Privacy Policy

Last Updated: September 2025

Zen File Manager (“the App”) is developed by Hatpeon and published under COMSON (HONG KONG) ELECTRONIC TECHNOLOGY CO., LIMITED (“we,” “our,” or “us”).

This Privacy Policy explains in detail what information we collect, why we collect it, how we use it, and what rights you have regarding your personal data. We are committed to protecting your privacy and complying with applicable laws, including:

- General Data Protection Regulation (GDPR – EU/EEA users)

- California Consumer Privacy Act (CCPA – California, USA)

- Virginia Consumer Data Protection Act (VCDPA – Virginia, USA)

- Lei Geral de Proteção de Dados (LGPD – Brazil)

1. Information We Collect and Why

Storage and File Data

• Permissions Used:

  • MANAGE_EXTERNAL_STORAGE

  • READ_EXTERNAL_STORAGE

  • WRITE_EXTERNAL_STORAGE

• Purpose: To enable file management functions such as browsing, organizing, moving, copying, renaming, and deleting files.

• Processing: We may analyze file types (e.g., images, videos, documents, audio, APKs, large files, duplicate files) for categorization.

• We may analyze file types (e.g., images, videos, documents, audio, APKs, large files, duplicate files) for categorization and management.

• Note: We do not upload or transfer your personal file contents. Only metadata (file size, type, storage location) is processed locally.

Installed Applications Data

• We collect the list of installed apps to support features like uninstalling apps and checking storage usage.

• Purpose: To provide app management functionality and help you optimize device storage.

Device Information

• Includes device model, operating system version, device identifier, and Advertising ID(com.google.android.gms.permission.AD_ID).

• Purpose: For analytics, app optimization, and delivering relevant ads.

Usage and Interaction Data

• Includes actions taken within the App (e.g., opened modules, buttons clicked, frequency of feature use).

• Purpose: To improve usability and prioritize useful features.

Crash Reports and Diagnostics

• Includes technical logs, stack traces, error codes, and crash events.

• Purpose: To fix bugs, improve reliability, and maintain performance.

2. How We Use Your Data

• To provide core file and app management functions.

• To optimize app performance and user experience

• To deliver personalized or contextual ads (with your consent where required).

• To comply with applicable legal obligations.

We never sell or trade your personal data.

3. Data Sharing with Third Parties

We integrate third-party advertising SDKs for monetization. These partners may collect identifiers such as Advertising ID, IP address, and technical device data:

• Applovin 

• Google AdMob 

• Fyber

• InMobi 

• IronSource 

• Vungle 

• Facebook Audience Network 

• Mintegral 

• ByteDance (TikTok Ads) 

• Bigo Ads 

• Pangle 

Each third party processes data under its own Privacy Policy. You can review their policies to understand how they manage your data.

Important:

• We do not sell personal data under CCPA/CPRA definitions.

• Some SDKs may qualify as “sharing” for targeted advertising purposes.

4. Data Retention

• File metadata and storage stats are processed locally and not retained.

• Analytics, ads, and crash data are stored for up to 90 days before automatic deletion.

• After retention periods, data is permanently removed.

5. Security Measures

We take reasonable measures to protect your information, including:

• Restricting internal access to authorized staff only.

• Transmitting analytics data over secure channels.

• Removing personally identifiable information from diagnostic logs.

However, no method of transmission or storage is 100% secure.

6. Your Privacy Rights

Depending on where you live, you may have the following rights:

Under GDPR (EU/EEA users)

• Right of Access – Request details of the data we collect.

• Right to Rectification – Correct inaccurate or incomplete data.

• Right to Erasure (“Right to be Forgotten”) – Request deletion of personal data.

• Right to Restrict Processing – Ask us to limit processing in certain cases.

• Right to Data Portability – Request a copy of your data in a portable format.

• Right to Object – Opt-out of certain processing, including personalized ads.

• Right to Lodge a Complaint – File a complaint with your local Data Protection Authority.

Under CCPA/CPRA (California, USA)

• Right to Know – What personal data we collect, use, share, or sell.

• Right to Delete – Request deletion of your personal information.

• Right to Correct – Fix inaccurate information.

• Right to Opt-Out – Stop the “sale” or “sharing” of personal data.

• Right to Non-Discrimination – You won’t face discrimination for exercising your rights.

Under VCDPA (Virginia, USA)

Rights similar to GDPR/CCPA, including access, correction, deletion, data portability, and the right to opt-out of targeted advertising.

Under LGPD (Brazil)

• Right to Confirm Processing – Verify whether we process your data.

• Right of Access – Request access to your data.

• Right to Rectification – Correct incomplete or inaccurate data.

• Right to Anonymization, Blocking, or Deletion – Remove unnecessary or excessive data.

• Right to Portability – Transfer your data to another provider.

• Right to Revoke Consent – Withdraw your consent at any time.

7. How to Exercise Your Rights

You may exercise your rights by contacting us via email: hatpeon@gmail.com.

For ad personalization, you can also opt out via your device settings:

Settings > Google > Ads > Opt out of Ads Personalization

8. Children’s Privacy

• The App is not intended for children under 13.

• We do not knowingly collect personal data from children.

• If such data is discovered, it will be deleted immediately.

9. Legal Basis for Processing (GDPR)

We rely on the following legal bases:

• Contractual necessity – To provide file management services.

• Legitimate interest – For app improvement, analytics, and crash reporting.

• Consent – For personalized advertising and certain third-party data use.

• Legal obligation – Where required by law.

10. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted inside the App or on our official distribusion channels. We encourage you to review it regularly.

11. Contact Us

Data Controller: COMSON(HK) ELECTRONIC TECHNOLOGY CO., LIMITED

DPO: Kelvin Wong

Email: hatpeon@gmail.com

If you believe your rights are not respected, you also have the right to lodge a complaint with your local Data Protection Authority or relevant regulatory authority.