Privacy Policy

Last updated: January 1, 2026

Zooska Network SRL ("Persotests", "we", "us", "our") respects your privacy and is committed to transparency about how we collect, use, disclose and otherwise process personal data when you access or use Persotests.com and any related pages, tests, reports, subscription features, content and services (collectively, the "Services").

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please do not use the Services.

1. Identity and contact details (Controller)
2. Scope of this Privacy Policy
3. What personal data we collect (and from where)
4. How and why we use personal data (purposes)
5. Legal bases (EEA/UK)
6. Disclosures and sharing
7. Cookies and similar technologies
8. Do we sell or share personal data?
9. International transfers
10. Security
11. How long we retain data
12. Your rights and choices
13. Appeals of privacy decisions (where applicable)
14. Children
15. Sensitive data and inferences
16. Do Not Track (DNT) and Global Privacy Control (GPC)
17. Changes to this Privacy Policy
18. Additional notices for U.S. residents (including California)
19. How to contact us

1. Identity and contact details (Data Controller)

For purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR"), Zooska Network SRL is the data controller of your personal data processed through the Services.

Company: Zooska Network SRL
Trade Registry No.: ROONRC.J2009007476403
VAT No.: RO25734886
Registered office: Bd. Agronomiei 7–15, Sector 1, Bucharest, Romania
Email: hello@persotests.com

We have not appointed a Data Protection Officer (DPO). If you have any questions or requests relating to privacy, please contact us using the details above.

2. Scope of this Privacy Policy

This Privacy Policy describes our online and offline privacy practices in connection with: (i) your use of our website and Services, (ii) purchases/subscriptions, and (iii) communications with us.

This Privacy Policy does not apply to third-party websites, apps, or services that may be linked from our Services. Those third parties have their own privacy policies, which you should review.

3. What personal data we collect (and from where)

We collect personal data from three sources: (A) data you provide, (B) data collected automatically, and (C) data from third parties (e.g., payment processors, authentication providers), as applicable. We apply data minimization and collect only what is reasonably necessary for the purposes described in this Privacy Policy.

A) Data you provide directly

Account identifiers: email address, password (stored in hashed form), and account settings/preferences.
Test interaction data: your responses to questions, selections, and generated outputs/reports associated with your account.
Customer support and communications: information you include when you contact us (e.g., messages, attachments you send us).
Checkout data (if provided to us): limited billing details such as name and country; payment card data is typically processed by our payment processor and not stored by us in full.

B) Data collected automatically

• Device and network data: IP address, device type, operating system, browser type, language, time zone, and similar technical identifiers. • Usage data: pages or screens viewed, clicks, referrer URLs, session identifiers, timestamps, and interaction events (e.g., starting a test, completing a test, viewing a report). • Approximate location: inferred from IP address (city/country level). • Cookie and similar technology data: see Section 7.

C) Data from third parties

• Payment processors: transaction status, timestamps, amount, currency, and limited payment metadata (e.g., last four digits of a card where made available). • Authentication providers (if enabled): if you choose social login (e.g., Google/Apple), we may receive basic profile information such as your verified email address, depending on your provider settings. • Analytics/advertising partners (if enabled): device identifiers and event data associated with advertising/analytics cookies (subject to consent where required).

4. How and why we use personal data (purposes)

We process personal data for the following purposes (the "Purposes"):

Provide and operate the Services: create and administer accounts, deliver tests, generate results/reports, provide subscription features, and maintain platform functionality.
Process payments and manage subscriptions: confirm payment status, administer subscription entitlements, handle chargebacks and fraud prevention, and maintain accounting records.
Customer support: respond to inquiries and troubleshoot issues.
Service improvement: analytics, debugging, research and development, and product performance monitoring.
Safety and security: protect the Services, users, and our business from misuse, fraud, or security incidents.
Legal and compliance: comply with applicable laws, enforce our Terms, and protect rights and safety.
Marketing (where permitted): send promotional communications (typically where you have opted in) and measure campaign effectiveness.

5. Legal bases (EEA/UK)

If you are located in the EEA or UK, we process personal data under the following legal bases, as applicable:

Contract: processing necessary to provide the Services you request (including subscriptions).
Legitimate interests: processing necessary for security, fraud prevention, service improvement, and business operations, where our interests are not overridden by your rights.
Consent: where required, for non-essential cookies/trackers and certain marketing communications; and where consent is the appropriate basis under applicable law.
Legal obligation: processing necessary to comply with tax, accounting, and other legal requirements.

Where we rely on consent, you may withdraw it at any time (see Section 12).

6. Disclosures and sharing

We do not sell your personal data in the conventional sense. We may disclose personal data as follows:

Service providers (processors): vendors supporting hosting, storage, content delivery, email delivery, customer support, analytics, security, and payment processing.
Affiliates: if we share data within corporate group entities under common control (if any), for internal business purposes consistent with this Privacy Policy.
Business transfers: in connection with a merger, acquisition, reorganization or sale of assets, subject to appropriate safeguards.
Legal process and protection: to comply with law, respond to lawful requests, protect rights and safety, investigate fraud/security incidents, and enforce agreements.
With your direction or consent: when you ask us to share or otherwise authorize disclosure.

Our service providers are contractually required to process personal data only on our instructions and to implement appropriate security measures.

7. Cookies and similar technologies

We may use cookies, pixels, SDKs, web beacons and similar technologies to: (i) operate the Services, (ii) remember preferences, (iii) perform analytics, and (iv) support advertising/marketing, where enabled.

Where required by law, we ask for your consent for non-essential cookies via a cookie banner/consent management tool. You can also manage cookies through browser settings. Disabling certain cookies may impact functionality.

Strictly necessary cookies: required for core functions (e.g., authentication, security).
Preference cookies: remember settings (e.g., language).
Analytics cookies: help us understand usage and improve performance.
Marketing cookies (if enabled): help measure and improve advertising campaigns and deliver more relevant ads.

8. Do we sell or share personal data?

We do not sell personal data for money. Depending on the use of advertising cookies and similar trackers, we may share certain identifiers and internet/network activity data with advertising partners for targeted advertising in a way that may be considered a "sale" or "sharing" under certain U.S. state privacy laws. Where applicable, you may have the right to opt-out (see Section 18).

We do not knowingly sell or share personal data of minors under 16.

9. International transfers

We may process and store personal data in Romania and in other countries where we or our service providers operate. If we transfer personal data outside the EEA/UK to jurisdictions without an adequacy decision, we rely on appropriate safeguards such as the European Commission Standard Contractual Clauses and supplementary measures as required.

If you have questions about our transfer mechanisms, contact us at hello@persotests.com.

10. Security

We implement reasonable technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access (e.g., access controls, encryption in transit, logging and monitoring, and least-privilege access).

No method of transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your credentials and using a secure environment when accessing the Services.

11. How long we retain data

We retain personal data only for as long as necessary to fulfill the Purposes described in this Privacy Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements.

We consider the following factors in determining retention periods: (a) the duration of our relationship with you and account activity, (b) legal and regulatory obligations (e.g., accounting/tax), and (c) litigation holds, investigations, and statutes of limitation.

Account data and associated test data: retained while your account is active and for a reasonable period thereafter, unless you request deletion (subject to legal exceptions).
Subscription/transaction records: retained as required by applicable accounting and tax laws.
Support communications: retained as needed to handle your request and for a reasonable period after closure.

We may retain aggregated, anonymized or de-identified data for analytics and service improvement where permitted by law.

12. Your rights and choices

Depending on your location, you may have the following rights (some rights are not absolute and may be subject to legal limitations):

Access: request access to the personal data we hold about you.
Rectification: request correction of inaccurate or incomplete data.
Deletion: request deletion of your personal data (subject to legal exceptions).
Restriction: request restriction of processing in certain circumstances.
Objection: object to processing based on legitimate interests.
Portability: receive certain data in a structured, commonly used and machine-readable format.
Withdraw consent: where processing is based on consent, withdraw at any time.
Marketing choices: unsubscribe from marketing emails using the unsubscribe link or by contacting us (we may still send non-marketing messages).

To exercise your rights, contact us at hello@persotests.com. We may need to verify your identity before responding.

EEA/UK complaints

If you are in the EEA/UK, you have the right to lodge a complaint with your local data protection authority. In Romania, the supervisory authority is the National Supervisory Authority for Personal Data Processing (ANSPDCP).

13. Appeals of privacy decisions (where applicable)

Depending on your country or U.S. state of residence, you may have the right to appeal our decision regarding a privacy request. To appeal, contact us at hello@persotests.com with the subject line "Privacy Appeal". We will respond as soon as reasonably possible and within the timeframes required by applicable law.

14. Children

The Services are not intended for children under 16, and we do not knowingly collect personal data from children under 16. If you believe a child has provided us personal data, please contact us at hello@persotests.com and we will take steps to delete it.

If you are a U.S. resident, we also do not knowingly collect personal data from children under 13 and will delete such data if we become aware of it (COPPA).

15. Sensitive data and inferences

We do not intentionally request or require special category (sensitive) data (such as health data, biometric data, political opinions, religious beliefs, sexual orientation, or similar categories) through free-text fields.

However, test responses and outputs may be sensitive to you and, in some cases, may allow inferences about personal aspects. We treat test responses and generated results as confidential and apply safeguards designed to protect them. Please do not submit sensitive information in any optional free-text fields (if any).

We do not use your test responses and results for purposes unrelated to providing the Services (such as selling them to third parties).

16. Do Not Track (DNT) and Global Privacy Control (GPC)

Do Not Track (DNT) is a browser preference that requests that a website not track a user. Our Services do not currently respond to DNT signals.

Where applicable and technically feasible, we will recognize certain global opt-out preference signals, such as the Global Privacy Control (GPC), for opt-out of certain online tracking (see Section 18).

17. Changes to this Privacy Policy

We may update this Privacy Policy when our practices change or as otherwise required or permitted by law. The updated version will be posted on the Services with a new "Last updated" date. Where changes are material, we will take reasonable steps to provide notice (e.g., via email or in-product notice).

18. Additional notices for U.S. residents (including California)

This section applies only to U.S. residents to the extent U.S. state privacy laws apply to our processing of personal information.

A) Categories of personal information (U.S.)

Identifiers (e.g., email address; online identifiers).
Commercial information (e.g., purchase/subscription records).
Internet or other electronic network activity (e.g., browsing and interaction data).
Device/geolocation data (approximate location via IP).
Inferences (e.g., inferences drawn from interactions to improve the Services).

B) Purposes (U.S.)

We use personal information for the business and commercial purposes described in Section 4, including to provide and improve the Services, security, fraud prevention, customer support, and marketing where permitted.

C) Disclosures (U.S.)

We may disclose the categories above to service providers and, where advertising cookies are enabled, to advertising/analytics partners for business or commercial purposes.

D) Your U.S. rights (summary)

• Right to know/access, right to delete, and right to correct (subject to legal limitations). • Right to opt-out of "sale" or "sharing" (targeted advertising) where applicable. • Right to non-discrimination for exercising privacy rights. • Right to use an authorized agent (where applicable), subject to verification.

To exercise these rights, contact us at hello@persotests.com.

E) Shine the Light (California)

California residents may request certain information regarding disclosures of personal information to third parties for their direct marketing purposes, as permitted by California law. Requests can be submitted to hello@persotests.com.

F) Financial incentives

We do not offer financial incentives or price/service differences in exchange for the collection, sale, or deletion of personal information.

19. How to contact us

If you have questions or requests about this Privacy Policy or our privacy practices, contact:

hello@persotests.com

Zooska Network SRL, Bd. Agronomiei 7–15, Sector 1, Bucharest, Romania