Privacy Policy

Last Updated: Feb 26th, 2026

This Privacy Policy (the “Privacy Policy” or “Policy”) describes the types of personal information Scatterlab, Inc. (“Company,” “we,” “us,” or “our”) collects and processes from and about you. Except as described below, the Policy applies to the Zeta AI story platform, including our website, mobile applications, and all related services (collectively, the “Services”), which allow users to freely converse with AI characters.

Undefined capitalized terms used in this Policy have the meaning set forth in zeta Terms of Service.

1. What Personal Information Do We Collect?

When you access or otherwise use our Services, we collect the following personal information from you to process user conversations and provide basic messaging, conversation content, and related services. We also use the collected personal information to identify records of abusive usage and improve AI conversation algorithms:

• Identifiers, such as your name and username (nickname);
• Demographic information, such as your date of birth and gender;
• Phone number, email address, device information (including model name, mobile carrier, OS, device identifier, ADID, time information, etc.), and application information (including version, etc.) (applies when using the mobile app)
• Linked account information (such as identifiers provided by services like SNS for social login functionality)
• Information about messages sent and received (including message send time, message content such as multimedia materials like emojis, stickers, images, videos, and voice messages), information about user reactions, and status information displayed to others
• Users’ service usage records (including records of abusive usage)

Information you provide directly to us might also include information that may be treated as sensitive under applicable laws, such as login credentials, personal communications sent or received using our Services, or other information about yourself that you choose to provide when using our Services (e.g., if you voluntarily include details about your race, religion, or sexual orientation in your user content). Sensitive personal information is not required or necessary to use the Services – please do not include any sensitive personal information in your interactions with us or the Services.

We collect information through the following methods:

• SNS and other sources for providing linked services
• Your direct input during the membership registration process
• Your voluntary provision of information during your use of the Services
• Automatically generated information during your use of the Services

Please note that we need certain types of personal information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services.

1. How Do We Use the Personal Information We Collect?

We use your information for the following purposes:

• To provide, administer, and operate the Services, including our AI character conversation services and our business (e.g., providing core functionality that analyzes user input to generate appropriate responses and personalized digital content);
• To improve the conversation algorithms for our AI character conversation services (e.g. utilizing conversation data exchanged by users, including text, audio, video, and all associated metadata). For this purpose, we use information to identify users, link your accounts from other services or accounts created through such services, and provide other content and supplementary services.
• To analyze user activity (e.g., error logs, abusive usage patterns) or conduct user surveys and interviews to enhance the user experience and improve the Services
• To identify and authenticate your account for the provision, maintenance, and management of services and membership status, etc.
• To develop new services and features (e.g. researching and developing AI technologies, including AI chatbot algorithm development, for new service creation)
• To generate and analyze inferences about the use of the Services, such as statistical tracking of your preferences, interests, and trends about our Services (e.g., how frequently users access the Services, how users navigate the Services, and what our users like or do not like)
• To utilize for marketing and advertising (e.g. providing tailored services, placing ads based on users’ statistical characteristics, verifying service effectiveness, and providing event and promotional information along with participation opportunities).
• To communicate with you about features or aspects of the Services we believe might be of interest to you;
• To communicate with you about changes to our terms, conditions, or policies; or to respond to your inquiries, comments, feedback, or questions;
• To process payments;
• To detect and prevent fraud, criminal activity, or misuse of our Service, and to maintain the security of our IT systems, architecture, assets, customers, and networks; and
• To comply with legal obligations and legal processes and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other parties, including to enforce our Terms of Service and any other agreements or policies.

1. How Do We Disclose the Personal Information We Collect?

We use your personal information only within the scope disclosed in the above section. We do not use such information beyond this scope without your prior consent and, as a general rule, do not disclose your personal information to external parties.

However, we may disclose personal information to third parties with your consent or in any of the following circumstances:

• Vendors and Service Providers. We disclose information to employees, consultants, service providers, and other vendors who need access to such information to carry out work or perform services on our behalf. This includes providers of infrastructure management for the provision and analysis of the Services, data processing for service improvement, research and development (R&D) for service improvement, data storage, payment processing, technology support and services, customer service, analytics, fraud prevention, content moderation, legal services, and marketing and advertising services.
• Safety and Protection of Scatterlab, Inc. and Others. We may disclose certain information if we believe in good faith that it is necessary or appropriate to (i) protect or defend Scatterlab, Inc. or other parties, including to defend or enforce this Policy, our Terms of Service, or other policies and agreements; and/or (ii) protect the rights, property, or personal safety of Scatterlab, Inc., our agents, employees, users, and/or the public.
• Marketing, Advertising and Analytics. We may disclose personal information to advertising and analytics providers to deliver tailored advertising, monitor ad performance, provide analytics services, and help improve our Services. These entities may use cookies and other tracking technologies to allow us to, among other things, track and analyze data, determine the popularity of certain content, deliver tailored advertising and content, and better understand your online activity. For more information about how we use cookies and tracking technologies, please see our Cookie Policy.
• Your Content. Certain actions you take may make your content available to others, including the public. For example, if you create and share “public” Characters, we may make that content available and visible to others.
• Legal Requirements. We may disclose certain information if we believe in good faith that doing so is necessary or appropriate to comply with a law enforcement, legal, or regulatory process, such as a warrant, subpoena, or court order, or other applicable laws and regulations.
• Business Transfers. We may disclose certain information, in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Other Disclosures with Consent or at Your Direction. We nay make additional disclosures of your personal information to third parties when you direct us to do so. For example, where you direct us to disclose information about you when you refer us or our Services to your friends or other acquaintances.

1. Privacy Rights and Choices

We offer you certain choices regarding the collection, use, and disclosure of your personal information.

Profile information. You may delete your account through your account profile page. You may also verify, correct, update, or delete certain information through the same page.

Marketing communications. You can unsubscribe from marketing emails by following the directions in those emails or by emailing privacy@scatterlab.co.kr. Please note that if you unsubscribe from marketing emails, we may still send you administrative emails regarding the Services, including, for example, notices of updates to our Terms of Service or this Policy.

Cookies. Depending on where you live and the options available on your device or browser, you may have the ability to manage cookies in use. For more information, please refer to our Cookie Policy.

Rights to information about you. Depending on where you live and subject to applicable exceptions under local law, you may have the following rights:

• To request information about our processing of your personal information;
• To request access to and/or a copy of certain information we hold about you (including in a portable and/or machine-readable format);
• To opt out of sales of personal information or targeted advertising;
• To update or correct your personal information;
• To request that we delete certain personal information we hold about you;
• To withdraw consent for the processing of your personal information, when under applicable laws you had previously provided consent; and
• The right not to be discriminated against for exercising your rights.

Please note that certain information may be exempt from such requests under applicable law. For example, we may need to retain certain information for legal compliance or to secure our Services. We may need certain information in order to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services.

If you would like information regarding your rights or would like to exercise any rights you may have under applicable law, please email us at privacy@scatterlab.co.kr. To protect your privacy and security, we take reasonable steps to verify your identity and requests before granting such requests. If we are unable to verify your identity, we may be unable to respond to your requests.

1. Regional Privacy Disclosures

Depending on where you live, you may have specific rights or there may be certain information we need to make available to you. If you live in the United States, please refer to our Regional Privacy Disclosures for additional information that may be relevant to you.

1. Children’s Privacy

The Services are not designed for minors under 13.

1. Data Retention

In General. We keep your information for the time necessary for the purposes for which it is processed or as otherwise described at the time the personal information is collected, unless a shorter retention period is required by law. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Popular Characters. If a Character you create has been made available to other users, then we reserve the right to preserve that Character’s characteristics and to keep that Character active on the Services, even if you otherwise delete your data and your account. We do this to avoid impacting the experience of other users. To ensure that we do not retain information about you when this occurs, please avoid submitting any such information as part of the Character creation flow if you are creating a Character that you plan to make available to others.

1. Links to Third Party Websites

The Services may contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information by third parties will be subject to the privacy policies of the third-party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third parties before providing information to them.

1. Changes to this Policy

We may update this Policy from time to time. We will update the “Last Updated” date to indicate the date of the most recent changes. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements such as by prominent posting on our website or mobile application. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.

1. Contact Us

If you have any questions about our Privacy Policy or information practices, please visit our Customer Center at https://support.zeta-ai.io/ or email us at privacy@scatterlab.co.kr.

Scatterlab, Inc.

125 Wangsimni-ro, Seongdong-gu, Seoul, Rooms 901 and 902 (Seongsu-dong 1-ga, KD Tower), Korea, Republic of