中文

Tokor Privacy Policy

> Translation notice: This English text is a non-binding translation of the Chinese version. In the event of any discrepancy or ambiguity, the Chinese version controls.

Version: 2026-10-20
Effective Date: October 20, 2026
Provider: ZealTop OÜ ("we", "us")


1. Data Controller

FieldValue
Data Controller (GDPR term)ZealTop OÜ
Registered AddressHarju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551, Estonia
Registry Code17367911
Contact Emailwww.zeal.top@gmail.com
DPO (Data Protection Officer)Not currently designated (current processing does not fall under the cases in GDPR Art.37 that require one)

2. Personal Data We Collect

2.1 Provided by you
TypeScope
Account infoEmail, nickname, avatar URL
Third-party OAuthGoogle-provided email + sub (unique ID); no passwords stored
Profile additionsBio, remarks you fill in
ContentText, images, audio, video, file attachments, knowledge-base content, AI prompts/conversation history you upload
Developer infoIf you register as a developer: your Stripe Connect Express account ID, plus the payout account country, entity type (individual / company), legal name (company name or personal name), and tax ID that you choose during payout setup or that Stripe syncs to us
Location (only if you choose)Location sharing (off by default; turn it on or off in Settings): your device's current location — coordinates rounded to 4 decimal places (about 10 m) plus the city / region / country derived from them — is attached to the messages you send in conversations with AI assistants. Sending a location: the place you pick in a chat (coordinates, name, address) is sent as a chat message

Location shared automatically is passed to the assistant's model for that reply only and is not saved in your chat history. A location you send as a message is stored like any other message and is visible to the members of that conversation. To turn coordinates into a city or address, and to show and search the map, your device contacts the location services listed in §5 directly.

2.2 Collected automatically
TypeScope
Device/clientUser-Agent, device ID, browser version
LogsIP, login times, accessed URLs, error logs
UsageBrowsing history, AI Token consumption, voice transcription duration, web-search and tool-call counts, subscription records
Payment eventsStripe order ID, amount, currency, payment time (Stripe stores card data; we only store order metadata)
2.3 We do NOT collect
  • Credit card numbers / CVV (handled by Stripe; we never see them)
  • Biometric / health / political affiliation or other GDPR special categories

3. Lawful Basis (GDPR Art.6)

PurposeLegal Basis
Service provision, order fulfillmentArt.6(1)(b) Contract necessity
Account security, anti-fraudArt.6(1)(f) Legitimate interest
Customer supportArt.6(1)(b) Contract necessity
Location sharing (optional)Art.6(1)(a) Consent (turn it off in Settings at any time)
Marketing emails (not currently sent; consent will be asked separately before any are sent)Art.6(1)(a) Consent (revocable)
Legal obligations (tax, KYC)Art.6(1)(c) Legal obligation
Severe violation / regulatory referralArt.6(1)(c) + (e) Law / public interest

AI content moderation uses OpenAI Moderation API; we transmit only required moderation fields, no identifiable personal data. Voice transcription, web search and AI tool execution are part of the service itself, based on Art.6(1)(b) contractual necessity.

4. Purposes

We use your personal data to:

  • Provide and improve Tokor service
  • Process orders, subscriptions, refunds
  • Ranking of content and products (based on platform-wide signals such as ratings, sales, refund rate and listing age; not currently personalized by your own browsing or purchase history)
  • Security (detect anomalous logins, fraud, abuse)
  • Customer support and dispute handling
  • Compliance review (per laws and regulations)
  • Aggregated business analytics (anonymized)

We will NOT:

  • Sell your personal data
  • Use for unrelated advertising
  • Share with unrelated third parties without your consent

5. Data Sharing and Third Parties

To provide service, we share necessary data with the following categories of third parties:

CategoryThird PartyShared DataPurpose
PaymentsStripe Inc. (US)email, name, order metadata, IPPayment processing, fraud detection, Connect account management
LLM inferenceModel services configured by the model's owner (you, the assistant developer, or another developer whose model the assistant borrows; a commercial API provider, or a server / personal device operated by the developer — see 5.2)Conversation content (anonymized user_id); your location, if you turned on location sharingAI inference (endpoint chosen by the configuring party)
Voice transcriptionGroq Inc. (US, primary), OpenAI (fallback)Voice input audioSpeech-to-text
Web searchTavily Inc. (US)Search query termswebSearch built-in tool
Content moderationOpenAI Inc. (US)Text/image URLs to be moderatedModeration API
Cloud infrastructureGoogle Cloud Platform (primarily Singapore region)All data (encrypted storage)GKE / Cloud SQL / Pub/Sub / Secret Manager / logging
File storage & deliveryCloudflare Inc. (global edge)Files and attachments you upload (R2 object storage), frontend static assetsR2 / Pages / CDN / origin protection
Code executionCloudflare Inc. (Workers)Hosted-tool call inputs and runtime logs (code-execution processor only, no long-term business data storage, see 5.1)Workers for Platforms
Human verificationCloudflare TurnstileDevice and browser signalsAbuse prevention (login / guest entry)
Location lookupBigDataCloud Pty Ltd (Australia, primary), OpenStreetMap Foundation Nominatim (UK, fallback)Coordinates of your device or of the place you pick, place names you search for, your IP address (requested directly from your device)Turning coordinates into a city / address; place search when sending a location
MapsOpenStreetMap Foundation map tile servers (UK)The map area you view, your IP address (requested directly from your device)Showing the map when you send a location
Push notificationsGoogle Firebase (FCM)Device push tokens, notification contentMobile / web push
Email notificationsResend (primary) and other email providersEmail, notification contentSystem notifications
Regulatory / judicialGovernment bodies (per legal requirement)Necessary dataCompliance
5.1 Third-Party Tools and Hosted Tools (developers can see this data)

Assistants may mount tools provided by developers. When you use such an assistant:

  • Data you provide to a tool is stored by and visible to that tool's developer, including tool inputs, rows and files the tool saves for you, and tool runtime logs (console output, kept for 3 days, visible only to the developer) which may contain content you provided.
  • Hosted tools (code run by the platform): the data lives in the platform's database and object storage (GCP / Cloudflare R2), and the code executes on Cloudflare Workers (Cloudflare acts solely as a code-execution processor). You manage this data the same way as with any other tool: through conversation with the assistant, using the operations the tool itself provides (whatever the tool exposes is what you can do); deleting your account removes all rows and files under your name. Files a tool keeps for you count toward your storage quota.
  • In-app pages: a hosted tool may ship a page that opens inside the app (a game, a dashboard, etc.) and runs on your device. Program errors that occur while the page runs (error message and stack trace, with URL parameters removed) are reported automatically to that page's developer for troubleshooting; they sit in the same panel as tool runtime logs and are kept for the same 3 days. Reports never include your conversation or file contents, and the platform caps how many are sent per person per minute and per page per day. What you do in the page still goes through the tool's own operations, so the data ownership described above applies unchanged.
  • Self-hosted tools: the developer's own server is an independent data controller; when calling it the platform passes your input and short-lived signed links to attachments in your message. Subsequent processing is the developer's responsibility — see their own privacy notice.
  • When a tool is deleted or your account is deleted, the corresponding data is cleaned up per the retention schedule in §7.
5.2 Model services used by assistants

We do not operate our own model inference. The model endpoint an assistant uses is supplied by the owner of that model: usually the assistant's developer, or — if the developer has borrowed the model from another developer's assistant — that other developer. Every turn of your conversation with that assistant is sent to that endpoint. The endpoint may be:

  • a commercial API provider (OpenAI / Anthropic / DeepSeek / others), handled under that provider's own privacy terms;
  • a server operated by the developer, in which case that developer is an independent data controller and subsequent processing is their responsibility — see their own privacy notice;
  • a device belonging to the developer (locally hosted model), meaning your conversation content is sent to that developer's own computer.

We do not control how the endpoint stores or uses this content. Model endpoints owned by official platform assistants are configured by ZealTop OÜ; if an official assistant borrows a model or tool from another developer, the corresponding conversation content and tool arguments go directly to that developer, whose endpoint is not configured by ZealTop OÜ.

Which assistant you talk to is your choice; an assistant's detail page lists the models and tools it mounts, who configured each one, and links to each item's owner profile.

6. International Data Transfers

Due to deployment on GCP, Cloudflare and Stripe, some data transfers outside the European Economic Area (EEA):

  • Singapore (GCP asia-southeast1, primary region)
  • United States (Stripe / OpenAI / Groq / Tavily / Resend)
  • Australia (BigDataCloud) and the United Kingdom (OpenStreetMap Foundation), only when you use location features
  • Cloudflare global edge (file delivery and code execution)
  • We use Standard Contractual Clauses (SCCs) as transfer mechanism
  • Stripe / Google / Cloudflare are EU-US Data Privacy Framework certified

If you have concerns about international transfers, please contact us for details.

7. Data Retention

TypeRetention
Account infoAccount lifetime; anonymized when you delete your account
Order / payment records7 years (EE Commercial Code + Tax Act requirement)
Chat history / AI conversationsUntil you delete it, at most for the lifetime of your account (the messages you sent are deleted when you delete your account); the AI reasoning details shown alongside replies are removed after 7 days
Chat attachments / tool-produced files7 days (hard cleanup)
Hosted-tool data (rows and files)For the lifetime of the tool; you can delete yours at any time; reclaimed within 7 days after the tool is deleted
Hosted-tool runtime logs3 days
Usage statistics (token consumption, tool-call counts, etc.)180 days
Logs90 days (rolling)
Violation records180 days (records from the most recent 30 days count toward the automatic-ban threshold)
Agreement acceptance records (which versions you accepted and when)Kept after account deletion as evidence of consent

8. Your Rights (GDPR)

As a data subject, you have the right to:

RightDescriptionHow to Exercise
Access Art.15Get a copy of data we process about youContact support
Rectification Art.16Correct inaccurate dataSettings page / support
Erasure ("right to be forgotten") Art.17Delete your data (subject to legal retention: orders/tax records for 7 years)Settings → Delete Account (self-service)
Restrict processing Art.18Pause certain processingSupport
Data portability Art.20Get structured data export (JSON)Support
Object Art.21Object to legitimate interest processingSupport
Withdraw consent Art.7(3)Applies only to optional consent-based processing (currently: location sharing). The Terms of Service constitute a contract and cannot be unilaterally withdrawn; to terminate the relationship, use Account DeletionLocation sharing: turn it off in Settings; any optional consent-based processing introduced later (e.g., marketing emails) will get its own toggle in Settings
Lodge complaint Art.77File complaint with DPAEstonia Andmekaitse Inspektsioon (AKI)

We commit to responding to reasonable requests within 30 days.

9. Cookies and Similar Technologies

  • Sign-in does not use cookies: the app keeps your sign-in state in your device's local storage
  • Local storage on your device: sign-in state, language / theme and similar preferences, and caches that make the app faster; strictly necessary for the service; you can remove it by clearing the app's or browser's site data
  • Human verification: Cloudflare Turnstile processes device and browser signals to prevent abuse (see §5)
  • Our website: visits are counted in aggregate with Cloudflare Web Analytics, which does not use cookies

We do NOT use: advertising cookies, analytics cookies, cross-site tracking.

If we later introduce any cookie or similar technology that is not strictly necessary, we will ask for your consent first (EU ePrivacy requirement).

10. Minors

The Platform is not directed at users under 18. Accounts found to be minors will be deleted upon confirmation.

Guardians who discover unauthorized registration by a child should contact support for removal.

11. Data Security

We implement industry-standard measures to protect your data:

  • Transit: HTTPS/TLS encryption
  • Storage: GCP encryption; model / tool credentials you configure are stored AES-256-GCM encrypted
  • Access control: principle of least privilege, audit logging
  • Key management: GCP Secret Manager
  • Vulnerabilities: periodic security scans / penetration testing (scaled with business)

However, no system is 100% secure. In the event of a data breach, we will notify regulators and affected users within 72 hours per GDPR Art.33/34.

12. AI and Automated Decisions

The Platform uses AI / algorithms for:

  • Product ranking (based on platform-wide signals; no individual profiling)
  • Content moderation (OpenAI Moderation + keyword blacklist)
  • Risk assessment (cumulative violations auto-trigger ban)

If such decisions have significant impact on you (e.g., account ban), you have the right to:

  • Request human review: for removed content or products, file an appeal in the app; for a banned account, email the appeal address given in the ban notification email (a banned account cannot sign in to the app)
  • Request explanation of decision logic
  • Object to fully automated decisions (GDPR Art.22)

13. Policy Changes

13.1 We may modify this Policy in response to legal changes or business adjustments. Material changes will be communicated via login interception + email.

13.2 The current version of this Policy is always available in the app and on our website. In Settings you can see which versions of the Terms of Service and of this Policy you have accepted, and when.

14. Contact Us

  • Data inquiries: www.zeal.top@gmail.com
  • Estonian DPA complaint: Andmekaitse Inspektsioon
  • EU DPA complaint: Your country's data protection authority

End of Policy