GDPR Addendum (EU/UK Privacy Rights)

Effective Date: January 1, 2026

Last Updated: February 2, 2026

This GDPR Addendum ("Addendum") applies specifically to individuals located in the European Economic Area (EEA), the European Union (EU), and the United Kingdom (UK). It supplements the ZINFI.AI Privacy Policy to comply with the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.

1. Data Controller

ZINFI Technologies, Inc. acts as the Data Controller for the personal data collected through www.zinfi.ai.

2. Legal Bases for Processing

Under GDPR, we process your personal data under the following legal bases:

• Performance of a Contract: Processing is necessary to provide the services defined in our General Terms of Service and Membership Terms.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as improving our collaborative "Best Practices" database and ensuring site security, provided these interests are not overridden by your rights.
• Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., subscribing to a newsletter).
• Legal Obligation: To comply with law enforcement or regulatory requirements.

3. Your Rights as a Data Subject

You have the following rights regarding your personal data:

• Right of Access: The right to request copies of your personal data.
• Right to Rectification: The right to request that we correct any information you believe is inaccurate.
• Right to Erasure ("Right to be Forgotten"): The right to request that we erase your personal data, under certain conditions.
• Right to Restrict Processing: The right to request that we restrict the processing of your personal data.
• Right to Data Portability: The right to request that we transfer the data that we have collected to another organization, or directly to you.
• Right to Object: The right to object to our processing of your personal data, especially for direct marketing.

4. International Data Transfers

Personal data collected by ZINFI is stored and processed in the United States. To ensure your data receives an adequate level of protection, we utilize Standard Contractual Clauses (SCCs) approved by the European Commission for the transfer of personal data outside the EEA.

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

6. Complaints

You have the right to lodge a complaint with a supervisory authority in your member state if you believe our processing of your personal data violates GDPR.

7. Contact

For all GDPR-related inquiries, please contact our Data Protection Officer: