crash reporting, customer engagement, A/B testing, remote configuration, social login, chat, or any other purpose. 9.2 ZelCafe does not share, sell, rent, license, disclose or transfer any information to advertisers, data brokers, analytics providers, business partners, affiliates, or any other third party. ZelCafe has no such relationships. 9.3 The only third party that processes any information in connection with the app is Apple Inc., solely (a) as the operator of the App Store through which the app is distributed and (b) as the processor of optional tips through StoreKit, in each case under Apple's own privacy policy and terms. 9.4 Portions of the app's visual components incorporate modified open-source software licensed under the MIT License. Those components are compiled into the app, run locally, and contain no networking or data-collection functionality. Attribution is provided on the app's Licenses page. SECTION 10. TRACKING AND ADVERTISING 10.1 ZelCafe displays no advertising of any kind, including banner, interstitial, rewarded, native or sponsored content. 10.2 ZelCafe does not track you across apps or websites owned by other companies, does not share data with data brokers, and does not participate in advertising measurement or attribution of any kind. 10.3 ZelCafe does not use cookies, web beacons, pixels, device fingerprinting, or any similar technology. SECTION 11. CHILDREN'S PRIVACY 11.1 ZelCafe is intended for general audiences. It is not directed specifically at children, but it is suitable for them. 11.2 ZelCafe does not knowingly or unknowingly collect personal information from anyone, including children under the age of 13 (COPPA), under 16 (GDPR default), or under the applicable age of digital consent in any jurisdiction. Because the app collects no personal information from any user, no parental consent mechanism is required and there is no children's data to review, correct or delete. 11.3 Parents and guardians are responsible for supervising a child's use of the app and for configuring Apple's parental controls, including Ask to Buy, for any optional tips. SECTION 12. LEGAL BASES AND PURPOSES (GDPR AND UK GDPR) 12.1 Because ZelCafe does not process personal data, no legal basis under Article 6 of the GDPR is required for the operation of the app. 12.2 To the extent that the local storage of settings and scores on your own device could be regarded as processing, it is carried out solely on your device, solely at your instruction, solely for the purpose of providing the functionality you have requested (Article 6(1)(b), performance of a contract, and Article 6(1)(f), legitimate interest in remembering your preferences), and it never leaves your device or reaches the developer. 12.3 ZelCafe does not perform automated decision-making or profiling. SECTION 13. DATA RETENTION 13.1 The developer retains no personal data, because none is collected. 13.2 Locally stored settings and scores remain on your device until you change them, reset scores, or delete the app. The developer has no ability to access, retain or recover them. SECTION 14. INTERNATIONAL DATA TRANSFERS ZelCafe transfers no personal data across borders, or anywhere, because it transmits no personal data. Any processing performed by Apple in connection with app distribution or optional tips is governed by Apple's privacy policy and Apple's international transfer safeguards. SECTION 15. YOUR PRIVACY RIGHTS 15.1 Depending on where you live, you may have rights to access, rectify, erase, restrict, port, or object to the processing of your personal data; to opt out of sale, sharing or targeted advertising; to limit the use of sensitive personal information; to withdraw consent; and to lodge a complaint with a supervisory authority. 15.2 ZelCafe holds no personal data about you. Consequently: (a) Right of access: there is no personal data to provide. (b) Right to rectification: there is nothing to correct. (c) Right to erasure: there is nothing on any server to erase; all local information is erased by deleting the app. (d) Right to portability: there is nothing to export. (e) Right to opt out of sale or sharing: ZelCafe does not sell or share personal information and never has. This constitutes our notice under CCPA/CPRA that we do not sell or share personal information and have not done so in the preceding twelve months. (f) Right to limit use of sensitive personal information: no sensitive personal information is collected. (g) Right to non-discrimination: exercising any right has no effect on your use of the app, which is free and identical for everyone. 15.3 You may nonetheless submit a request or question using the Support link on the ZelCafe App Store listing. We will respond within the time required by applicable law, ordinarily by confirming that no personal data is held. We may not be able to verify your identity for a request precisely because we hold no identifying information; in that case we will explain this in our response. 15.4 Residents of the European Economic Area, the United Kingdom and Switzerland may contact their national data protection authority. California residents may contact the California Privacy Protection Agency. Authorized agents may submit requests on a consumer's behalf where permitted by law. SECTION 16. SECURITY 16.1 The most effective security measure is not collecting data. ZelCafe operates no servers, holds no user database, stores no credentials and transmits no personal data, so there is no ZelCafe system that could suffer a breach of your personal information. 16.2 Information stored locally on your device is protected by your iPhone's own security features, including device passcode, Face ID or Touch ID, iOS application sandboxing, and Apple's data protection encryption. 16.3 Optional tip transactions are secured by Apple's StoreKit and Apple's payment infrastructure. SECTION 17. THE ZELCAFE WEBSITE 17.1 The ZelCafe website is a static informational page separate from the app. It loads no third-party scripts, fonts, analytics, advertising or tracking technologies and sets no advertising cookies. 17.2 If you use the website's option to pause decorative animation, that single preference is stored in your own browser's local storage and is never transmitted. 17.3 As with any website, the hosting provider may maintain standard, short-lived server access logs (for example, requested page and time) for operational and security purposes under the provider's own policies. These logs are not used to identify, profile or track visitors and are not combined with any app data, because no app data exists. SECTION 18. DO NOT TRACK AND GLOBAL PRIVACY CONTROL ZelCafe does not track users, so browser Do Not Track signals and Global Privacy Control signals require no action; the outcome they request is already the default and only behavior. SECTION 19. CHANGES TO THIS POLICY 19.1 If ZelCafe changes in any way that affects the statements in this policy, we will revise this document, update the version number and effective date at the top, and describe the change plainly. Material changes will be reflected in the App Store listing and, where required by law, presented within the app. 19.2 We commit that ZelCafe will not add tracking, analytics, advertising, accounts or data collection without an updated policy that says so clearly. The statement that ZelCafe collects no personal data and sends nothing anywhere is the foundation of the app. SECTION 20. CONTACT Data controller: Rocheston Application: ZelCafe Support and privacy inquiries: via the Support link on the ZelCafe listing on the Apple App Store For questions about Apple's processing of App Store or in-app purchase information, please refer to Apple's Privacy Policy at apple.com/legal/privacy or contact Apple directly. SECTION 21. APP STORE PRIVACY DISCLOSURE (FOR REFERENCE) For transparency, the App Privacy information declared for ZelCafe in App Store Connect is: Data Not Collected. The developer does not collect any data from this app. Data used to track you: None. Data linked to you: None. Data not linked to you: None. Privacy practices may be verified by using the app in airplane mode, by reviewing the absence of any privacy permission prompts, and by noting that no App Tracking Transparency prompt is displayed. END OF PRIVACY POLICY