Privacy Policy
Updated: June 16, 2026
Privacy Policy
Last updated: June 16, 2026
Operator: Dramafy is operated by Zeto Global Inc. Contact: [email protected].
This Privacy Policy explains how Zeto Global Inc. ("Dramafy", "we", "us", or "our") collects, uses, shares, retains, and protects personal data when you use the Dramafy website, web and mobile applications, and related services (together, the "Service"), and describes your rights and choices.
This Policy is part of our Terms of Service and should be read with our Cookie Policy, AI Disclaimer, Community Guidelines, and Content Policy.
This Policy is written to meet, at a single global standard, the requirements of the EU/UK GDPR, the California Consumer Privacy Act as amended by the CPRA, Brazil's LGPD, Singapore's PDPA, and comparable laws in other jurisdictions where the Service is offered (see §11 for jurisdiction-specific notices). Where local law grants you stronger rights than described generally in this Policy, the local-law right applies.
1. Who is the data controller
Zeto Global Inc., incorporated in the United States, is the controller (or "business"/"controller" under equivalent local terminology) for personal data processed through the Service, unless stated otherwise for a specific feature. Our affiliate BLACKHOLEAR LTD acts as our establishment and point of contact for users in the United Kingdom. Personal data is hosted and processed primarily in Singapore (see §6).
Contact our privacy team:
- Email: [email protected]
- Web: /contact
- EU/UK representative or establishment (where required under GDPR Art. 27 / UK GDPR): [to be appointed/identified based on EU/UK user volume]
2. The data we collect
We collect personal data in three ways: (a) data you give us, (b) data collected automatically, and (c) data from third parties.
2.1 Data you give us
- Account data. Email address, username, password (stored hashed), profile information (display name, avatar, bio).
- Authentication data. If you sign in via a third-party provider (Google, Apple, etc.), the basic profile information you authorize (e.g., email, name).
- Age and consent data. The age you declare at sign-up (and any age changes), guardian consent for users 13–17, your acceptance of our legal policies, your content-preference and mature-content settings, and the date, IP address, and user agent at the moment of each consent or preference change.
- Chat and creation data. Messages you send to and receive from AI characters, characters and worlds you create, character configurations (names, backstories, prompts, tags, avatars, voices), scene and story data, generated images/audio/video, and any files you upload.
- Support and safety data. Information you provide to support, in feedback, or in reports about other users or content.
- Payment data. Our payment processor collects your payment method details directly. We receive only non-sensitive transaction metadata (last four digits, transaction ID, amount, plan, status, billing region for tax purposes).
2.2 Data collected automatically
- Device and usage data. Device/browser identifiers, operating system, language, IP address and IP-derived approximate location, access times, pages/features used, session duration, in-product interaction patterns (including how you interact with AI characters, e.g., message frequency and timing), referral URLs, crash and error logs.
- Cookies and similar technologies. As described in our Cookie Policy.
- Safety and integrity signals. Automated signals generated from your activity to detect abuse, fraud, coordinated manipulation, or policy violations (e.g., rate, pattern, keyword/classifier matches, flagged categories), including automated screening of messages for self-harm or crisis indicators as described in §3.4.
2.3 Data from third parties
- Identity providers, for sign-in.
- Payment processors and fraud-prevention services — transaction status, chargeback, fraud signals.
- Analytics, attribution, and advertising-measurement partners (subject to your cookie/consent preferences).
- Reports from other users.
We do not intentionally collect sensitive categories of data (e.g., race/ethnicity, religious or political beliefs, health data, sexual orientation, criminal history, precise geolocation, biometric identifiers) as a registration requirement. However, because Service conversations are free-form, you may voluntarily disclose such information in chats. By doing so, you direct us to process that data for the purposes in §3, subject to any additional protections required by applicable law (e.g., GDPR Art. 9, CPRA "Sensitive Personal Information"). We recommend you avoid sharing sensitive information you do not want processed as described in this Policy.
3. How we use your data
| Purpose | Examples |
|---|---|
| Provide the Service | Create/maintain accounts, deliver chats, generate AI Output, run creator tools, process subscriptions, enforce content ratings and regional availability |
| Personalize | Recommend characters, remember preferences/language, content-preference-aware feeds |
| Safety and trust | Detect/prevent abuse, enforce policies, respond to reports, age-appropriate protections, crisis-response screening |
| Develop and improve our AI systems | Train, fine-tune, evaluate, and benchmark Dramafy's AI models (including models used for features other than the one you used), build new features, and create de-identified/aggregated datasets for ongoing model development |
| Operate and grow the business | Analytics, product research, debugging, capacity planning, and — where you consent — marketing |
| Legal compliance | Comply with law, respond to lawful requests, enforce agreements, protect rights/property/safety, meet record-keeping obligations |
3.1 AI training and model improvement
Your conversations, character creations, and Output may be used by Dramafy and our AI service providers to (a) generate responses, and (b) develop, train, fine-tune, and evaluate Dramafy's AI models and related products, including models and features beyond the one you used. This is, by default, enabled for all accounts and is one of the core ways we improve the Service.
Your control. You can turn this off prospectively at any time via Settings → Privacy & Data → "Do not use my conversations to improve AI models." Turning it off:
- stops new conversations from being used for training going forward;
- does not retroactively remove your past conversations from models already trained, or from de-identified/aggregated datasets derived from them (see §7); and
- does not affect our processing of your data to deliver the Service, ensure safety, comply with law, or enforce agreements.
If you are located in the EU/EEA, UK, Switzerland, Brazil, or California, see §11 for region-specific information about the legal basis for this processing and how to exercise rights that function as an opt-out (e.g., GDPR Art. 21 right to object).
3.2 De-identified and aggregated data
We may create de-identified, pseudonymized, or aggregated data from your personal data (e.g., usage statistics, training datasets stripped of direct identifiers). Once data no longer identifies you and we have implemented technical and contractual controls against re-identification, we treat it as outside the scope of this Policy's individual-rights provisions and may use, retain, and share it without time limitation, including for research, product development, and commercial purposes such as benchmarking or licensing aggregate insights.
3.3 Automated decisions and profiling
We use automated systems to: rank/recommend content; detect abuse and policy violations; apply content-rating and regional-availability controls based on your declared age, content preferences, and detected region; and screen messages for safety signals (§3.4). These systems may flag a message, restrict a feature, hide content, or suspend an account. Significant enforcement actions (e.g., account termination) involve human review on appeal — see Community Guidelines.
3.4 Safety screening, including crisis-response
To meet legal and safety obligations (including emerging AI-companion laws that require crisis-intervention protocols), messages you send may be automatically screened for indicators of self-harm, suicide risk, or harm to others. If such indicators are detected, the Service may interrupt the normal character interaction to provide safety resources, and a record of the detection event (category and timestamp, not full message content) may be created and reviewed by trained safety staff. This processing relies on our legitimate interest in protecting life and safety (and, where applicable, vital-interests and legal-obligation bases) and applies regardless of your AI-training opt-out choice.
4. Legal bases for processing (EU/UK/EEA/Brazil and equivalent frameworks)
- Contract — processing necessary to provide the Service you request (accounts, chat delivery, subscriptions, content-rating enforcement).
- Legitimate interests — our default basis for product analytics, safety and integrity, fraud prevention, service security, and — subject to §3.1 and §11 — AI model development, where these interests are not overridden by your rights and a balancing assessment supports the processing. You can object to legitimate-interest processing at any time (§9); for AI training, the toggle in §3.1 implements this.
- Consent — required for: optional/advertising cookies, marketing communications, enabling mature content (which also requires an age representation), and — for users in jurisdictions where law requires it (see §11) — AI training on identifiable conversation data.
- Legal obligation — record-keeping, responding to lawful requests, and age/consent-record retention.
- Vital interests — emergency processing to protect life or physical safety (§3.4).
You can withdraw consent at any time; withdrawal does not affect the lawfulness of prior processing.
5. How we share your data
We do not sell personal data for money. Depending on your jurisdiction, certain data-sharing described below (e.g., with analytics/advertising partners, or for AI training with third-party model providers) may be considered a "sale" or "share" under laws like the CPRA — see §11.3 for your opt-out rights.
5.1 Service providers / sub-processors
Categories include: cloud hosting and storage; AI model providers (including third-party foundation-model providers used to generate or help train responses); payment processors; email/customer-support tools; analytics, attribution, and error monitoring; security and fraud prevention; age-assurance vendors (if and where deployed). All are bound by contracts requiring protection of your data consistent with this Policy. An up-to-date sub-processor list is available at /sub-processors or on request to [email protected].
5.2 Other users
Your public profile, published characters, public comments, and anything you post in shared/public spaces are visible to other users by design. Private 1:1 chats with AI characters are not shown to other users, except as needed for safety review, abuse investigation, or legal process.
5.3 Legal and safety disclosures
We may disclose data to law enforcement, regulators, or other parties where we believe in good faith it is necessary to: comply with law or valid legal process; enforce our Terms/policies; detect/prevent fraud, security, or technical issues; protect the rights, property, or safety of Dramafy, our users, or the public; or investigate child-safety or other serious-harm matters (including, where applicable, reporting child sexual abuse material to the U.S. National Center for Missing & Exploited Children (NCMEC) and to competent authorities in the regions we operate).
5.4 Business transfers
In a merger, acquisition, reorganization, financing, or asset sale, personal data may be transferred as part of that transaction, subject to confidentiality commitments and, where required, notice to you.
6. International data transfers
Singapore is our primary location for hosting and processing personal data. Because our controlling entity is in the United States and our sub-processors and AI providers operate in multiple countries, your data may also be processed in the United States, parts of the EU/EEA, and other jurisdictions.
- Transfers from the EEA/UK/Switzerland to Singapore or the United States, or to any other country without an adequacy decision, are made under Standard Contractual Clauses (SCCs) (and the UK International Data Transfer Addendum), together with a transfer impact assessment and additional technical and organizational safeguards as appropriate. Where personal data is processed in the United States by an entity that self-certifies to the EU-US / UK Data Privacy Framework, that mechanism may also apply.
- Transfers from Brazil rely on LGPD-compliant transfer mechanisms.
- Transfers from other jurisdictions rely on consent, contractual safeguards, or other mechanisms permitted by local law.
Contact [email protected] for details on the specific safeguards applicable to your data.
7. How long we keep data
We keep personal data only as long as necessary for the purposes in this Policy, plus any period required by law. You may request earlier deletion subject to the exceptions below.
| Category | Default retention |
|---|---|
| Account data | While active, plus up to 24 months after deletion in backup/archive systems (purged on the next backup cycle thereafter) |
| Chat, creation, and Output data | While active, plus up to 24 months after account deletion, except data already incorporated into AI training, model evaluation sets, or de-identified/aggregated datasets, which may be retained indefinitely per §3.2 |
| Age, consent, and content-preference records | Minimum 5 years after the relevant consent/declaration is superseded, to demonstrate compliance with age-verification and consent obligations |
| Safety/crisis-screening event logs | Up to 3 years, longer if related to an active investigation or legal hold |
| Payment and tax records | As required by applicable tax/accounting law (typically 5–10 years) |
| Support tickets | Up to 3 years |
| Cookies | As set out in the Cookie Policy |
When a retention period ends, we delete the data or render it non-identifying (at which point §3.2 applies).
8. How we protect your data
We use technical and organizational measures including: encryption in transit (TLS) and at rest where supported by our infrastructure providers; role-based access controls, audit logging, and least-privilege access for staff; monitoring/alerting for anomalous access; vendor security review for sub-processors; and incident-response procedures, including breach notification to regulators and affected users as required by applicable law (e.g., GDPR 72-hour notification, LGPD notification to ANPD, Singapore PDPA notification to the PDPC, and applicable US state breach-notification laws).
9. Your rights (general / GDPR-aligned baseline)
Subject to the jurisdiction-specific notices in §11, you generally have the right to:
- Be informed — this Policy is our primary notice.
- Access — request a copy of personal data we hold about you.
- Rectification — correct inaccurate or incomplete data.
- Erasure — request deletion, subject to the retention exceptions in §7 and the license-survival terms in the Terms of Service §5.3.
- Restriction — request we limit processing in certain circumstances.
- Object — object to processing based on legitimate interests (including, per §3.1, AI-training use) or direct marketing.
- Portability — receive a machine-readable copy of data you provided to us.
- Withdraw consent at any time, without affecting prior lawful processing.
- Lodge a complaint with us first ([email protected]) and, if unresolved, with your local data-protection authority (see §11 for examples).
Most of these can be exercised directly from Settings → Privacy & Data (export, delete account, manage AI-training and marketing preferences, manage cookie preferences). For anything else, email [email protected]. We will respond within the timeframe required by applicable law (generally 30 days, extendable as permitted) and may need to verify your identity first.
A parent or legal guardian may exercise these rights on behalf of a minor in their care, subject to verification.
10. Children and minors
The Service is intended for users aged 13 and above (or the higher minimum age required by local law — see §11.5 for examples). Users 13–17 may only use the Service with parental/guardian consent and cannot enable mature content. We do not knowingly collect personal data from children below the applicable minimum age; if we learn we have, we will delete the account and associated data, and you may report suspected violations to [email protected].
11. Jurisdiction-specific notices
11.1 European Economic Area, United Kingdom, and Switzerland (GDPR / UK GDPR)
- The legal bases in §4 apply. Where §3.1 (AI training on identifiable conversations) relies on legitimate interests, we have conducted (or will conduct) a documented Legitimate Interest Assessment; you may object at any time as described in §3.1, which we will honor as an erasure/restriction of future use.
- You have the right to lodge a complaint with your local supervisory authority (e.g., the Irish Data Protection Commission, the UK Information Commissioner's Office (ICO), or your member-state authority).
- International transfers are made under SCCs / the UK IDTA (and, for US processing, the Data Privacy Framework where applicable) as described in §6.
11.2 Brazil (LGPD)
- We act as "controlador" (controller). Legal bases mirror §4 (Art. 7 LGPD): execution of contract, legitimate interest, consent, and legal obligation.
- You may exercise your LGPD Art. 18 rights (confirmation, access, correction, anonymization, blocking, deletion, portability, information about sharing, and revocation of consent) via [email protected] or in-product where available.
- You may lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).
11.3 California, USA (CCPA/CPRA) and other US state privacy laws
- Categories collected/used/disclosed correspond to §2 and §3 (identifiers, account/profile information, internet/network activity, geolocation (approximate), audio/visual data you submit, inferences drawn from interactions, and — only if you voluntarily disclose it in chat — sensitive personal information).
- "Sale"/"Share." We do not sell personal information for monetary consideration. To the extent any analytics, advertising, or AI-training data flow with third parties is considered a "share" (e.g., for cross-context behavioral advertising) under the CPRA, you may opt out via Settings → Privacy & Data → "Do Not Sell or Share My Personal Information" or by submitting a Global Privacy Control (GPC) signal, which we will honor as an opt-out request.
- Right to Limit Use of Sensitive Personal Information, where applicable, is available via the same settings page.
- Rights to Know/Access, Delete, Correct, and Portability, and the right to non-discrimination for exercising these rights, are available via Settings → Privacy & Data or [email protected]. Some rights (e.g., deletion of training-relevant data) are subject to §3.1/§7's prospective-only effect.
- We will respond to verifiable consumer requests within 45 days (extendable by 45 days as permitted).
- Residents of other US states with comprehensive privacy laws (e.g., Virginia, Colorado, Connecticut, Utah, and others as they take effect) have substantially similar rights; contact [email protected] to exercise them.
11.4 Singapore (PDPA) — our primary data-processing location
Because personal data is hosted and processed primarily in Singapore, the Personal Data Protection Act 2012 (PDPA), as amended, governs that processing, in addition to applying to Singapore-resident users as one of our priority markets.
- The PDPA's Legitimate Interests Exception and Business Improvement Exception permit certain uses of personal data — including improving and developing our products and services — subject to a reasonableness test. We rely on these exceptions, alongside the bases in §4, as part of the legal basis for Singapore-based data processing, including aspects of AI model development described in §3.1, for users not otherwise covered by GDPR/LGPD/CPRA-style requirements.
- We do not use NRIC, FIN, or other Singapore national identification numbers for account authentication or identity verification, consistent with PDPC guidance.
- You may exercise the rights in §9 (access, correction, withdrawal of consent where consent is the basis, and — where the Data Portability Obligation applies — portability) via [email protected] or Settings → Privacy & Data.
- You may lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore.
11.5 Other jurisdictions (Asia-Pacific priority markets and beyond)
| Jurisdiction | Framework | Notable points |
|---|---|---|
| Indonesia | UU PDP (2022) | Access, correction, erasure, consent withdrawal, objection to profiling, portability; complaints to the relevant PDP authority. Mature-content availability is also subject to Indonesian content regulations reflected in our Content Policy. |
| Thailand | PDPA (2019) | Access, rectification, erasure, restriction, portability, objection, consent withdrawal; complaints to the PDPC (Thailand). Thai law independently restricts certain adult content — see Content Policy. |
| Vietnam | Decree 13/2023 (PDPD) | Access, rectification, deletion, restriction, objection, portability; complaints to the Ministry of Public Security. Local-storage/representative obligations may apply on request under Decree 53/2022. |
| Malaysia | PDPA (2010) | Access and correction; right to limit direct-marketing processing; complaints to the JPDP. |
| Philippines | Data Privacy Act (RA 10173) | Access, rectification, erasure/blocking, objection, portability; complaints to the National Privacy Commission. |
| Japan | APPI | Right to disclosure, correction, suspension of use, and deletion; complaints to the PPC. Cross-border transfer notices apply where required. |
| South Korea | PIPA | Right to access, correction, deletion, and suspension of processing; complaints to the PIPC. Explicit consent generally required for cross-border transfer and for "sensitive information." |
| Taiwan | Personal Data Protection Act (PDPA) | Right to inquire/review, request copies, supplement/correct, demand cessation of collection/processing/use, and deletion; complaints to the competent authority. |
| Hong Kong | Personal Data (Privacy) Ordinance (PDPO) | Right to access and correction; complaints to the Office of the Privacy Commissioner for Personal Data (PCPD). |
| India | DPDP Act (2023) | Access, correction, erasure, grievance redress, right to nominate; complaints to the Data Protection Board of India; verifiable parental consent for children. |
| Canada / Australia | PIPEDA / Privacy Act 1988 | Access, correction, and withdrawal of consent; complaints to the OPC (Canada) / OAIC (Australia). |
This table is illustrative and non-exhaustive; if your jurisdiction is not listed and grants rights not otherwise described in this Policy, contact [email protected] and we will honor applicable rights.
12. Cookies and tracking
See our Cookie Policy. On first visit, you can accept or decline optional (analytics/advertising) cookies; essential cookies are always active. You can change choices anytime via Settings → Privacy & Data → Cookie Preferences or the cookie banner.
13. Third-party links and services
The Service may link to third-party sites/apps not covered by this Policy. Review their privacy notices separately.
14. Changes to this Policy
We may update this Policy. For material changes, we will update the "Last updated" date and notify you (in-product banner, email, or similar) before changes take effect, and — where required by law — ask you to review/accept. Non-material changes take effect when posted.
15. Contact
- Privacy team: [email protected]
- General support: [email protected]
- Safety and abuse: [email protected]
- Legal and regulatory: [email protected]
By creating an account or continuing to use Dramafy, you acknowledge that you have read and understood this Privacy Policy.