Privacy Policy — ZeroTrust

Version: 2026-10-01 · Effective: October 1, 2026 · Supersedes: none, this is the first published version

This document is versioned by its effective date. Every superseded version remains available at zerotrust.entrinsia.com/privacy-policy/<version> permanently. Changes are listed in the Revision History at the end.

This Privacy Policy explains how Entrinsia Inc. ("Entrinsia," "we," "us," or "our") collects, uses, shares, and protects information in connection with ZeroTrust, our identity and age verification product (the "Service").

ZeroTrust is used in two ways, and this policy addresses both:

Business Customers — companies that integrate ZeroTrust into their checkout, sign-up, or account flows ("Customers," "you," when we mean the business).
End Users — the individuals a Customer's website or app asks to verify their ID and take a live selfie ("End Users," "you," when we mean the person being verified).

By using ZeroTrust, whether as a Customer integrating the Service or an End User completing a verification, you agree to the practices described in this Privacy Policy.

1. The Short Version

We wrote the full policy below because you should be able to see exactly how we handle your information. Here is the part that matters most.

We do not store the ID photo or video selfie you submit during verification. Both are processed in real time and permanently deleted, typically within seconds of a verification completing.
We do not extract, retain, or sell biometric templates. The facial comparison used to confirm liveness and match a selfie to an ID happens in memory during processing and is not saved afterward.
We retain only what a compliance record needs. After a verification ends we keep the person's name, the pass or fail result of each check we ran, the type of document presented, coarse location (city, state, and postal code), a one-way hash of the document number, a record of the biometric notice that was accepted, and a timestamped record that the verification occurred.
Full street address is passed through, never retained. Where a Customer has configured ZeroTrust to return the address printed on an ID, we pass it to that Customer at the moment of verification, for example so a shopping cart can populate a shipping address. Entrinsia does not store it.
Date of birth is never returned and never retained. It is read from the ID solely to compare against the age threshold the Customer configured, such as 18 or 21. Neither the date of birth nor the person's exact age leaves that comparison. We keep only the threshold that was applied and whether it was met.
Document numbers are never stored in readable form. If a document number, such as a driver's licence or passport number, is part of a verification, we store only a one-way cryptographic hash of it, not the number itself. We cannot look up or reveal what a document number is from that hash. We can only confirm whether a document number someone later presents matches one we have seen before.
We do not sell personal information, and we do not use End User verification data for advertising.
We do not use your data to train AI models. Neither we nor the cloud processing providers we use may train or improve any machine learning model on ID images, video selfies, biometric data, or data extracted from an ID.

The rest of this policy explains all of this in detail, including exactly what we collect, how long we keep it, who is responsible for what, and your rights.

2. Information We Collect

2.1 Information From Business Customers

When a business signs up to use ZeroTrust, we collect:

Account information — name, business name, email address, and role of the individuals who administer the account.
Billing information — billing contact, billing address, and payment details (processed by our third-party payment processor or AWS Marketplace; we do not store full payment card numbers).
Integration data — domains registered for verification, configuration settings (which data fields are returned, age thresholds, accepted document types), and API and usage logs.
Communications — support requests, correspondence, and information provided when you contact us.

2.2 Information From End Users During Verification

When an End User completes a ZeroTrust verification, the following information is involved.

Submitted during the verification session, processed, then deleted:

A photo or scan of a government-issued ID (driver's licence, state ID, or passport)
A short video selfie used for liveness detection and to confirm the selfie matches the ID photo

Extracted during processing, and returned to the Customer only where that Customer has configured the field:

Name fields printed on the ID
Address fields printed on the ID, including the street address
Document number, document type, and expiration date
A pass or fail result for each check performed: document authenticity, age threshold, liveness, selfie match, document expiry, and any acknowledgment step
An age-over-threshold confirmation, for example "21 or over: yes"
Liveness and face-match confidence values used to produce those results

Fields a Customer has not configured are not transmitted to that Customer. Date of birth is never transmitted, under any configuration.

Used internally only, never transmitted and never retained:

Date of birth, read from the ID solely to compare against the Customer's configured age threshold
Exact age, computed from the date of birth for that same comparison and discarded with it

Retained by Entrinsia after the verification session ends (see Section 5):

Full name
City, state, and postal code as printed on the ID. Never the street address
The age threshold that was applied, and whether the End User met it
The type of document presented, and whether it had expired
A one-way keyed cryptographic hash of the document number, never the number itself (Section 5.3)
The pass or fail result of each check performed, and the confidence values that produced those results
A record that the biometric notice was accepted, which version of that notice was shown, and when
A compliance record confirming the verification occurred: timestamp, result, session identifier, the Customer's account, and the Customer's transaction or order reference where supplied
Device diagnostics: device type, mobile operating system, browser user agent, and camera resolution

Returned to the Customer, never retained by Entrinsia, regardless of configuration:

Full street address, passed through at the moment of verification so a Customer's order or account processing can use it

We do not retain the ID image, the video selfie, the document number in readable form, the date of birth, the exact age, the street address, gender, the document issue or expiry dates, or any biometric template derived from any of them. See Section 9 for biometric information specifically.

2.3 Information Collected Automatically

When Customers or End Users interact with our website, API, or verification widget, we automatically collect:

Device and log data — IP address, browser type, operating system, device identifiers, and timestamps
Usage data — API calls made, pages visited on our marketing site, and general interaction data used for reliability, security, and abuse prevention

2.4 Information From Third Parties

Cloud AI providers (currently Amazon Web Services) that perform the underlying document authentication, liveness detection, and facial comparison on our behalf. These providers process ID images, video selfies, and biometric comparisons solely in memory and in transit to return a result to us, operate under contract as our subprocessors, and are contractually prohibited from retaining End User ID images, selfies, or biometric data, or from using them to train or improve their own AI models or services.
Payment processors and AWS Marketplace — transaction confirmations and subscription status.
Authentication providers, if a Customer's administrator signs in using a third-party identity provider.

2.5 Verification Starts and Service Telemetry

When an End User opens the verification portal, before any acknowledgment and before any camera access, we record that a verification began. That record contains a timestamp, a session identifier, the Business Customer's account and organisation code, the Customer's transaction or order reference where supplied, an identifier for the e-commerce platform the verification was launched from, the Customer's registered storefront domain, the address of the page that embedded the portal, and the device type, operating system, and browser user agent.

We use this record for two purposes. The first is to measure how many End Users begin a verification and do not finish it, so that we can find and fix the points where the flow fails. The second is to bill Business Customers, as described in our Terms of Service.

This record contains nothing read from an ID, no image, and no biometric data. It is retained for the same period as the compliance record described in Section 5.4.

We also record operational events during a verification, such as which step was reached and whether a step failed, for reliability and fraud monitoring. These events carry the same identifiers as the start record and no ID data.

3. How We Use Information

3.1 To Provide the Verification Service

Authenticate a submitted ID and confirm it is genuine
Confirm the person in the live selfie matches the ID and is physically present (liveness and anti-spoofing)
Determine age from the ID and compare it to the Customer's configured threshold
Return the specific result and data fields the Customer configured
Generate and retain the minimal compliance record described in Section 5

3.2 To Operate Our Business

Administer Customer accounts and process billing
Provide support and respond to inquiries
Maintain the security, integrity, and availability of the Service
Detect, investigate, and prevent fraud, abuse of the verification flow (for example repeated fake ID attempts), and security threats
Analyse aggregated, de-identified usage trends to improve accuracy and performance

3.3 What We Do Not Do

We do not use End User ID images, selfies, or extracted ID data for advertising or marketing.
We do not sell personal information to third parties.
We do not build a searchable database of End Users' identities.
We do not use Customer data, End User ID images, video selfies, biometric data, or data extracted from an ID to train or improve any machine learning model, whether our own or a third party's.

We do not sell personal information. We share information only as follows.

4.1 Service Providers

We use vetted service providers under contract to operate ZeroTrust, including cloud infrastructure and AI processing providers, payment processors, and email and communication tools. These providers process data solely to deliver the Service to us and are contractually restricted from using it for their own purposes, from retaining it beyond what is needed to perform the service, and from using it to train or improve any model.

A current list of the subprocessors that process End User personal data, including the categories of data each one receives and the country in which it processes them, is maintained at zerotrust.entrinsia.com/subprocessors. Business Customers may subscribe to notification of changes to that list. The notice period and objection right are set out in our Terms of Service.

4.2 With the Business Customer

The result of a verification, and any data fields the Customer configured us to return, is shared with the Customer whose checkout or sign-up flow initiated the verification. The Customer receives only what it configured. It does not receive the underlying ID image or video selfie, and it does not receive the date of birth under any configuration.

4.3 Legal Requirements

We may disclose information if required to do so by law, subpoena, court order, or governmental request, or where we believe disclosure is necessary to protect our rights, investigate fraud, or respond to an emergency.

4.4 Business Transfers

If Entrinsia is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Policy or a policy offering equivalent protections.

We may share information for other purposes with explicit consent from the relevant party.

5. Data Retention

This is the section most people come to this policy to read, so we have kept it direct.

5.1 Raw ID Images and Video Selfies

The ID image and video selfie submitted during a verification are processed in memory and in transit to perform document authentication, liveness detection, and facial comparison. Once a result is produced, the raw image and video are permanently deleted, generally within seconds, and no later than the completion of the verification session. In the event of a system error, a dropped session, or an uncompleted verification attempt, deletion occurs in all cases within 24 hours. We do not archive them, we do not use them for model training in any form, and we do not provide any Customer, employee, or third party with access to them after deletion.

Two mechanisms back this commitment rather than policy alone. Images and video are never written to persistent storage in the first place: they are held in browser memory for the life of the session and discarded with it. Where a verification begins on a desktop and is completed on a phone, every image and video is removed on the phone before anything is transmitted, so the record that moves between the two devices contains text fields and numeric results only.

A handoff record that the originating desktop never collects, because the End User closed the page or lost connectivity, is deleted automatically within 24 hours.

5.2 Extracted Data Fields

Not every field we can read from an ID is retained, even where it was briefly available during processing or returned to the Customer at the moment of verification.

We retain: the full name; the city, state, and postal code printed on the ID; the age threshold applied and whether it was met; the document type and whether the document had expired; a keyed one-way hash of the document number; the pass or fail result and confidence value for each check performed; and a record of the biometric notice accepted.

We do not retain, even though it is returned to the Customer at the moment of verification: the full street address, used only to support the Customer's own order or account processing. It is not stored by Entrinsia after the verification session ends.

We never return, and never retain: the date of birth, and the exact age computed from it. Both are used solely to produce a pass or fail result against the Customer's configured age threshold, and neither leaves that computation.

We do not retain at all: gender, the document issue date, the document expiry date, or any field a Customer has not configured us to return.

5.3 Document Numbers, One-Way Hash Only

Document numbers, such as a driver's licence or passport number, are never retained in plaintext or in any reversible form. Instead, we store a one-way cryptographic hash of the document number.

This means:

We cannot reconstruct, decrypt, or look up the original document number from what we store.
We can compare a document number presented to us in the future against previously stored hashes, to determine whether that specific document has been used in a prior verification. This lets us flag the same ID being used across multiple accounts or orders in a way that may indicate fraud.
The hash is produced with a secret key held on our servers and never released to a browser or a Customer. A licence number alone carries little entropy, so an unkeyed digest would be reversible by anyone who obtained the stored values. The keying prevents that.
This hash is not linked back to the underlying ID image or video selfie, both of which are already deleted under Section 5.1.

This allows us, and where configured our Customers, to detect document reuse and fraud patterns without Entrinsia ever holding a readable copy of a government ID number.

5.4 Compliance Record

For every verification attempt, we retain a minimal compliance record consisting of a timestamp, the pass or fail result, a session identifier, the Customer's account, and, where supplied by the Customer, a transaction or order reference. This record exists so a Customer can demonstrate, if audited or challenged, that a verification took place and what its outcome was. It does not, and will never, contain the ID image, the video selfie, or any biometric template, regardless of retention period.

Retention period: compliance records, the retained fields described in Section 5.2, the biometric notice acceptance record described in Section 9.3, and the start and telemetry records described in Section 2.5 are retained for 3 years from the date of verification, which aligns with common state age-verification and audit-trail requirements, including recommended AB 1263 recordkeeping practices. Where a Customer's financial, tax, or KYC-related obligations require longer retention of associated billing or transaction records, those specific records, not the compliance record itself, may be retained for up to 7 years, consistent with Section 5.5. After the applicable period, records are deleted or de-identified, except as required by law (Section 5.7).

5.5 Business Customer Account Data

Customer account and billing information is retained for the duration of the Customer's subscription and for a limited period afterward as required for accounting, tax, and legal purposes, generally up to 7 years for financial records.

5.6 Backups

Backup copies of the limited data described above may persist for a short period after deletion for disaster recovery purposes, and are purged on a routine schedule. Raw ID images and video selfies are never written to backups, because they are never written to persistent storage in the first place.

5.7 Legal Holds

We may retain information longer than stated above where necessary to comply with a legal obligation, resolve a dispute, or enforce our agreements.

6. Data Controllers and Processors

Understanding who is responsible for what matters for compliance, for both Customers and End Users.

6.1 For Business Customers

Entrinsia is the data processor for verification data belonging to a Customer's End Users. We process it strictly according to the Customer's configuration and instructions, such as which fields to return and what age threshold to apply.
The Customer is the data controller for its End Users' verification data. The Customer determines why verification is being run, for example to comply with an age-verification law, what it does with the data we return, and how long it keeps that data on its own systems.

Business Customers processing personal data subject to the GDPR or the UK GDPR should also read our Data Processing Addendum, which forms part of our agreement with them and sets out our obligations as a processor in full.

6.2 What This Means in Practice

Customers are responsible for having a lawful basis to collect and use End User data, for their own privacy notices to their End Users, for honouring End User rights requests regarding data the Customer holds, and for their own regulatory compliance with respect to what they do with the verification result after we return it.
Entrinsia is responsible for processing data only as instructed, securing it appropriately while it is in our systems, deleting the raw ID image and video selfie as described in Section 5, and providing the biometric notice described in Section 9.3.
End Users whose data was processed as part of a verification, and who have questions about how a business used their result, should generally start with that business, since the business controls what happens to the data after we return it. Entrinsia will assist Customers in responding to End User requests where relevant to data we hold.

7. Data Security

7.1 Technical Safeguards

Encryption — data is encrypted in transit (TLS) and at rest.
Keyed one-way hashing of document numbers — document numbers are never stored in plaintext; only an irreversible keyed cryptographic hash is retained, as described in Section 5.3, with the keying material held server side and never released to a browser.
Ephemeral processing — raw ID images and video selfies are held in memory for the life of the session and are never written to storage or backup. In cross-device verification, all image data is removed on the capturing device before any transfer.
Access controls — access to Customer accounts, configuration, and compliance records is role-based and limited to personnel who need it to operate or support the Service.
Zero-trust architecture — every request to our systems is authenticated and authorised; nothing is trusted by default based on network location alone.
Monitoring — we monitor for anomalous access patterns and potential abuse of the verification flow.

7.2 Organizational Safeguards

Limited employee access to personal information, on a need-to-know basis
Confidentiality obligations for employees and contractors with system access
Vetting of subprocessors who touch verification data (see Section 4.1)

7.3 No Guarantee of Absolute Security

No method of transmission or storage is 100% secure, and no verification system can guarantee the identification of every fraudulent document or spoofing attempt with perfect accuracy. We implement reasonable, industry-standard safeguards, but we cannot and do not guarantee absolute security, or guarantee that every verification result is error-free. Customers are responsible for determining whether ZeroTrust's verification approach is appropriate for their specific legal and risk requirements, and for maintaining appropriate fallback and dispute-handling procedures for their own use of the Service.

7.4 Data Breach Notification

In the event of a breach affecting personal information we control, we will notify affected Business Customers without undue delay, and in any event within 72 hours of becoming aware, so they can meet their own notification obligations. We will notify affected individuals directly where we are legally required to do so, consistent with applicable law.

8. Your Privacy Rights

8.1 If You Are a Business Customer

You may access, correct, or export your account and configuration data through your account, or by contacting us. You may request deletion of your account, subject to the retention obligations described in Section 5.5.

8.2 If You Are an End User

Because a Business Customer controls what happens to your verification result after we return it (Section 6), requests about how a business uses your data should generally go to that business first. For data that Entrinsia itself holds, being the compliance record described in Section 5.4 and the retained fields described in Section 5.2, you may contact us directly, and we will work with the relevant Customer as needed to respond to:

Access — a description of the compliance record and retained fields we hold about a specific verification
Correction — correction of inaccurate information we hold
Deletion — deletion of the compliance record and any retained fields, subject to the legal retention exceptions in Section 5.7
Questions about a specific verification result — we can confirm what our system returned to the Customer, but decisions about the underlying transaction, such as whether an order shipped, are the Customer's to make

8.3 How to Exercise These Rights

Email support@entrinsia.com with the subject line "Privacy Rights Request," including your name, the Customer or business involved if known, and the nature of your request. We will respond within 30 days, or as required by applicable law. We may need to verify your identity before completing certain requests.

9. Biometric Information

Because ZeroTrust's core function involves comparing a live selfie to a photo ID, this section addresses biometric data specifically and directly.

9.1 What We Process

During a verification session, our system, and the AI processing providers we use under contract, analyses a live video selfie in order to confirm that it reflects a real, physically present person rather than a photo, video, or mask, and to compare facial characteristics to the photo on the submitted ID in order to produce a match or no-match signal.

9.2 What We Do Not Do

We do not store the video selfie or ID photo after verification (Section 5.1).
We do not create or retain a persistent biometric template, faceprint, or identifier that could be used to re-identify an End User later or to run future comparisons.
We do not use biometric data for any purpose other than completing the specific verification session in which it was submitted.
We do not use biometric data to train or improve any machine learning model, and our processing providers are contractually prohibited from doing so.
We do not sell, license, or otherwise disclose biometric data to third parties for their own purposes.

Before ZeroTrust requests access to a camera, and before it captures any image or video, the verification flow displays a biometric notice and requires the End User to take an affirmative action to continue. The notice states:

that a photograph of a government-issued ID and a short video selfie will be captured;
that facial characteristics from the selfie will be compared with the photograph on the ID, in order to confirm that they match and that a live person is present;
that this processing is carried out by Entrinsia and by the cloud processing providers named in Section 14, acting under contract on our behalf;
that the image and the video are deleted when the session ends and are never used to train any model; and
that no facial template, faceprint, or other persistent biometric identifier is created or stored.

An End User who does not accept cannot proceed, and no camera is opened. Where a verification begins on a desktop and is handed off to a phone, the notice is shown on the device that captures the images.

We retain a record that the notice was accepted, which version of the notice text was shown, and when it was accepted. We retain no image or video associated with that acceptance. A Business Customer may request that record for a verification run under its account.

This notice is built into the ZeroTrust flow. It does not depend on a Business Customer's configuration and cannot be disabled. It is separate from, and does not replace, any additional notice a Business Customer displays in its own checkout or sign-up flow, such as an AB 1263 disclaimer or a notice specific to that Customer's product or jurisdiction.

9.4 State Biometric Privacy Laws

We designed our biometric handling, being real-time processing with immediate deletion, no persistent templates, and the mandatory in-flow notice described in Section 9.3, to align with the intent of state biometric privacy statutes, including the Illinois Biometric Information Privacy Act (BIPA), the Texas Capture or Use of Biometric Identifier Act, Washington's biometric privacy law, and comparable provisions under California law.

Business Customers deploying ZeroTrust in these states remain responsible for their own compliance obligations under these statutes, including any notice or written release those statutes require of the party collecting biometric identifiers, since Entrinsia acts as a processor and does not control how a Customer presents verification to its own End Users.

10. California Residents (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), as amended.

10.1 Right to Know

You may request the categories and specific pieces of personal information we hold about you, the categories of sources, the business purpose for collecting it, and the categories of third parties with whom it is shared.

10.2 Right to Delete

You may request deletion of personal information we hold about you, subject to exceptions such as completing a transaction, complying with a legal obligation, or the compliance-record retention described in Section 5.

We do not sell personal information, and we do not share it for cross-context behavioural advertising. There is nothing to opt out of.

10.4 Right to Correct

You may request correction of inaccurate personal information we hold.

10.5 Right to Limit Use of Sensitive Personal Information

ID and biometric data processed during verification may constitute "sensitive personal information" under the CCPA while it is being processed. We limit our use of this information to the verification purpose itself and do not use it to infer characteristics about you beyond the specific configured result. Because the underlying image and biometric data are deleted immediately after processing (Section 5.1), and because we do not retain the date of birth, exact age, street address, or readable document number (Section 5.2), there is minimal sensitive personal information for us to retain or further limit.

10.6 Non-Discrimination

We will not discriminate against you for exercising your CCPA rights.

10.7 Authorized Agents

You may designate an authorised agent to submit requests on your behalf, subject to identity and authorisation verification.

10.8 How to Submit a CCPA Request

Email support@entrinsia.com with subject line "CCPA Request."

If you are located in the European Economic Area, United Kingdom, or Switzerland, the following applies where the GDPR governs our processing.

11.1 Legal Basis for Processing

Contract — to provide the Service to a Business Customer or complete a specific verification an End User initiated (Article 6(1)(b))
Legitimate interests — to secure the Service, prevent fraud, and improve verification accuracy (Article 6(1)(f))
Legal obligation — to comply with applicable law (Article 6(1)(c))
Explicit consent for biometric data — facial liveness detection and the comparison of a live selfie to an ID photo constitute processing of special category biometric data for the purpose of uniquely identifying a person. For End Users located in the EEA, UK, or Switzerland, this processing relies on explicit consent under Article 9(2)(a) GDPR, obtained through the mandatory in-flow consent step described in Section 9.3, in addition to the Article 6 basis supporting the verification as a whole.

11.2 International Transfers

Data may be processed in the United States. Where required, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses and, for UK transfers, the UK International Data Transfer Addendum. The operative terms are set out in our Data Processing Addendum at zerotrust.entrinsia.com/dpa.

In addition to the rights in Section 8, you may have the right to restrict processing, receive your data in a portable format, object to processing based on legitimate interests, and lodge a complaint with your local data protection authority.

11.4 Contact

Email support@entrinsia.com, subject line "GDPR Request."

12. Children's Privacy

ZeroTrust is not directed at children, and its function, being to verify that a person meets a minimum age requirement, typically 18 or 21, is designed to prevent underage individuals from completing age-restricted transactions in the first place.

We do not knowingly collect personal information from children through the verification flow independent of a verification attempt.
If a verification attempt indicates the individual does not meet the required age threshold, the raw ID image and selfie are deleted in the same manner as any other verification (Section 5.1), and only the configured fail result is returned to the Customer.
If we become aware that we have retained information about a child under 13 outside of the standard verification-and-delete flow described above, we will delete it promptly. Parents or guardians with concerns should contact support@entrinsia.com.

13. Cookies and Tracking

13.1 What We Use Cookies For

Essential cookies — authentication for Business Customer accounts, session management, and security
Functional cookies — remembering preferences and settings
Analytics cookies — understanding usage of our marketing website and dashboard

13.2 What We Don't Do

We do not use cookies to track End Users across unrelated third-party websites, and we do not use verification-related data for ad targeting.

13.3 Managing Cookies

You can control cookies through your browser settings. Disabling essential cookies may affect the ability to log into a Customer dashboard or complete a verification session.

13.4 Do Not Track

We do not currently respond to browser "Do Not Track" signals.

14. Third-Party Services

The Service relies on the following categories of third-party providers, each governed by its own privacy policy. The current, specific list is published at zerotrust.entrinsia.com/subprocessors.

Cloud infrastructure and AI processing: Amazon Web Services, https://aws.amazon.com/privacy/. As described in Section 2.4, our agreements with cloud AI subprocessors used for document authentication, liveness detection, and facial comparison require that End User ID images, video selfies, and biometric data be processed only in memory or in transit to generate a result for us, and prohibit these subprocessors from independently retaining that data or using it to train or improve their own models or services.
Payment processing and marketplace billing: AWS Marketplace and our direct payment processor
Email and support tools: used to communicate with Business Customers

We are not responsible for the privacy practices of third-party websites linked from our site, and encourage you to review their policies independently.

15. International Use

Data is primarily processed on infrastructure located in the United States. By using the Service, you consent to the transfer and processing of information in the United States and any other country where our service providers operate, subject to the safeguards described in Section 11.2. If you access the Service from outside the United States, you are responsible for compliance with applicable local laws, including any local consent requirements for biometric or ID data collection.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. Material changes will be communicated to Business Customers via email or dashboard notice, and a new version with a new effective date will be published. Where a change would materially reduce the protections applying to End User data, we will give Business Customers at least 30 days' notice before it takes effect. Continued use of the Service after changes take effect constitutes acceptance of the revised policy.

17. Limitation Regarding This Policy

This Privacy Policy describes our data handling practices and is not, by itself, a guarantee of any particular legal compliance outcome for a Business Customer's use of the Service. Business Customers are solely responsible for determining whether their use of ZeroTrust satisfies the requirements of laws applicable to their business, including but not limited to state age-verification statutes, the CCPA, the GDPR, and biometric privacy laws, for obtaining any consents required from their own End Users beyond the in-flow notice described in Section 9.3, and for their own retention and use of any data ZeroTrust returns to them. Nothing in this Policy constitutes legal advice.

18. Contact Us

Email: support@entrinsia.com

Subject lines for specific requests:

General privacy inquiry — "Privacy Inquiry"
CCPA request — "CCPA Request"
GDPR request — "GDPR Request"
Data deletion — "Data Deletion Request"

Mail: Entrinsia Inc. Attn: Privacy Officer 559 S El Monte Ave Los Altos, CA 94022

Response time: we aim to respond within 30 days, or as required by applicable law.

Revision History

Every published version of this document remains available at zerotrust.entrinsia.com/privacy-policy/<version>.

Version	Effective	Summary of changes
`2026-10-01`	October 1, 2026	First published version.

This policy applies specifically to ZeroTrust. Other Entrinsia products, such as MementoBook, are governed by their own privacy policies.