Zeteo Privacy Policy

Last updated: August 8, 2026
Effective date: August 8, 2026

ZM22ZR, LLC (”Zeteo,” “we,” “us,” or “our”) provides the Zeteo mobile application (the “App”) and related services (together, the “Services”). This Privacy Policy explains what information we collect, how and why we use it, who we share it with, how long we keep it, and the rights and choices available to you.

This policy applies to the Zeteo App on iOS and Android. It does not cover Substack’s own website or services, or any third-party website or service you access through a link in the App. Those are governed by their own privacy policies.

By using the App, you acknowledge that you have read and understood this Privacy Policy.

1. Summary

For quick reference (the detail is in the sections below):

• We collect the minimum needed to run the App: your Substack account email/name (to verify your subscription), a push token and your notification preferences (if you opt in), and anonymous usage analytics.

• We use AppsFlyer to measure how installs happen and how the App is used afterward, without giving it your name, email address, or account identifier. On iOS this only runs if you allow it via Apple’s tracking prompt.

• We do not collect your precise location, camera, photos, microphone, or contacts.

• We do not sell your personal information or share it for cross-context behavioral advertising.

• We do not store your Substack password; you log in through Substack directly.

• You can disable notifications, deny tracking, and request deletion of your account data at any time.

2. Information We Collect

We collect information in three ways: (a) information you provide, (b) information collected automatically as you use the App, and (c) information we receive from third-party service providers.

2.1 Information You Provide

Account and subscription information. To access Zeteo content, you log in with your Substack account. Through Substack’s authentication, we receive:

• Your email address

• Your name (where you have provided one to Substack)

• Your subscription plan and status (for example, free or paid subscriber, and tier)

We use this to confirm what content you are entitled to. Authentication happens on Substack’s own login screen; we never receive or store your Substack password.

Substack is the data controller for the account, payment, and other information it collects from you directly (for example, when you create your Substack account or manage your subscription), and its handling of that information is governed by Substack’s Privacy Policy. This Privacy Policy covers only the limited information Zeteo receives and uses as described here.

Reviewer / access-code sessions. For App Store and Google Play review, we support a temporary access-code sign-in that unlocks content without a Substack login. These sessions are not linked to an email address or personal identity, and the session record itself contains no account identifier.

Purchases made in the App. If you subscribe through the App on iOS, the purchase is processed by Apple under your Apple Account. We do not receive or store your payment card details. We receive a signed transaction record from Apple confirming that a valid subscription exists, along with its expiry, so we can unlock paid content.

Communications. If you contact us for support, we receive whatever information you include in your message (such as your email address and the contents of your request).

2.2 Information Collected Automatically

Push notification data. If you enable notifications, we collect:

• A device push token issued by Apple Push Notification service (APNs) or Firebase Cloud Messaging (FCM)

• Your notification preferences (for example: breaking news, show/episode alerts, followed topics, digests)

We use these only to deliver the notifications you’ve opted into. You can change or turn off notifications at any time.

Usage and analytics data. To understand how the App is used and to improve it, we collect anonymous event and device data, including:

• App events (for example: articles viewed, videos played, screens visited, features used)

• General device information (device type, operating system version, App version)

• An anonymous device identifier used for analytics that is not tied to your name or account and that rotates automatically each day

This analytics data is designed to be non-identifying; it does not include your name or email.

Log and technical data. When the App communicates with our servers, our servers automatically record standard technical information such as IP address, device/client type, request timestamps, and error/diagnostic data. We use this for security, debugging, rate-limiting, and abuse prevention. IP addresses are not stored alongside your analytics events in identifiable form.

On-device storage. The App stores certain data locally on your device, such as your login session token (kept in the device’s secure storage), your notification preferences, cached article content for offline reading, and analytics events queued for sending. Our attribution provider also stores a small identifier on your device so that a reinstall of the App can be recognized as a reinstall rather than a new install. This data lives on your device and is removed when you log out or uninstall the App (offline cache and queued events may clear on logout).

2.3 Information From Third Parties

Attribution data (AppsFlyer). We use AppsFlyer to understand how users discover and install the App, for example which marketing campaign, ad, or referral led to an install, and how the App is used after install (for example, articles opened, media played, and articles saved). We do not provide AppsFlyer with your name, email address, or account identifier, and we do not send it the text of your searches or the headlines of the articles you read. On iOS, AppsFlyer only accesses device identifiers used for tracking if you grant permission through Apple’s App Tracking Transparency (ATT) prompt. If you decline, the App still works fully. On Android, attribution operates in line with your device’s advertising settings.

We do not collect precise geolocation, and we do not access your camera, photo library, microphone, or contacts.

3. How We Use Information

We use the information described above to:

• Provide, operate, and maintain the App and its content

• Authenticate you and verify your subscription status to unlock paid content

• Deliver push notifications you have opted into, in the categories you’ve chosen

• Understand how the App is used and improve features, content, reliability, and performance

• Measure the effectiveness of our marketing and understand install sources

• Provide customer support and respond to your requests

• Detect, investigate, and prevent fraud, abuse, security incidents, and technical problems

• Comply with applicable law and enforce our terms

We do not sell your personal information, and we do not use it for cross-context behavioral advertising.

4. Legal Bases for Processing (EEA / UK)

If you are in the European Economic Area or the United Kingdom, we process your personal data under the following legal bases:

• Performance of a contract: to authenticate you, verify your subscription, and provide the App you’ve requested.

• Consent: for push notifications, for tracking/attribution on iOS via the ATT prompt, and — if you are in the EEA or UK — before any analytics data is shared with our third-party analytics provider. You may withdraw consent at any time in the App’s settings.

• Legitimate interests: for first-party anonymous analytics, product improvement, security, and abuse prevention, balanced against your rights and freedoms. Analytics shared with our third-party analytics provider relies on consent for users in the EEA and UK, as described above.

• Legal obligation: where processing is necessary to comply with the law.

5. How We Share Information

We share information only with service providers that help us operate the App, and only as needed for them to perform their services. The categories of recipients are:

Service provider

Purpose

Data shared

Substack

Authentication and subscription verification

Email, name, subscription status

Apple

In-app subscription purchase and renewal

Purchase and transaction records associated with your Apple Account; we receive a signed confirmation of entitlement and expiry, not your payment details

AppsFlyer

Install attribution and marketing analytics

Device identifiers, install and in-app event signals (subject to iOS ATT consent); no name, email address, or account identifier

PostHog

Anonymous product analytics

Anonymous, daily-rotating device identifier; app events

Apple (APNs) / Google (FCM)

Push notification delivery

Device push token

Hosting / infrastructure providers

Running our servers and delivering content

Technical/log data described above

These providers are contractually limited to using your information to provide services to us and are subject to their own privacy policies. We do not share your information with third parties for their own independent marketing.

We may also disclose information:

• To comply with applicable law, regulation, legal process, or enforceable governmental request

• To enforce our terms or protect the rights, property, or safety of Zeteo, our users, or the public

• In connection with a merger, acquisition, financing, or sale of assets, in which case we will require the recipient to honor this Privacy Policy or notify you of any material change

6. Data Retention

We keep personal information only as long as necessary for the purposes described in this policy:

• Account/subscription data: for as long as your account/session is active, and afterward as needed for legal compliance, dispute resolution, and enforcement.

• Push tokens and preferences: until you disable notifications, log out, or uninstall, or until the token becomes invalid.

• Analytics data: retained in anonymized/aggregated form; the analytics identifier rotates daily and is not linked to your identity.

• Log/technical data: retained for a limited period for security and diagnostics.

When we no longer need information, we delete or anonymize it.

7. Your Choices and Rights

Push notifications. Manage or disable notification categories anytime in the App’s notification settings, or in your device’s system settings.

Tracking (iOS). Allow or deny App Tracking Transparency at any time in Settings > Privacy & Security > Tracking. On Android, you can reset or limit your advertising identifier in your device settings.

Analytics (EEA/UK). If you are in the EEA or UK, we ask for your consent before sharing analytics data with our third-party analytics provider. You can give or withdraw that consent at any time in the App’s settings.

Account data. To request access to, correction of, or deletion of your account information, contact us at support@zeteonews.com. You can also log out in the App to clear your session and locally stored content on the device.

Regional rights. Depending on where you live, you may have additional rights (see Sections 8 and 9). We will not discriminate against you for exercising your privacy rights.

8. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know / access the categories and specific pieces of personal information we’ve collected about you

• Delete personal information we’ve collected, subject to legal exceptions

• Correct inaccurate personal information

• Opt out of the “sale” or “sharing” of personal information

We do not sell or share personal information as those terms are defined under the CCPA/CPRA, and we do not knowingly sell or share the personal information of minors under 16.

In the past 12 months, we have collected the following categories of personal information: identifiers (email, name, device identifiers, push token, IP address), internet/network activity (app usage and analytics events), and commercial information (subscription status). We collect this from you and from the service providers listed in Section 5, for the business purposes described in Section 3.

To exercise your rights, contact us at support@zeteonews.com. We may need to verify your identity before responding. You may use an authorized agent to submit a request on your behalf.

9. Your European Privacy Rights (GDPR / UK GDPR)

If you are in the EEA or UK, you have the right to access, rectify, erase, restrict, or object to processing of your personal data, and the right to data portability. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise these rights, contact us at support@zeteonews.com. You also have the right to lodge a complaint with your local data protection authority.

10. Children’s Privacy

The App is not directed to children under 13 (or the applicable minimum age in your jurisdiction), and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us at support@zeteonews.com and we will delete it.

11. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect your information, including encrypted transport for network communications and secure on-device storage for session tokens. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

12. International Data Transfers

We are based in the United States, and your information may be processed in the United States or other countries where we or our service providers operate. These countries may have data protection laws that differ from those in your country of residence. Where required, we implement appropriate safeguards (such as standard contractual clauses) for such transfers.

13. Third-Party Links and Content

The App may contain links to third-party websites or services (for example, Substack, or sources referenced in articles). We are not responsible for the privacy practices of those third parties, and this Privacy Policy does not apply to them. We encourage you to review their privacy policies, including Substack’s Privacy Policy, which governs the information Substack collects and processes as its own data controller.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last updated” date above and, where appropriate, provide additional notice in the App. Your continued use of the App after an updated policy takes effect constitutes acceptance of the changes.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, contact us at:

ZM22ZR, LLC (d/b/a Zeteo)
1640 Boro Pl, 4th Floor
McLean, VA 22102
United States
Email: support@zeteonews.com