Effective date: October 6, 2026
Website: https://www.echozero.io
Operating Entity: Zero Group LLC (doing business as ECHOZERO)
Principal Office: 2050 North Tustin St. #1120, Orange, CA 92865, United States
Data Protection Contact: Michael Ridolfi (contact@echozero.io)
Zero Group LLC ("Company," "we," "us," or "our"), doing business as ECHOZERO, operates the website and media platform at https://www.echozero.io. We provide digital memberships, video releases, a members’ feed, limited-run physical collectible drops for subscribers on the qualifying tiers, and an email newsletter that you can receive without creating an account.
This Privacy Policy explains what personal data we collect, why we collect it, who we share it with, and what rights you have. It is written to meet the EU General Data Protection Regulation (GDPR), the UK GDPR, and the California Consumer Privacy Act as amended by the CPRA.
1. Information We Collect
We collect only what is needed to run your account, take payment, deliver the benefits of your tier, keep the service secure, and count, in aggregate, how the site is used.
- Account and identity information (all members): an email address, a public display handle of your choosing, an optional profile picture, and a unique account identifier. Authentication is delegated to Clerk; we never receive or store your password. We do not ask for your legal first or last name when you register. If you sign in with a Google account, Google shares your name, email address and profile picture with Clerk: the picture may become your profile picture until you change it, your first name may be used to greet you in the welcome email and is shown beside your comments only if your account has no handle, and your last name is never shown. You may also add a phone number to your profile. Clerk keeps a record of your sign-ins and active sessions, including the device, browser and IP address used.
- Content you post: comments you write, which are shown with your handle, your profile picture and the time they were posted to everyone who can read the post, and hearts you leave on posts and comments, which are shown only as a count. You can edit your own comments, and an edited comment is marked as edited, with how long ago it was changed. If you report another member’s comment, we store that report, its category, and any reason you give. A report also keeps a copy of the comment’s words as they stood when it was reported, so that editing a reported comment does not change what we review.
- Communication preferences: which kinds of email you have switched on or off. Every kind starts switched on when you create an account, unless you had already unsubscribed from our newsletter (see below). The unsubscribe links in the emails we send to account holders carry a signed token that names your account and the kind of email, so that one click is enough. The newsletter confirmation link carries your address in encrypted form and stops working after a week. Neither is a cookie, and neither is used to track you.
- Complimentary memberships: we may give a member free access to a paid tier, for example to a collaborator or a family member. Where we do, your account carries a note that the membership is complimentary, the date it was granted, and a short reason written by us. That note is part of your account record: it appears in the copy of your data that you can download, and we write it knowing that you can read it.
- Newsletter subscribers without an account: if you subscribe to the newsletter from the homepage, we email you a confirmation link, and nothing is added to the list until you press it. Until then we keep no copy of your address ourselves: it travels inside the link, encrypted, and our email provider keeps its usual record of the confirmation email it delivered. Once you confirm, our email provider holds your address on the newsletter list, together with whether you have unsubscribed. To stop the form being used to send unwanted mail, our server counts the confirmation emails requested for each address over an hour, using a one-way hash of the address that is held only in its memory and never written to storage. If you later create an account with the same address, your choice carries over: if you were subscribed, you stay on the list and the Newsletter setting in your account controls it from then on; if you had unsubscribed, the list entry is deleted and your new account starts with every email switched off.
- Shipping information (physical-drop tiers): recipient name, street address, city, state or province, postal code, country, and a phone number. Checkout asks for all of these when you join a tier that receives physical drops, and you can change them on the Shipping page of your account, where the phone number is optional. This is held on your customer record at Stripe, which is our system of record for shipping addresses; if no shipping address is held there, the billing address on that record is used for a parcel instead. It stays on that record if you move to a tier without physical drops. When the shipping list for a drop is prepared, a copy of the address, with the recipient’s name, phone number and email address, is stored with that parcel’s record so that the label matches what you entered, for the period described in Section 6.
- Payment information: payments are processed by Stripe, a PCI-DSS Level 1 certified provider. Card numbers never reach our servers and we do not store them. What we hold on our own systems is limited to your Stripe customer and subscription identifiers, your current tier, your subscription status, its renewal date, and any scheduled change of tier or cancellation. A member with a complimentary membership also has a Stripe customer record, so that a shipping address can be held for them, and it is never charged. A new record carries no payment method; if you paid us before, your existing record is reused as it is, including any card saved on it.
- Technical data: our hosting provider, Vercel, records standard server information including IP address, browser and device information, request headers, timestamps, and error logs, which we use to keep the service available and secure. Our servers also count requests from each IP address for a minute at a time, in memory only, to stop abuse. Our own application logs are written to leave out your full email address; where one has to be identified, it is shortened to its first letter and domain.
- Visit statistics: the pages you view on the public site, the page you arrived from, your browser, operating system and device type, and an approximate location (country, region and city), collected through Vercel Web Analytics without cookies, not linked to your account, and seen by us only as totals (see Section 2).
- Messages you send us: if you use the contact form we receive the name, email address, and message you provide, so that we can reply. The message is emailed to our inbox through our email provider and is not stored on the site.
We do not collect special category data as defined by Article 9 of the GDPR, and we ask you not to include any in comments or messages.
2. Cookies and Similar Technologies
We use strictly necessary cookies only. To count visits we use Vercel Web Analytics, which sets no cookies (see “Visit statistics” below). There is no advertising technology anywhere on this site: no tag manager, no advertising or social media pixels, and no cross-site or cross-device tracking by us or on our behalf. We do not build profiles of visitors and we do not track you across other websites. Fonts and our own scripts, including the visit statistics script, are served from our own domain. If the site uses a logo or font file that we uploaded ourselves, your browser loads that file from our hosting provider’s file storage, Vercel Blob. Our authentication provider, Clerk, loads its script on every page from clerk.echozero.io, a subdomain that Clerk operates for us behind Cloudflare’s network, so Clerk and Cloudflare receive your IP address and browser details when a page loads. When you sign up, Clerk may also run a Cloudflare check that tells people from automated sign-ups. Clerk’s usage telemetry is switched off, so your browser sends it no usage statistics.
Because every cookie we set is strictly necessary to deliver a service you have asked for, none of them requires your consent under the ePrivacy Directive or the GDPR, and we therefore do not show a cookie consent banner. Our visit statistics set no cookies and store nothing on your device. The cookies in use are:
- Authentication cookies (Clerk): Clerk, and the Cloudflare network in front of Clerk’s service, may set small cookies for every visitor, signed in or not, that record whether you are signed in and screen out automated traffic (for example Cloudflare’s __cf_bm, which lasts 30 minutes). When you sign in, Clerk sets further cookies that keep you signed in and protect against cross-site request forgery. Removing them signs you out.
- Payment cookies (Stripe): set only if you proceed to checkout or the billing portal, to process the payment and to detect fraud.
- Administrative cookies: set only for site administrators. One, cleared when the browser closes, lets them preview the site as a member of a given tier would see it; the other, kept for a year, remembers whether the administrative sidebar is folded. They are never set for members or visitors.
Visit statistics: we use Vercel Web Analytics, provided by our hosting company, to count page views and visitors. It sets no cookies and stores nothing on your device. When a page loads, a small script served from our own domain sends Vercel the page’s address, the page you arrived from, and the time. Vercel adds your browser, operating system, device type, and an approximate location (country, region and city) worked out from your IP address; the IP address itself is not kept with the page view. Vercel tells visitors apart with a code computed from the request and discards it after 24 hours. We do not count visits to your account pages, the administrative area, or the unsubscribe and newsletter confirmation pages, and before anything is sent we remove everything after the “?” in a page address except campaign tags (such as utm_source). We see only totals, never individual visits, and nothing is linked to your account.
Embedded video: some posts include a video played through YouTube’s embedded player, part of YouTube API Services. Until you press play, the post shows a still image served through our own servers, and nothing about you is sent to Google; video thumbnails in the feed are served the same way. When you press play, the player loads in privacy-enhanced mode (youtube-nocookie.com) and the video starts at once. From that moment Google receives your IP address, information about your browser and device, and information about your viewing, and the player may store information on your device, all under the Google Privacy Policy. If you follow a link from the player to YouTube itself, YouTube’s own terms and policies apply. If JavaScript is turned off in your browser, the player loads with the page instead.
3. Lawful Bases for Processing (GDPR Article 6)
We process personal data only where one of the following applies:
- Performance of a contract (Art. 6(1)(b)): creating and maintaining your account, sending account emails such as the welcome email, taking subscription payments, giving you access to the content your tier includes, and producing and posting physical drops, including a final parcel to a member whose membership has recently ended. A complimentary membership is treated the same way, as the arrangement under which we provide the tier to you.
- Legal obligation (Art. 6(1)(c)): retaining invoices, sales tax records, and transaction records to satisfy accounting, IRS, and California Department of Tax and Fee Administration requirements.
- Legitimate interests (Art. 6(1)(f)): keeping the service secure and available; preventing fraud, abuse, spam, and automated attacks; moderating comments so the community remains usable; counting visits and page views, in aggregate, to understand which parts of the site are read; loading the YouTube player when you press play on a video; emailing account holders about new posts, drops and parcels, and sending them the newsletter, each of which is switched on when you create an account and can be switched off at any time in your account’s notification settings or with the unsubscribe link in any such email; and keeping a record of administrative actions such as an export of the member list, and alerting the site administrator when they happen. You may object to processing on this basis at any time (see Section 7).
- Consent (Art. 6(1)(a)): the newsletter for people without an account. Newsletter subscriptions taken without an account are confirmed by double opt-in: we email you a link, and nothing is sent until you press it. You may withdraw consent at any time, from the unsubscribe link in any newsletter, and withdrawing it does not affect processing carried out beforehand.
4. Service Providers and Sub-Processors
We do not sell, rent, trade, or share your personal data for advertising, and we have never done so. We share the minimum necessary with the following providers. Google (YouTube), the postal carriers and, for its own fraud prevention and legal obligations, Stripe decide for themselves how they use what they receive, under their own privacy policies.
Sub-Processor | Function | Data Shared | Location and Safeguards |
|---|---|---|---|
Clerk | Authentication and identity management | Email address, display handle, profile picture, phone number if you add one, the name Google provides if you sign in with Google, sign-in and session records (including IP address and browser), email preferences, membership tier and status, complimentary membership note. Clerk’s service runs behind Cloudflare, which receives every visitor’s IP address and browser details | USA / Standard Contractual Clauses |
Vercel | Application hosting, edge network, and visit statistics (Web Analytics) | IP address, request headers, server and error logs (our own log lines are written to leave out full email addresses); for visit statistics, the page address, referring page, browser, operating system, device type and approximate location, collected without cookies | USA / EU-U.S. Data Privacy Framework |
Vercel Blob | Storage for images published on the site, and for logo and font files we upload | Uploaded image, logo and font files; when your browser loads an uploaded logo or font, your IP address and browser details | USA / EU-U.S. Data Privacy Framework |
Neon | PostgreSQL database | Account identifier, comments, hearts and reports, and fulfilment records: the tier a parcel was sent under, your membership start date, and the name, address, phone number and email address it was sent to | USA / SCCs, encrypted in transit and at rest |
Stripe | Subscription billing, payment processing, and system of record for shipping addresses | Name, email address, shipping and billing address, phone number, payment method, customer and subscription identifiers, and your account identifier. For complimentary members: name, email address and shipping address; a new record carries no payment method, and a former paying member’s existing record is reused as it is | USA / PCI-DSS Level 1, SCCs |
Resend | Transactional and notification email, and the newsletter list | Email address, message content, delivery events; for the newsletter, the address of each subscriber (including account holders who receive it) and whether it has unsubscribed | USA / SCCs |
Google Workspace | Our email inbox (contact@echozero.io) | Messages you send us through the contact form or by email, and our replies | USA / EU-U.S. Data Privacy Framework |
Pirate Ship | Shipping label generation for physical drops | Recipient name, mailing address, phone number and email address where held, tier, packing note, and shipment reference | USA / SCCs |
Postal carriers (USPS, UPS, FedEx, DHL) | Delivery of physical drops | Recipient name, mailing address, phone number where held, tracking details | Destination country postal services |
Google (YouTube) | Video playback when you press play, in privacy-enhanced mode. Google acts on its own behalf, under the Google Privacy Policy | IP address, browser and device information, and information about your viewing, from the moment you press play (or when a page with a video loads, if JavaScript is turned off) | USA / EU-U.S. Data Privacy Framework |
Internal use of the member list: to prepare physical drops and to understand the membership, the site administrator can export a list of members from the administrative area. For each member it holds their handle, email address, phone number, first name where a sign-in provider supplied one, account and Stripe customer identifiers, tier, subscription dates and status, whether the membership is complimentary and the reason, amount paid to date and number of months paid, the shipping address held at Stripe (or, where there is none, the billing address) and whether it is complete, and how many drops they have received and the most recent one. Each export of this list, and of a drop’s shipping list, is recorded, and the administrator is emailed when one happens. The member list is used only by us for those purposes and is not shared with anyone; a drop’s shipping list goes to Pirate Ship, as described above.
We may also disclose personal data where we are legally required to do so, or where it is necessary to establish, exercise, or defend legal claims.
5. International Data Transfers
Zero Group LLC operates in the United States. If you use the service from the European Economic Area, the United Kingdom, or Switzerland, your personal data will be transferred to and processed in the United States.
Where a provider is certified under the EU-U.S. Data Privacy Framework (and its UK Extension or the Swiss-U.S. Data Privacy Framework), transfers to it rely on the adequacy decision for that framework (Article 45 of the GDPR). Otherwise they are made under the European Commission’s Standard Contractual Clauses (Article 46). You may request a copy of the relevant safeguards by writing to contact@echozero.io.
6. Data Retention
We keep personal data only as long as we need it:
- Account and profile records: for as long as your account exists. When you delete your account, your profile is deleted from Clerk, any subscription you hold is cancelled immediately, and any complimentary membership ends. Your comments, hearts and the reports you filed are deleted from our database; a comment that has replies under it is instead kept as an empty placeholder with no link to you, so that the replies still make sense, and any reports about it are deleted. Parcels not yet sent to you are cancelled, and every stored copy of your address is removed from our parcel records. Your billing address, shipping address (including the recipient name) and phone number are cleared from every Stripe customer record linked to your account, and your email address is removed from the newsletter list. The Stripe customer record itself, with its name and email address, is kept alongside the invoices described below.
- Complimentary membership notes: for as long as the complimentary membership lasts. The note is removed when the membership ends or when a paid subscription replaces it. Your Stripe customer record keeps a marker that it was used for a complimentary membership.
- Parcel records: when the shipping list for a drop is prepared, a copy of each recipient’s address is stored with that parcel’s record. Once a parcel has been dispatched, the copy is kept for 180 days, long enough to resolve a lost parcel, a carrier claim, or a payment dispute, and is removed once that period has passed. A copy taken for a parcel that was never sent is removed once that parcel is cancelled or its drop is finished, and once 180 days have passed both since the copy was taken and since the drop’s last parcel was sent. If you delete your account, every copy is removed at once, whether or not the 180 days have passed. The record of each parcel (which drop, which tier, when your membership began, when it was sent, the carrier and tracking number, and the account it was sent to) is kept without the address.
- Newsletter list: an address stays on the list until it is taken off. If you unsubscribe using the link in a newsletter, the address is kept on the list marked as unsubscribed, so that we never email it again by mistake. If you switch the newsletter off in your account settings, or delete your account, the address is removed from the list. If you create an account after unsubscribing, the old entry is removed and your account starts with every email switched off.
- Commercial and tax records: invoices and transaction records held by Stripe are retained for up to seven years to meet statutory tax and audit requirements. These are records of transactions that took place and are not deleted on request.
- Technical logs: retained by our hosting provider under its own retention schedule, which is short, and not archived by us.
- Visit statistics: the code Vercel uses to tell visitors apart is discarded after 24 hours. The page-view records, which carry no IP address and nothing that links them to your account, are kept available to us for the reporting period of our hosting plan (no more than 12 months), and Vercel may hold them longer on its own systems.
- Messages you send us: kept in our email inbox for as long as we need them to answer you and deal with any follow-up.
- Comments and hearts: until you remove them or delete your account. A comment hidden after reports or by a moderator, or marked as removed by a moderator, is kept out of sight with its words until a moderator restores it or deletes it for good, or until you delete your account. Reports you file are kept no longer than your account, and the copy of a comment’s words that a report keeps is deleted with the comment.
7. Your Rights
If you are in the EEA or the UK, you have the following rights over your personal data. Residents of other jurisdictions, including California, may hold equivalent rights (see Section 8).
- Access (Art. 15): confirmation of whether we hold data about you, and a copy of it.
- Rectification (Art. 16): correction of data that is inaccurate or incomplete.
- Erasure (Art. 17): deletion of your data where we no longer have grounds to keep it.
- Restriction (Art. 18): suspension of processing in certain circumstances.
- Portability (Art. 20): a copy of the data you gave us, in a structured, machine-readable format.
- Objection (Art. 21): objection to processing carried out on the basis of our legitimate interests.
- Withdrawal of consent (Art. 7(3)): withdrawal of any consent you have given, at any time.
- Complaint: the right to complain to a supervisory authority in your country, or to the UK Information Commissioner’s Office.
Two of these you can exercise yourself, immediately and without asking us. Your account settings include a button that downloads your data as a single structured file (JSON): your account details, membership and email preferences, your comments, hearts and reports, your parcels, and the billing and shipping details Stripe holds for you. This answers the right to data portability, and most of what the right of access covers. Invoices and card details are not in the file; you can see them in the billing portal. There is also a delete option that removes your account, cancels any subscription immediately, and erases the data described in Section 6. Visit statistics are not linked to you, so we cannot find your visits in them to give you a copy or to erase them.
For anything else, email contact@echozero.io. We will verify your identity and respond within one month, as required by Article 12(3), and will tell you if we need to extend that period.
We do not carry out automated decision-making or profiling that produces legal or similarly significant effects, within the meaning of Article 22.
8. California Privacy Rights
If you are a California resident, the CCPA as amended by the CPRA gives you the right to know what personal information we collect and how we use and disclose it, the right to request deletion, the right to request correction, and the right not to be discriminated against for exercising those rights.
We do not sell personal information, and we do not share it for cross-context behavioral advertising, as those terms are defined by the CCPA. We have not done so in the preceding twelve months. Because we do not, we do not offer a “Do Not Sell or Share My Personal Information” link.
Other companies: when you pay, Stripe collects information on its own checkout and billing pages, and when you press play on a video, Google collects information through the YouTube player, each under its own privacy policy, which may cover your activity on other websites and services. No advertising or analytics company collects information about your activity on this site for use on other websites. Do Not Track: we do not track you across other websites. Our site does not respond to Do Not Track signals; the visit statistics described in Section 2 are collected whether or not your browser sends one.
The categories of personal information we collect are set out in Section 1, the purposes in Sections 1 and 3, the categories of recipients in Section 4, and our retention periods in Section 6. To exercise a California right, use the download and delete controls in your account settings or email contact@echozero.io.
9. Children
This service is not directed to children. You must be at least 16 years old to create an account. If you are under the age of majority where you live, you may only subscribe with the involvement of a parent or legal guardian who accepts our Terms of Service and is responsible for payment.
We do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, email contact@echozero.io and we will delete it.
10. Security
We maintain technical and organizational measures appropriate to the data we hold, including:
- HTTPS with HTTP Strict Transport Security across the whole site.
- Encryption of data in transit and at rest in our database.
- Authentication delegated to Clerk, so that we never receive or store passwords.
- Card data handled entirely by Stripe and never transmitted to or stored on our servers.
- A Content Security Policy, renewed on every page load, and framing protections that prevent the site being embedded and used to trick you into actions you did not intend.
- Rate limiting on our data endpoints and on the contact and newsletter forms, except the notifications our payment and identity providers send us, which are verified by signature instead.
- Email addresses masked in our application logs, so they are not duplicated into systems that do not need them.
- Uploaded files validated by inspecting their contents rather than trusting the file name.
- Administrative areas that are not discoverable and are unavailable to anyone who is not an administrator.
- An email to the site administrator whenever the member list or a drop’s shipping list is exported, a complimentary membership is granted or withdrawn, the site is closed or reopened for maintenance, or our payment or identity providers report a delivery that could not be verified, so that misuse of an administrator account is noticed quickly.
- Spreadsheet files exported from the administrative area are written so that their contents cannot run as formulas when opened. The copy of your data that you can download is a plain JSON text file.
No system is perfectly secure. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours where required by Article 33, and notify you where Article 34 requires it.
11. Changes to This Policy
We may update this policy as the service changes or the law requires. The effective date at the top always reflects the current version. Where a change materially affects your rights or how we use your data, we will tell you by email or by a notice on the site before it takes effect.
12. Contact
Data Controller: Zero Group LLC (dba ECHOZERO)
Data Protection Contact: Michael Ridolfi
Email: contact@echozero.io
Address: 2050 North Tustin St. #1120, Orange, CA 92865, United States