Privacy notice

Version 2026-09-29b, effective 2026-09-29

This document has not yet been reviewed by a lawyer. It describes how ZenOS actually works today; the provider's full registered details will be added before paid plans open.

Who is responsible for your data

The company that operates ZenOS is the controller for the account and billing information you give us directly, and the processor for the data you choose to put into your workspace — the same split our data processing agreement sets out in binding terms. Its registered name and address are published on the Legal notice page before paid plans open; until then, our Legal notice page says so plainly. This page is the plain-words explanation; the data processing agreement is the legally binding one.

We do not need to appoint a data protection officer: we are not a public authority, and our core activities are neither large-scale, regular and systematic monitoring of people nor large-scale processing of special categories of data or data about criminal offences — the tests the General Data Protection Regulation (Article 37) sets for when one is required. Any question a data protection officer would answer goes to us through the channels below.

How to contact us

For any question about this notice, or to exercise any of the rights below, use our contact form and choose privacy request as the topic, or write to hello@zen-os.net. A contract question goes the same way until the registered details on the Legal notice page are published.

What we actually process

Running your agents means we hold a few different kinds of information about your business, always inside your own workspace:

• Business facts you give us directly — your company name, country, VAT number, billing details, working hours and similar settings, entered once during setup.
• How you want things written — your preferred tone, language and a short style note, used only to shape the wording an agent produces, never to change what it is allowed to do.
• Documents you upload — project notes, timesheets and similar internal material you choose to give an agent so it has something real to work from.
• What your agents did, and why — every proposal, every approval or rejection, and a record of the exact instructions and knowledge behind each one. Our internal audit trail stores pointers to that record, not a second copy of its content — removing the content later does not remove the trail of what was decided.
• Connections to your other tools — a pointer to where an access token for a tool you connect is kept, never the token itself, inside our records or in a log.

What you have to give us, and where the rest comes from

Providing account data is necessary to enter into the contract; if you do not provide it we cannot open your workspace. No law requires you to give it to us. Where personal data reaches us inside documents you upload or connections you authorise, the source is you, and you are the controller for it.

Our lawful basis for processing it

Where you are the data subject (your own account and billing details): we process it to perform our contract with you, and to meet our own legal obligations — for example, tax and accounting records.

Where the data belongs to someone else — your staff, or your clients' staff, named in documents you upload or in agent output — we process it on your instructions, as your processor, under the data processing agreement. You are responsible for having your own lawful basis (typically your contract with your client, or your own legitimate interest as an employer) for putting that data into the product in the first place; we do not independently establish or verify it, and you must not upload data you do not have the right to share with us for this purpose.

We do not rely on consent as a lawful basis for any of the processing described here.

Two kinds of action — looking up someone who has never contacted you, and sending them a first-contact message — carry an extra, stricter lawful-basis requirement of their own, described on our acceptable use page, which also says whether either is available today. Whenever either is, a person approves every lookup and every first-contact message before it happens, permanently, with no plan or setting that changes it.

Automated decisions

An agent's output is never treated as a final decision about you or anyone else on its own. Every action that would change something outside your workspace — sending a message, issuing an invoice, publishing a post, and every other kind of action this product recognises — is a proposal only, and a deterministic set of rules, or a person, decides whether it proceeds. We do not use profiling or automated decision-making that produces legal or similarly significant effects about a data subject without a person in the loop.

Where it is processed

Your workspace data is stored in Frankfurt, Germany — a named country location, not a general “Europe” region that could quietly move your data somewhere else. Some steps are carried out by outside companies. This is where each one happens, as our Sub-processors page records it:

• Storing your workspace data: Supabase, in Frankfurt, Germany. Its own support staff may reach your data from the United States or Singapore, under the standard contractual clauses described below.
• Running the website, the dashboard and the console our own staff use: Vercel, in Frankfurt, Germany, for the application itself. Static files are served from Vercel's global network, and Vercel may process data in the United States.
• Running the background workers that carry out agent runs: Fly.io, in Frankfurt, Germany.
• Running the language models: the United States. Every model request goes through OpenRouter, in the United States, which passes it to the company that runs the model. The models we use by default are Anthropic's, and Anthropic processes in the United States.
• Turning your documents into a form we can search by meaning: Voyage AI, in the United States. It does not publish which region.
• Connecting the tools you link: Composio, in the United States.
• Taking payment: Stripe, in Ireland, with processing also in the United States.

Google, LinkedIn Corporation and Meta Platforms work differently. When you connect your own account at one of them, that company acts as an independent controller of that account, not as our processor, under its own terms with you. The Sub-processors page lists them separately for that reason.

What the outside companies' own terms say about your data

We do not claim more about a company than its own terms and our own records show. Two points matter most.

• Model requests. We send every request to OpenRouter with an instruction to use only model companies that do not collect or train on request data. We have not switched on zero data retention, so we do not say that requests are not kept. Anthropic's own terms say it deletes inputs and outputs within 30 days and does not train on data sent through its API by default.
• Documents you upload. Voyage AI's terms allow it to train on the content sent to it unless the account opts out. We have not yet confirmed that our account has opted out, so do not assume it has. Until we confirm it, take that into account before you upload a document; this notice and the Sub-processors page will say so when we have.

Agreements that are not in force yet. For Composio and Fly.io, the data processing agreement has to be accepted in the company's own dashboard, and we have not done that yet. Until we do, no agreement covers that company. The Sub-processors page shows the state of every agreement, company by company.

International transfers

Some of these companies process data outside the European Economic Area. Two things make such a transfer lawful. The standard contractual clauses are standard promises, written by the European Commission, that a company outside the European Union signs so data can lawfully be sent to it. The EU–US Data Privacy Framework is a scheme under which a company in the United States certifies that it protects European data, and the European Commission accepts certified companies as a lawful destination.

• Model requests go to OpenRouter and Anthropic, in the United States, under the standard contractual clauses. Neither is on the Data Privacy Framework list.
• Voyage AI, in the United States, is covered by the standard contractual clauses, and by the Data Privacy Framework certification of MongoDB, Inc.
• Supabase's support access from the United States or Singapore is under the standard contractual clauses. Supabase is not on the Data Privacy Framework list.
• Vercel is covered by the Data Privacy Framework and by the standard contractual clauses. Stripe relies on the Data Privacy Framework first, and on the standard contractual clauses after that.
• Fly.io has an active Data Privacy Framework certification and no standard contractual clauses in place, because its agreement is not in force yet. Composio, in the United States, has no transfer mechanism in place until its agreement is accepted.

The Sub-processors page shows the mechanism, and whether the agreement is in force, for each company.

How long we keep it

While your workspace is open, how long we keep the content behind an agent run depends on your plan. These figures are read from the same plan records the product uses:

• Free — 7 days for the content behind an agent run.
• Pro — 90 days for the content behind an agent run.
• Max — 180 days for the content behind an agent run.
• Ultra — 365 days for the content behind an agent run.
• Own key — 90 days for the content behind an agent run.

The record of decisions — who decided what, when and on what basis — is kept for the life of the workspace and for 12 months after it is closed, as our record that the audit trail was not altered. It contains no document contents. Everything else in your workspace is deleted within 30 days of cancellation. The only exception is what the law itself requires us to keep, such as invoices we must keep for tax purposes. Our data processing agreement sets out the same rule.

Cookies

We use only strictly necessary cookies: a sign-in session cookie on the dashboard, and a short-lived cookie on this website that keeps a checkout attempt together. We do not use analytics cookies or advertising cookies, and we do not set anything that tracks you across other sites. Because every cookie we set is strictly necessary to provide the service you asked for, no consent banner is needed.

What we do not do

We do not sell your data. We do not use your data to train any model. That is a statement about what we do; it is not a promise about every company we send data to, which is why the exceptions are stated above. Support staff can see that something happened without special consent, but seeing the actual content of what happened is a separate permission we ask you for, and every support session is time-limited, logged, and can never approve anything on your behalf.

Your rights

You have the right to access the personal data we hold about you, to have inaccurate data corrected, to have it erased, to restrict how we process it, to receive a portable copy of it, and to object to processing we base on our legitimate interest. Erasing content empties the documents we hold, what an agent remembered and the detail of past proposals, while the audit trail of decisions still shows that something happened and when, because that trail was never the content itself.

To exercise any of these, use our contact form and choose privacy request, or write to hello@zen-os.net; we will respond within the period the law requires. If you are not satisfied with our answer, you have the right to complain to the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec Republike Slovenije), https://www.ip-rs.si.

If something goes wrong

If a personal data breach affects data we process for you, we tell you without undue delay after we become aware of it, and in any event in time for you to meet your own 72-hour obligation to report it to your regulator. We tell you what we know, what we are doing about it, and what we recommend you do. If a breach affects the account and billing information we are the controller for, we report it to the Information Commissioner and tell the people affected where the law requires it.

Changes to this notice

We may update this notice from time to time. We will tell you before a material change takes effect.