PRIVACY POLICY

Last Updated: February 1, 2026

This Privacy Policy explains how Zenturo Ltd. ("Zenturo", "we", "us") collects, uses, stores, and protects personal data when you visit or interact with the website located at zenturo.com (the "Website").

Scope clarification: This Privacy Policy applies solely to zenturo.com. If you use the Agend product or other Zenturo-operated services, those services are governed by their own separate privacy policies.

1. Data Controller

Zenturo Ltd.
394A / 395A, Triq il-Kbira San Guzepp
Santa Venera, SVR 1016
Malta

Company Registration No.: C-39472
VAT ID: MT-18142026

Email: service@zenturo.com

2. Information We Collect

a) Information You Provide

• Name, email address, phone number
• Information submitted via contact forms
• Communications between you and us
• Business or consultation-related information you voluntarily share

b) Information Collected Automatically

• IP address
• Browser type and device information
• Referring/exit pages
• Log file data and timestamps
• Cookie and similar tracking data

c) Cookies and Tracking Technologies

We may use cookies, analytics tools, and similar technologies to understand website usage, improve performance, and enhance user experience. You may control cookies through your browser settings. Where legally required, we use a consent mechanism for optional cookies.

3. How We Use Information

• To respond to inquiries and provide requested information
• To operate, secure, and improve the Website
• To communicate with prospective clients
• To comply with legal obligations
• To protect against fraud, abuse, or security risks

4. Legal Bases (GDPR)

Where GDPR applies, we rely on:

• Contract / Pre-contractual steps – to respond to service inquiries
• Legitimate interests – to operate and improve the Website
• Consent – where required (e.g., optional analytics or marketing)
• Legal obligation – where processing is required by law

5. How We Share Information

We may share information with:

• Hosting providers and IT service providers
• Analytics providers
• Professional advisors (legal, accounting, compliance)
• Authorities where required by law
• In connection with a merger, acquisition, or corporate restructuring

We may also share aggregated or anonymized data that does not identify you.

6. International Transfers

Your data may be processed outside your country, including outside the EEA. Where required, we implement appropriate safeguards such as Standard Contractual Clauses or equivalent legal mechanisms.

7. Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy, including:

• Responding to inquiries
• Maintaining business records
• Complying with legal obligations
• Resolving disputes
• Enforcing agreements

Where we retain data for analytical or improvement purposes, we take steps to minimize or anonymize identifying information where feasible.

8. Security

We implement reasonable administrative, technical, and organizational measures to protect personal data. However, no system is completely secure, and we cannot guarantee absolute security.

If a security breach occurs that affects your personal data, we will take appropriate steps in accordance with applicable laws and regulations.

9. Your Rights

Depending on your location and applicable law, you may have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data
• Request restriction of processing
• Object to certain processing
• Request data portability (where applicable)
• Withdraw consent where processing is based on consent

You may also lodge a complaint with a supervisory authority in the country where you reside, work, or believe your rights were infringed.

To exercise your rights, contact: service@zenturo.com

10. Children

The Website is not intended for individuals under 18. We do not knowingly collect personal data from children.

11. External Links

The Website may contain links to third-party websites. We are not responsible for their privacy practices. Please review their policies before submitting personal information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised "Last Updated" date.

13. Contact

Zenturo Ltd.
394A / 395A, Triq il-Kbira San Guzepp
Santa Venera, SVR 1016
Malta

Email: service@zenturo.com

Company Registration No.: C-39472
VAT ID: MT-18142026