Privacy Policy

1. Who We Are

This website is operated by EPAGE LABS LIMITED, a private company limited by shares incorporated in Hong Kong (Company Registration No. 78976978), with its registered office at Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong.

We trade as Zulbera and can be reached at hello@zulbera.com.

2. What Data We Collect

We may collect and process the following personal data:

• Contact information: name, email address, phone number, and company name when you submit our contact form or book a call.
• Usage data: pages visited, time on site, browser type, and device information via Google Analytics (GA4).
• Communication data: the content of messages you send us by email or through forms on this website.

We do not collect sensitive personal data (e.g. health, financial, or biometric data).

3. How We Use Your Data

We use your data to:

• Respond to your enquiries and process service requests.
• Schedule and conduct discovery calls.
• Improve our website and understand visitor behaviour (analytics).
• Send you relevant updates if you have opted in (you may unsubscribe at any time).
• Comply with legal obligations.

4. Legal Basis for Processing (GDPR)

For visitors in the European Economic Area, we process your data under the following legal bases:

• Legitimate interests — for analytics and improving our services.
• Contract performance — when processing data necessary to provide services you have requested.
• Consent — for optional communications and cookies where required.
• Legal obligation — when required by applicable law.

5. Cookies

We use cookies to operate the website and analyse traffic. For full details see our Cookie Policy.

6. Third-Party Services

We use the following third-party services that may process your data:

• Google Analytics (GA4) — website usage analytics. Data may be transferred to the US under Google's standard contractual clauses.
• Cal.com — scheduling calls. Subject to Cal.com's own privacy policy.
• Vercel — website hosting. Server logs may include IP addresses.

We do not sell your personal data to third parties.

7. Data Retention

We retain contact and enquiry data for up to 3 years from last contact, unless a longer retention period is required by law or by an ongoing client relationship. Analytics data is retained per Google's default retention settings (up to 14 months).

8. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate data.
• Request erasure of your data ("right to be forgotten").
• Object to or restrict our processing of your data.
• Request portability of your data.
• Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, email us at hello@zulbera.com. We will respond within 30 days.

9. Data Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. All data in transit is encrypted via TLS.

10. International Transfers

EPAGE LABS LIMITED is incorporated in Hong Kong. If you are located in the EEA, data transferred outside the EEA is done so with appropriate safeguards (standard contractual clauses or adequacy decisions where applicable).

11. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors.

12. Changes to This Policy

We may update this policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the website after changes constitutes acceptance.

13. Contact

For any privacy-related questions or requests:
EPAGE LABS LIMITED (trading as Zulbera)
Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong
Email: hello@zulbera.com