Privacy Policy

1. Who We Are

Zoli (application) is owned and operated by Way Enterprises, which is a trading name of Gue Holdings Ltd. Gue Holdings Ltd is a company registered in England and Wales.

Registered address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Contact: admin@guemw.com

2. What This Policy Covers

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use Zoli (available at zoli.uk and any associated mobile applications). We are committed to complying with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), the Data Protection Act 2018, and applicable US state privacy laws including the California Consumer Privacy Act (CCPA).

3. Data We Collect

We collect the following categories of personal data:

Device ID — a unique identifier assigned to your device. Used for ad attribution.
Purchases — details of any subscription or payment made through the platform. We use RevenueCat to process these payments and never see any card details/sensitive info.
Usage data — lesson progress, XP, streaks, quiz results, and in-app interactions.
Crash and diagnostic data — anonymised technical information to help us identify and fix errors.

4. How We Use Your Data

We use your data for the following purposes:

To create and manage your account.
To deliver and personalise the Zoli learning experience (lessons, streaks, XP, progress tracking).
To process payments and manage your subscription.
To send you service-related communications (e.g. account confirmations, billing updates).
To improve the platform through aggregated usage analytics.
To diagnose and fix technical issues.

Our legal bases for processing under UK GDPR are:

Contract performance — to provide the service you have signed up for.
Legitimate interests — to improve and maintain the platform.
Legal obligation — where required by applicable law.

5. Third-Party Services

We use the following third-party services which may process your data:

Payment processor (RevenueCat) — to handle subscription billing. These providers receive payment and billing data and operate under their own privacy policies.
Hosting and infrastructure providers — to run the Zoli platform. Data is stored on servers within the UK or EEA, or with providers that implement appropriate safeguards.

We do not sell, rent, or share your personal data with any third party for their own marketing purposes.

6. Data Retention

We retain your personal data for as long as your account is active. If you request deletion of your account, we will delete or anonymise your personal data within 30 days, except where we are required to retain it by law (e.g. financial records for HMRC purposes, typically 6 years).

7. International Data Transfers

Where third-party providers process data outside the UK or EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO). Please refer to the privacy policies of our third-party providers for details.

8. Your Rights Under UK GDPR

As a UK resident, you have the following rights:

Right of access — request a copy of the personal data we hold about you.
Right to rectification — ask us to correct inaccurate or incomplete data.
Right to erasure — ask us to delete your personal data.
Right to restriction — ask us to limit how we process your data.
Right to object — object to processing based on legitimate interests.
Right to data portability — receive your data in a structured, machine-readable format.

To exercise any of these rights, contact us at admin@guemw.com. We will respond within 30 days.

You also have the right to lodge a complaint with the ICO at ico.org.uk.

9. US Privacy Rights (CCPA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

Right to know — request disclosure of the categories and specific pieces of personal data we have collected about you.
Right to delete — request deletion of your personal data, subject to certain exceptions.
Right to opt-out of sale — we do not sell your personal data.
Right to non-discrimination — we will not discriminate against you for exercising your CCPA rights.

To exercise your rights, contact us at admin@guemw.com. We will respond within 45 days.

10. Cookies

Zoli may use essential cookies and similar technologies to keep you logged in and maintain your session. We do not use third-party advertising cookies. If we introduce non-essential cookies in future, we will update this policy and seek your consent where required.

11. Children

Zoli is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data, please contact us at admin@guemw.com and we will delete it promptly.

12. Security

We take reasonable technical and organisational measures to protect your personal data, including encrypted connections (HTTPS/TLS) and access controls. No method of internet transmission is 100% secure, and we cannot guarantee absolute security.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via the platform or by email. Your continued use of Zoli after changes are posted constitutes acceptance of the revised policy.

14. Contact

For any questions or concerns about this Privacy Policy:

Gue Holdings Ltd
Email: admin@guemw.com