Privacy Policy

Last updated: August 21, 2025

1. Policy Statement

Zailo Health Ltd ("Zailo", "we", "our", "us") is committed to protecting and respecting your privacy. Zailo app (iOS & Android) (the "App") is operated by Zailo as a Digital Therapeutic as a Service (DTaaS), incorporating evidence-based Couples Behavioural Therapy (CBT) and Family-Based Interventions (FBI) to support families and loved ones in addiction recovery journeys.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our services, including our digital therapeutics application ("the App"), website, and related services.

We are the "data controller" of your personal information under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

If a user registers for Zailo products and services, CyberLiver® will act as the data controller for any personal data collected, with Zailo acting as the data processor and service provider.

2. Important Information and Who We Are

Service Provider Contact Details

Changes to the Privacy Policy

We keep this Privacy Policy under regular review. We will post any changes to this Privacy Policy on this page. If the changes are significant, we will provide more prominent notice by sending you a notification in the App.

Information About Children

The Zailo app is not intended for or targeted at children under 18. We do not knowingly or intentionally collect information about children under 18. If you believe we have collected information about a child under 18, please contact us at digital@zailo.co.uk so we may delete the information.

3. Information We Collect About You

Personal Data

When you sign up for the App, we request the following information:

• First name and last name
• Email address
• Date of birth
• Gender
• Location (postcode and country)
• Height and weight
• Weekly drinking average
• Unique password
• Optional profile photo

Special Category Data

Special category data includes your digital biomarker data and health-related data measured through the Zailo app, including:

• Abstinence and alcohol consumption
• Nutrition (food, fluid, etc.)
• Sleep activity
• Physical activity
• Drink location
• Coping strategies and triggers
• Personal interests (e.g., music, sports)
• Time stamps of activities

Log Files and Analytics

We collect information your browser or App sends, including:

• Internet Protocol (IP) address
• Device model and IMEI number
• Browser type and version
• Pages visited and time spent
• Mobile UDID and geo-localization data

We use third-party services such as Google Analytics to collect, monitor and analyze this information to improve our App functionality.

4. How We Use Your Personal Data

Legal Basis for Processing

We collect personal data from you where we have:

• Your consent to do so
• A need to perform a contract with you
• Legitimate interests not overridden by your data protection rights
• A legal obligation

We Use Your Data To:

• Deliver content and services to you
• Send reminders and digital behaviour change interventions
• Improve your user experience by personalizing the App
• Respond to your support requests
• Register you as a user
• Manage our relationship with you
• Improve our platform, products and services
• Monitor trends to improve the App
• Detect or prevent illegal activities
• Send marketing communications (with your consent)

5. Disclosures of Your Personal Data

We Never Sell Personal Data

We will never sell your personal data to a third party.

We May Disclose Your Data To:

• Service Providers: Who provide data processing services integral to delivering our services
• Professional Advisers: Including lawyers, bankers, auditors and insurers
• Regulators: HM Revenue & Customs and other authorities where required
• Research Partners: For anonymized research and analysis (identity always protected)
• Corporate Events: Third parties in the event of a business sale, transfer or merger

6. Data Security

We use various security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. We secure the personal data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

7. Data Retention

We will only retain your personal data as per the NHS (National Health Service) data retention policy to fulfill the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting or reporting requirements.

You can ask us to delete your data. In some circumstances, we will anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your Legal Rights

You have the following data protection rights:

• Access: Request access to your personal data
• Correction: Request correction of inaccurate personal data
• Deletion: Request deletion of your personal data
• Object: Object to processing of your personal data
• Restrict: Request restriction of processing your personal data
• Transfer: Request transfer of your personal data
• Withdraw Consent: Withdraw your consent at any time
• Complain: Make a complaint to the Information Commissioner's Office (ICO)

To exercise any of these rights, please contact us at digital@zailo.co.uk

9. International Transfers

Certain of our third-party suppliers are based outside the European Economic Area (EEA). When we transfer your personal data from the EEA, we use EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer.

10. Cookies and Similar Technologies

If you access your account in the App, we will use tracking technology to retain your login session. We use third parties such as Google Analytics to track user behaviour on the App.

We don't partner with any third party to advertise in the App based on your personal preferences and data. We don't share or sell personal data to any third party for advertising or marketing.

11. Contact Us