Zerno — Privacy Policy

Operator: COPER LLP, Republic of Kazakhstan Effective date: June 12, 2026 Version: 2.2 Contact: info@coper.kz

This Privacy Policy ("Policy") describes how COPER LLP ("we", "us", the "Company") collects, uses, stores, and protects information from users of the Zerno application (the "App"). By using the App, you agree to this Policy. If you do not agree, do not use the App. This Policy takes into account the data-protection laws of the Republic of Kazakhstan, the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA), to the extent they apply to you.

1. Who we are

The data controller is COPER LLP, registered in the Republic of Kazakhstan. For any question regarding the processing of personal data or the exercise of your rights, contact us at info@coper.kz.

2. Data we collect

2.1. Account data. When you register through Apple ID or a Google account, we receive your email address and an account identifier. We do not receive or store passwords.

2.2. Content you create.

Voice recordings. Your speech is converted into text using speech recognition. For languages supported by Apple's on-device speech recognition, transcription is performed locally on your device and the audio is not transmitted to us or to any third party. For languages that Apple's on-device recognition does not support (currently including Russian), the audio is securely transmitted to OpenAI (Whisper) for the sole purpose of transcription. In either case, we do not store audio files: audio is used only to produce the text and is not retained on our servers.
Transcripts and note text. Text obtained from your recordings or typed manually, together with the projects, tags, and attachments you create.
Attachments. Files, images, and other materials you add to notes.

2.3. Usage data. We collect anonymized usage statistics and crash data through Firebase and Amplitude to improve the product. This includes information about in-app actions, device type, operating-system version, and general activity metrics. This data is not used to identify you personally.

2.4. Subscription data. Subscriptions are processed through Apple In-App Purchase. Payments are handled by Apple. We do not receive or store your payment-card details. From Apple we receive only your subscription status (active, expired, canceled).

2.5. Microphone access. The App requests microphone access solely to record speech for the purpose of converting it into text. No recording occurs without your permission, which you can revoke at any time in your device settings.

2.6. What we send and do NOT send to third-party services.

We send to third-party services (see Section 5): (a) for transcription of languages not supported by on-device recognition, the audio recording — to OpenAI (Whisper), solely to convert it into text; and (b) the resulting note text — to Groq, Inc. for analysis, structuring, chat features, and generation of summaries.
We do NOT send to third-party AI services: your payment-card data, passwords, or your email and account identifier as part of note content. Where on-device recognition is available for your language, audio is not transmitted off your device at all.

3. How we use data

To provide the core functions of the App — converting speech into structured text, organizing it into projects, and generating AI-powered analysis, summaries, and chat responses based on your notes.
To operate your account and sync data across sessions and devices.
To verify subscription status and grant access to paid features.
To improve the quality, stability, and usability of the App.
To provide customer support.
To comply with applicable law.

If you are located in the European Economic Area, we process your data on the following bases:

Performance of a contract — providing the App features you registered for.
Your consent — for example, granting microphone access or enabling AI features. Consent for AI processing is requested in the App before any data is first sent to a third-party AI service, and can be withdrawn at any time in the App's Settings.
Legitimate interest — improving the App and anonymized analytics.
Legal obligations — compliance with the law.

To operate the App we use third-party services. Each receives only the data necessary for its function.

Apple (on-device Speech framework) — for supported languages, speech-to-text transcription is performed locally on your device. No audio is transmitted to Apple's servers or to us for this purpose.
OpenAI — speech-to-text transcription (Whisper) for languages not supported by on-device recognition (currently including Russian). The audio is transmitted solely to produce the text. By default, OpenAI does not use data submitted via its API to train its models and retains it only for a limited period for abuse monitoring before deletion. Policy: https://openai.com/policies/privacy-policy/ · API data handling: https://openai.com/enterprise-privacy/
Groq, Inc. — processing of note text (analysis, structuring, chat, and summaries). Groq does not use data submitted via its API to train or fine-tune models. Inference requests are not retained by default; limited temporary logs may be kept by Groq for up to 30 days solely for troubleshooting or abuse investigation. Policy: https://groq.com/privacy-policy · Data handling: https://console.groq.com/docs/your-data
Apple — authentication (Sign in with Apple) and subscription payment processing. Policy: https://www.apple.com/legal/privacy/
Google — authentication via Google account. Policy: https://policies.google.com/privacy
Firebase (Google) — crash monitoring and analytics. Policy: https://firebase.google.com/support/privacy
Amplitude — anonymized product analytics. Policy: https://amplitude.com/privacy
Cloud infrastructure provider — storage of your account data and notes.

We require our providers to protect your data to a standard no lower than that required by applicable law. We do not sell your personal data and do not share it with third parties for advertising purposes.

6. Data retention

We do not store audio files (see Section 2.2). Where audio is sent to OpenAI for transcription, it is transmitted transiently for that purpose only and is not stored by us; OpenAI's retention is governed by its own policy (a limited retention period for abuse monitoring, after which it is deleted).
Note text sent to Groq for processing is not retained by Groq by default; any limited temporary logs are governed by Groq's own policy (see Section 5).
Transcripts, note text, projects, and related data are kept while your account exists, or until you delete them.
After account deletion, associated data is permanently deleted within 30 days, except data we are required to retain by law.
Data tied to contractual and accounting obligations (e.g., subscription status) is retained for the period required by applicable law.

7. Account deletion

You can delete your account and all associated data directly in the App, under Settings → Account → Delete account. Deletion is permanent (not a temporary deactivation) and is initiated within the App. If you registered through Apple ID, we also revoke the associated access tokens upon deletion. You may also request deletion by writing to info@coper.kz.

8. International data transfers

The servers that process and store data, as well as the servers of the third-party services we use (including OpenAI for transcription of unsupported languages and Groq for note-text processing, both located in the United States), may be located outside the Republic of Kazakhstan and the European Economic Area. For cross-border transfers outside the EEA, we ensure a comparable level of protection, including through Standard Contractual Clauses approved by the European Commission. By using the App, you consent to such cross-border transfer and processing.

9. Security

We apply reasonable technical and organizational measures to protect your data, including encryption in transit (HTTPS/TLS) and access controls. However, no method of transmission or storage can be guaranteed 100% secure.

10. Your rights

Depending on your jurisdiction, you have the right to:

access the data we hold about you and obtain a copy;
correct inaccurate data;
delete your account and associated data;
restrict or object to processing;
receive your data in a structured, machine-readable format (portability);
withdraw previously given consent at any time.

For California residents (CCPA): you have the right to know what personal data we collect, request its deletion, and opt out of its sale (we do not sell personal data).

To exercise these rights, write to info@coper.kz — we will respond within one month. You can also delete your account yourself (see Section 7).

11. Tracking and advertising

The App does not use the advertising identifier (IDFA) and does not track your activity across other companies' apps and websites for advertising. We do not display ads and do not sell your data. The analytics described in Section 2.3 are anonymized and used only to improve the product.

12. Children's privacy

The App is not intended for children under 13 (or under 16 in the European Economic Area), and we do not knowingly collect their personal data. If you become aware that a child has provided us with personal data, contact info@coper.kz and we will delete it.

13. Changes to this Policy

We may update this Policy from time to time. We will notify you of material changes within the App or by other available means. Continued use of the App after changes take effect constitutes acceptance of the updated Policy.

14. Contact

COPER LLP, Republic of Kazakhstan — info@coper.kz