ZELUN COMPREHENSIVE PRIVACY NOTICE

Last Updated: October 16, 2026

1. Identity and Address of the Data Controller

ZELUN TECHNOLOGIES, S.A.S., referred to in this Privacy Notice as “Zelun,” “we,” “us,” or “our,” with registered address at:

Avenida México 2582, Torre 200, Interior 10E

Colonia Ladrón de Guevara

Guadalajara, Jalisco 44600

Mexico

is responsible for personal data that it collects directly through its websites, mobile applications, web applications, platforms, products, integrations, communication channels and other related services, collectively the “Services.”

For privacy and personal data matters, you may contact us at:

privacy@releasetwin.com

This Privacy Notice is intended to comply with Mexico's Federal Law on the Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares) and other applicable privacy laws.

2. Scope

This Privacy Notice applies to personal data that Zelun obtains directly from, among others:

When a business uses Zelun to store or process personal data relating to its own customers, employees, contractors, vendors or other individuals, that business generally determines the essential purposes and means of processing and acts as the controller of such data.

In those cases, Zelun generally acts as a processor/service provider, processing information on behalf of and according to the instructions of the business pursuant to our agreement and applicable Data Processing Agreement.

Requests relating to data controlled by a business using Zelun should generally first be submitted to that business.

3. Personal Data We May Process

Depending on how you interact with Zelun, we may process the following categories of personal data.

3.1 Identification and Contact Information

This may include:

3.2 Account and Authentication Information

This may include:

Passwords should be stored using appropriate technical protection mechanisms rather than in plain text.

3.3 Business and Professional Information

This may include information relating to:

3.4 Tax and Billing Information

Where necessary, we may process:

3.5 Payment-Related Information

We may process:

Where payment information is processed directly by specialized payment providers, Zelun may not receive or store full card numbers, security codes or complete financial credentials.

3.6 Technical and Device Information

This may include:

3.7 Service Usage Information

This may include information relating to:

3.8 Communications and Support

This may include:

4. Data Processed on Behalf of Businesses Using Zelun

Businesses using Zelun may enter information relating to their own customers, employees, contractors and vendors.

Depending on the features used, this information may include:

For this data, the business using Zelun is generally responsible for providing applicable privacy notices, obtaining required consent and establishing another appropriate lawful basis where necessary.

Zelun processes such data pursuant to the documented instructions of the business, our agreement with that business, the applicable Data Processing Agreement and applicable law.

5. Sensitive Personal Data

Zelun does not generally request users to provide sensitive personal data.

Businesses should avoid storing sensitive personal data unless:

Sensitive personal data may include information concerning:

If Zelun directly collects sensitive personal data for which consent is legally required, we will obtain the applicable express consent prior to processing.

6. Primary Purposes of Processing

Zelun may process personal data for purposes necessary to provide and operate the Services, including to:

These purposes are necessary to establish, maintain and administer the relationship with Zelun.

7. Secondary Purposes

Where permitted, we may process certain information for additional purposes, including to:

These purposes are not necessary in order to use Zelun's core functionality.

You may request that your information not be used for promotional or marketing purposes by contacting:

privacy@releasetwin.com

You may also use the unsubscribe mechanism included in our marketing communications.

Refusing secondary purposes will not prevent you from using contracted Zelun functionality.

8. Artificial Intelligence and Automated Systems

Certain Zelun features may use artificial intelligence, machine learning or other automated systems to:

Automatically generated output may contain errors and should not be treated as legal, tax, financial, medical or other professional advice.

Where Zelun uses information to improve general systems or proprietary models, we seek to use aggregated or appropriately de-identified information where reasonably practicable.

Zelun will not use sensitive personal information for general training of proprietary models without an appropriate legal basis and any legally required consent.

9. Processors, Service Providers and Subprocessors

Zelun may engage third-party service providers to operate the Services.

These providers may support areas such as:

Where these providers process personal data on behalf of Zelun, they are required to process the information subject to contractual and confidentiality obligations appropriate to the nature of their services.

10. Domestic and International Data Transfers

Zelun may transfer personal data to third parties in Mexico or other countries where necessary to:

Where applicable law permits a transfer without the individual's consent, the transfer may be made pursuant to the applicable legal exception.

Where a transfer legally requires consent, Zelun will request such consent through an appropriate mechanism.

Service providers acting solely as Zelun's processors or subprocessors are not thereby authorized to use personal data for unrelated purposes of their own.

11. Processing Outside Mexico

Zelun provides cloud-based technology services and may use service providers located or operating infrastructure outside Mexico.

As a result, certain information may be processed or stored in other countries.

Where applicable, Zelun will implement reasonable contractual, organizational and technical safeguards designed to protect information during such processing.

12. Data Retention

Zelun retains personal data only for as long as reasonably necessary to:

Terminated Accounts

When a customer terminates or cancels its Zelun account, Customer Data will generally remain available for export for 60 days following termination.

Certain operational functionality may be restricted or disabled during that period.

After the 60-day period, Zelun may delete Customer Data from active production systems.

Certain information may be retained for a longer period:

Information contained in backups will be deleted according to Zelun's normal backup overwrite and retention cycles.

13. Information Security

Zelun implements reasonable administrative, technical and physical safeguards designed to protect personal data against:

Depending on the circumstances, these safeguards may include:

No Internet-connected system can guarantee absolute security.

If a security breach significantly affects individuals' property or moral rights, Zelun will provide notifications as required by applicable law.

14. Privacy and ARCO Rights

Individuals may exercise the Mexican rights of Access, Rectification, Cancellation and Objection (ARCO).

Access

You may request information regarding personal data we hold about you and the general conditions under which it is processed.

Rectification

You may request correction of inaccurate, incomplete or outdated personal information.

Cancellation

You may request cancellation of personal information where legally appropriate.

Cancellation may result in a blocking period during which the information is retained solely for purposes of potential legal or contractual liability.

Objection

You may object to certain processing in the circumstances provided by applicable law.

To exercise an ARCO right, contact:

privacy@releasetwin.com

Your request should include at least:

For rectification requests, you should also identify the requested correction and provide documentation supporting it.

Zelun will respond within the time periods established under applicable law.

15. Withdrawal of Consent

Where processing is based on your consent, you may request withdrawal of that consent by contacting:

privacy@releasetwin.com

Withdrawal:

16. Limiting Use or Disclosure

You may request that Zelun limit certain uses or disclosures of your personal information by contacting:

privacy@releasetwin.com

For marketing communications, you may also use the unsubscribe mechanism contained in the relevant message.

17. Cookies and Similar Technologies

Our websites and applications may use cookies, local storage and similar technologies to:

Where applicable law requires consent for particular categories of cookies or technologies, Zelun will provide an appropriate consent mechanism.

18. Children

Zelun is primarily intended for businesses and individuals who have legal capacity to enter into contracts.

Zelun does not seek to directly collect children's personal information for purposes of creating business accounts.

Businesses using Zelun are responsible for complying with applicable law when they enter information relating to minors into their own accounts, including obtaining any required consent.

19. Requests Regarding Data Controlled by Our Customers

If you are an end customer, employee or contractor of a business using Zelun and wish to exercise rights relating to information that business maintains through Zelun, you should generally contact that business first.

Where appropriate, Zelun will provide reasonable assistance to the business in responding to the request pursuant to the applicable Data Processing Agreement.

20. Corporate Transactions

In connection with a merger, acquisition, restructuring, financing, sale of assets or similar corporate transaction, certain personal data may form part of the transaction to the extent permitted by applicable law.

Any subsequent processing remains subject to applicable privacy obligations and restrictions.

21. Changes to This Privacy Notice

Zelun may update this Privacy Notice as a result of:

The current version will be available at:

https://zelun.io/en/privacy/2026-10-16

Where changes are material, we may provide notice through:

The date shown at the beginning of this Notice identifies the current version.

22. Privacy Contact

For privacy questions, requests or personal data matters:

ZELUN TECHNOLOGIES, S.A.S.

Registered address:

Avenida México 2582, Torre 200, Interior 10E

Colonia Ladrón de Guevara

Guadalajara, Jalisco 44600

Mexico

Privacy email:

privacy@releasetwin.com

Website:

https://zelun.io

Leer esta versión en español

Zelun Privacy Notice (2026-10-16)