Legal

Privacy Policy

Last updated July 04, 2026

This Privacy Notice for ZP Tracking Pty Ltd (“we”, “us”, or “our”) describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

• Download and use our mobile application (delt), or any other application of ours that links to this Privacy Notice.
• Use delt. delt is a mobile application for iOS that helps individuals track, analyze, and reflect on their personal gambling and betting activity. It is a personal record-keeping, analytics, and social tool — it is not a gambling operator, sportsbook, or casino, and it does not accept, place, process, or settle real-money wagers. Users manually log (or import the details of) bets and gaming sessions they have made elsewhere; the App stores those records and turns them into statistics, trends, and behavioral insights.
• Engage with us in other related ways, including any marketing or events.

The Service is organized into the following areas:

• Activity tracking. Users record individual wagers (single bets and multi-leg parlays) across categories such as sports, poker, blackjack, slots, table games, and racing — capturing details like stake, odds, potential payout, the book or venue, the event, free-text notes, and the eventual outcome. Users can also run live casino “sessions,” logging buy-ins over time and a final cash-out so the App can compute their net result and time played. Some bets may be associated with real upcoming sporting fixtures so results can be referenced against publicly available scores.
• Analytics and insights. From a user’s own recorded activity, the App derives profit/loss over selectable time periods, category-level performance, session statistics, equity curves, variance estimates, “what-if” counterfactuals, a personalized period-in-review (“Wrapped”) summary, behavioral archetypes, and discipline scores. These analytics are generated from the user’s own data and are intended for self-awareness and entertainment, not as financial or betting advice.
• Group sessions. Users who belong to a shared group chat can run a multi-user live session together: members “check in” with their buy-ins, a shared ledger tracks who added money and when, members can record money lent between each other during play, and at the end the App produces a results leaderboard and a “who owes whom” settle-up summary. The App records these amounts and any settle-up payments members log; it does not move, hold, or process any actual money — all real-world payment happens outside the App.
• Social and community features. Users can create a profile (display name, username, optional bio and profile photo), choose whether it is public or private, follow other users, and exchange direct messages and group chats (including text, photos, and shared bet/session cards). The App includes community spaces such as forums and posts, message reactions, and read indicators, along with safety controls including blocking other users and reporting content for moderation.
• Responsible-gambling tools. The App offers optional features intended to support healthier habits, such as self-exclusion / cooldown breaks, spending or loss limits and prompts, and a “discreet mode” that hides monetary figures on screen.
• Notifications. With the user’s permission, the App sends push notifications (for example, new chat messages, group-session activity, or live-session reminders) and may surface live, on-device activity indicators for in-progress sessions.
• Eligibility. The Service is intended only for adults who are of legal gambling age in their jurisdiction and is not directed to children.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at admin@zptracking.com.

Summary of key points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your information?
4. When and with whom do we share your personal information?
5. Do we use cookies and other tracking technologies?
6. Do we offer artificial intelligence-based products?
7. How do we handle your social logins?
8. Is your information transferred internationally?
9. How long do we keep your information?
10. How do we keep your information safe?
11. Do we collect information from minors?
12. What are your privacy rights?
13. Controls for do-not-track features
14. Do United States residents have specific privacy rights?
15. Do other regions have specific privacy rights?
16. Do we make updates to this notice?
17. How can you contact us about this notice?
18. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• usernames
• passwords
• contact or authentication data
• contact preferences
• profile photos and other user-generated content
• betting and gambling activity records
• casino session records
• group-session financial records
• messages and user-generated content
• preferences and settings

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• financial data
• precise geolocation

Payment Data. In-app purchases are processed by Apple (App Store in-app purchases) and Google (Google Play Billing). We do not collect or store your payment card or bank details; we receive only transaction receipts, purchase history, and subscription status to provide and manage your purchases. You may find their privacy notices here: apple.com/legal/privacy and policies.google.com/privacy.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called “How do we handle your social logins?” below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device to provide certain location-based services. You can change our access or permissions in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your camera, storage, notifications, and other features. You can change our access or permissions in your device’s settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). You can opt out in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. Like many businesses, we also collect information through cookies and similar technologies.

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
• To keep our community safe. We review reported content and enforce community guidelines to protect users from abuse and harassment.

3. What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests — for example, to analyse how our Services are used, diagnose problems, prevent fraud, improve user experience, and protect our users from harm and maintain a safe, trustworthy community.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, this section applies to you. We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent.

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. The categories of third parties we may share personal information with include:

• AI Service Providers — Anthropic and Google Cloud AI
• Cloud Computing Services — Supabase
• Functionality and Infrastructure Optimisation — Expo
• User Account Registration and Authentication — Supabase and Google Sign-In
• Web and Mobile Analytics — PostHog

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API).
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice.
• Other Users. When you share personal information or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. Other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

5. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising. To the extent these technologies are deemed a “sale”/“sharing” under applicable US state laws, you can opt out as described under “Do United States residents have specific privacy rights?”

6. Do we offer artificial intelligence-based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). We provide the AI Products through third-party service providers (“AI Service Providers”), including Anthropic and Google Cloud AI. Your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products.

Our AI Products are designed for the following functions:

• AI insights
• AI predictive analytics
• Image analysis
• Text analysis

All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreement with third parties. To opt out, you can log in to your account settings and update your user account, or contact us using the contact information provided.

7. How do we handle your social logins?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider — often your name, email address, friends list, and profile picture. We will use the information we receive only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, other uses of your personal information by your third-party social media provider.

8. Is your information transferred internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Australia and the United States. If you are accessing our Services from outside these countries, please be aware that your information may be transferred to, stored by, and processed by us and the third parties with whom we share your personal information, in Australia, the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, these countries may not necessarily have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law, including using the European Commission’s Standard Contractual Clauses for transfers of personal information. Our Standard Contractual Clauses can be provided upon request.

9. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible, securely store your personal information and isolate it from any further processing until deletion is possible.

10. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at admin@zptracking.com.

12. What are your privacy rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. You can make such a request by contacting us using the contact details provided in the section “How can you contact us about this notice?” below.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. If you have questions or comments about your privacy rights, you may email us at admin@zptracking.com.

13. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. California law requires us to let you know how we respond to web browser DNT signals; because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

14. Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

We only collect sensitive personal information, as defined by applicable privacy laws, for the purposes allowed by law or with your consent. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you. We will use and retain the collected personal information as needed to provide the Services or, for each category, as long as the user has an account with us.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. These rights include the right to know whether or not we are processing your personal data, the right to access your personal data, the right to correct inaccuracies, the right to request deletion, the right to obtain a copy of the personal data you previously shared with us, the right to non-discrimination for exercising your rights, and the right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at admin@zptracking.com, or by referring to the contact details at the bottom of this document. We will only use personal information provided in your request to verify your identity or authority to make the request.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at admin@zptracking.com. If your appeal is denied, you may submit a complaint to your state attorney general.

15. Do other regions have specific privacy rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act). This Privacy Notice satisfies the notice requirements defined in both Privacy Acts. At any time, you have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New Zealand Privacy Commissioner.

16. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

17. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at admin@zptracking.com or contact us by post at:

ZP Tracking Pty Ltd

18. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at admin@zptracking.com.