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Subscription Policy

SUBSCRIPTION AND RECURRING CHARGES POLICY ROCCIBEL LLC

This Policy shall be governed by the provisions of the Restore Online Shoppers' Confidence Act (ROSCA, 15 U.S.C. § 8403) and the Texas Data Privacy and Security Act (TDPSA), Texas Business & Commerce Code Chapter 601 (SB 838, effective September 1, 2025, governing subscription and auto-renewal contracts), Tex. Bus. & Com. Code Chapter 601A, and other applicable federal and state regulations governing subscription services, recurring charges, and consumer protection.

Effective Date: October 1, 2026

  1. IDENTIFICATION:

This Policy is issued by ROCCIBEL LLC (hereinafter ROCCIBEL), a U.S. company domiciled at 24285 Katy Freeway, Suite 300, Katy, TX 77494, United States, with inquiries email: support@zenttu.com . ROCCIBEL is a company whose main corporate purpose is the marketing and distribution of beauty products and services, including - without limitation - makeup, skincare items, cosmetics, and facial and body treatments, as well as any other aesthetic wellness product it may offer, through its e-commerce platform available at https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version)

ROCCIBEL acts as the Controller of the personal data collected within the framework of the Subscription Program described in this Policy, in accordance with the Texas Data Privacy and Security Act (TDPSA). Technical management of the Subscription Program is carried out by Processors designated under the documented instructions of ROCCIBEL and pursuant to the contractual agreements currently in force between the parties.

This Policy supplements - and must be read together with - the Privacy and Personal Data Security Policy, the Privacy Notice, the Website Terms and Conditions of Use, and the SMS Text Message and Notification Consent Policy of ROCCIBEL, without replacing them.

  1. PURPOSE

The purpose of this Policy is to establish, in a clear, accessible, and legally grounded manner, the conditions under which ROCCIBEL offers its consumers subscription services with recurring charges through the website https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version); the rights available to the Subscriber in connection with the contracting, modification, suspension, and cancellation of such services; the technical security architecture for recurring payments managed through the platform; the administrative communications arising from the subscription relationship; and the obligations that ROCCIBEL assumes with respect to transparency, prior notice before charges, and the processing of personal data in the context of the Subscription Program, with the aim of becoming a benchmark for regulatory compliance in the beauty e-commerce sector.

  1. SCOPE OF APPLICATION

This Policy applies to any natural person who enters into a Subscription Plan offered by ROCCIBEL through the website https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version), and who expressly authorizes the processing of recurring charges under the terms described herein.

From a geographic standpoint, this Policy is primarily directed at Subscribers located in the State of Texas; however, since ROCCIBEL operates in multiple countries and states, Subscribers located in other jurisdictions will additionally be subject to the local regulations applicable to subscription services and recurring charges, which ROCCIBEL will seek to observe in a proportional and reasonable manner, applying in all events, as a minimum standard, the Texas and federal provisions cited herein.

The Subscription Program and the management of the billing-cycle scheduling and associated transactional communications will be operated by Processors, all under the documented instructions of ROCCIBEL as Controller, without this altering ROCCIBEL's liability toward the Subscriber under the terms established in this Policy.

  1. DEFINITIONS

For all purposes of this Policy, the following definitions shall apply:

  • Privacy Notice: A written communication issued by the data controller (Controller), addressed to the data subject with respect to the Processing of their personal data, informing the data subject of the existence of the personal data Processing policies and the information applicable to them, how to access such policies, and the purposes of the intended Processing of personal data.

  • Contact Channels: Channels made available to data subjects for handling requests, inquiries, complaints, and/or communications. These include Electronic Support at support@zenttu.com, and the Mailing Address: 24285 Katy Freeway, Suite 300, Katy, TX 77494, United States.

  • Billing Cycle: The period of time elapsing between one recurring charge and the next, according to the frequency of the Subscription Plan contracted by the Subscriber. At the end of each Billing Cycle, and unless the Subscriber has canceled their subscription in accordance with the procedure set forth in this Policy, the system automatically executes the charge corresponding to the next cycle.

  • Consent: A clear manifestation, through an affirmative act, freely, previously, expressly, and knowingly given by the data subject to authorize the Processing of personal data.

  • Consumer: A natural person residing in the State of Texas, acting solely in a personal or household context.

  • Data Controller: A natural or legal person, public or private, that alone or jointly with others determines the database, purposes, and means of processing personal data. ROCCIBEL acts as Controller with respect to the personal data collected within the framework of the Subscription Program.

  • Customer Portal: An integrated self-service platform through which the Subscriber can independently manage their subscription, including modifying the delivery frequency, the quantity or variant of the product, the shipping address, pausing or skipping cycles, updating the payment method, and canceling the subscription.

  • Personal Data: Any information, including sensitive information, linked or reasonably linkable to an identified or identifiable natural person. In the context of the Subscription Program, this mainly includes full name, email address, shipping address, subscription order history, and the Payment Token associated with the Subscriber's profile, among others.

  • Disclosure, Sharing, and Sale: Any disclosure, communication, copying, or transfer of personal data from one party to another, regardless of the means used. ROCCIBEL will not share SMS Program data with third parties for third-party marketing purposes without the Consumer's express consent.

  • Dunning (Payment Failure Management): An automated process by which the Subscriber is notified of a failure in processing a recurring charge and is provided a secure link to update their payment method, retrying the charge according to the rules configured by ROCCIBEL before proceeding with automatic cancellation of the subscription for non-payment.

  • Magic Link: A unique, temporary, and expiring link sent by email to the Subscriber to access the Customer Portal without needing a password. It constitutes the Subscriber's secure authentication mechanism on the Customer Portal, based on the principles of passwordless authentication recognized by information security standards.

  • Pre-Charge Notification: A transactional communication sent by email to the Subscriber, with three (03) days' advance notice before the automatic charge for the next Billing Cycle is executed, informing the amount, the date, and the payment method to be charged.

  • Subscription Plan: A recurring purchase arrangement offered by ROCCIBEL through the Website, by which the Subscriber authorizes the automatic and recurring charge of a specified amount in each Billing Cycle, in exchange for the periodic delivery of the selected products.

  • Payment Processor: A third party responsible for the technical processing and encryption of the Subscriber's financial data. The Payment Processor stores card data in a secure environment certified under the PCI-DSS standard. The Processor does not have direct access to the Subscriber's financial data, but only to a reference Token.

  • Processor: A natural or legal person that processes personal data on behalf of the Controller, following its instructions and without making decisions of its own regarding the purposes or means of the processing. The Processor is required to comply with the security, confidentiality, and other measures established by the TDPSA, and may only process data as authorized by the Controller. Subscription Program: The recurring-purchase service operated by ROCCIBEL through the designated platform, through which the Subscriber periodically receives the contracted products in exchange for an automatic charge in each Billing Cycle. This is the internal functional designation adopted by ROCCIBEL to identify the whole of its subscription services.

  • Service Provider: Any natural or legal person that processes data on behalf of ROCCIBEL. This refers to third-party companies or individuals engaged by ROCCIBEL to facilitate the Service, to provide the Service on behalf of ROCCIBEL, to perform services related to the Subscription Program, or to help ROCCIBEL analyze how the Service is used.

  • Complaint: Dissatisfaction with the processing of personal data.

  • Charge Retry: An automated additional charge attempt executed following the initial failure of a recurring charge, in accordance with the frequency and retry-count rules configured by ROCCIBEL for the Subscription Program.

  • ROCCIBEL: A legal entity, owner and operator of the Subscription Program, in charge of its operational and functional administration and of the processing of the associated personal data, considered in this document as the Controller of the personal data and as ultimately responsible for the contractual relationship with the Subscriber.

  • Website: The official website of ROCCIBEL, accessible at https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version), through which the Subscription Program's contracting process operates.

  • Request: A formal requirement submitted by a Subscriber to the Controller of Personal Data Processing to exercise their rights under the TDPSA, ROSCA, and other applicable regulations.

  • Subscriber: A natural person who has entered into a Subscription Plan offered by ROCCIBEL, granted their affirmative consent for the execution of recurring charges, and accepted the terms of this Policy.

  • Third Party: Any person other than the Consumer, the Controller (Responsable), the Processor (Encargado), or an affiliate of the Controller (Responsable) or Processor (Encargado).

  • Territory: Refers to the State of Texas, United States of America, as well as any other jurisdiction within or outside the territory of the United States of America in which ROCCIBEL offers its subscription products or services.

  • Data Subject: A natural person whose personal data is processed by ROCCIBEL. In the context of the Subscription Program, the Data Subject is any natural person who has entered into a Subscription Plan and whose data is processed in connection with that transaction.

  • Payment Token: An alphanumeric reference string issued by the Payment Processor that replaces the Subscriber's actual card data in communications between the Processor and the Payment Processor. The Token allows the Payment Processor to be instructed to execute a recurring charge without the Processor or ROCCIBEL having access to the Subscriber's actual financial data.

  • Processing: Processing means any operation or set of operations performed, by manual or automated means, on personal data or sets of data. This includes, among others, the collection, use, access, storage, analysis, modification, communication, Disclosure, Sharing, Sale, deletion, or any other action performed on personal data, in accordance with the TDPSA.

  1. 5. AVAILABLE SUBSCRIPTION PLANS

ROCCIBEL offers its consumers the option to enter into Subscription Plans for selected products in its portfolio, with delivery frequencies defined at the time of purchase. The specific characteristics of each Subscription Plan - including available products, enabled frequencies, applicable amounts, and particular terms - are clearly and conspicuously specified on the product pages of the Website at the time of purchase, in accordance with the disclosure standards required by ROSCA (15 U.S.C. § 8403) and Section 5 of the FTC Act.

The specific offering of Subscription Plans is dynamic and may change as ROCCIBEL's commercial portfolio evolves. In any event, ROCCIBEL guarantees that information about the current Subscription Plans will be available clearly, accurately, and completely on the Website before the Subscriber grants consent and provides their billing information.

  1. 6. CONTRACTING AND CONSENT PROCESS

6.1 Prior Disclosure of Material Terms

In accordance with the Restore Online Shoppers' Confidence Act (ROSCA, 15 U.S.C. § 8403) and Section 5 of the FTC Act, before requesting the Subscriber's billing information, ROCCIBEL will clearly and conspicuously disclose the material terms of the Subscription Plan, including at a minimum the product subject to the subscription, the amount to be charged in each Billing Cycle, the frequency of recurring charges, the minimum commitment period if applicable, the mechanism for canceling the subscription, and the policy applicable to refunds and returns under Section 12 of this Policy.

6.2. Express and Informed Consent

Entering into a Subscription Plan requires the Subscriber's free, prior, express, and informed consent. Such consent is obtained through the positive and unambiguous act of checking the box provided to accept the subscription terms and authorize the processing of recurring charges, together with clicking the button to complete the purchase. The acceptance checkbox is not pre-checked, by technical design, in compliance with the active affirmative consent standard required by ROSCA and Section 5 of the FTC Act.

6.3. Consent Record (Timestamp)

At the moment the Subscriber completes the contracting act, the platform automatically generates and retains a Consent Record that includes the exact date and time of consent, the IP address of the device from which the act was performed, the version of the subscription terms in effect at that time, and the Payment Token associated with the selected payment method. This Record constitutes the legal proof of the Subscriber's consent.

6.4. Payment Method Security Architecture

At the time of purchase, the Subscriber enters their card details through the Website's secure form. That data travels encrypted directly to the Payment Processor in a secure environment certified under the PCI-DSS standard. The Processor receives only a reference Token that allows it to instruct the Payment Processor to execute recurring charges, without having direct access to the Subscriber's financial data. This technical architecture minimizes the risk of financial data exposure and constitutes an additional security guarantee for the Subscriber.

6.5. Subscription Confirmation

Immediately after completing the purchase, the Subscriber will receive a confirmation email that includes a summary of the material terms of the subscription, the access link to the Customer Portal, instructions for independently managing the subscription, and the Contact Channels available for inquiries or complaints.

7. RECURRING CHARGES AND PRIOR NOTIFICATIONS

7.1. Charging Method

The Subscription Program operates under a per-cycle charging model. At the end of each Billing Cycle, and unless the Subscriber has canceled their subscription in accordance with the procedure established in this Policy, the Processor will instruct the Payment Processor to automatically execute the charge corresponding to the next cycle, using the Token associated with the payment method registered by the Subscriber.

7.2. Accepted Payment Methods

The Subscription Program accepts, as payment methods for the automatic execution of recurring charges, credit and debit cards, Apple Pay, Google Pay, Shop Pay, and PayPal, as well as any other method enabled by the platform at the time of purchase. Local payment methods that do not allow auto-charging - such as bank transfers, cash payments, or cash on delivery - are not compatible with the Subscription Program in its automatic-charge mode.

7.3. Pre-Charge Notification

In accordance with transparency standards, ROCCIBEL will send the Subscriber a Pre-Charge Notification with three (03) days' advance notice before executing the charge corresponding to the next Billing Cycle. The notification will be sent by email to the address registered by the Subscriber and will include the exact amount to be charged, the scheduled charge date, the payment method to be charged, and instructions for modifying, pausing, or canceling the subscription before the charge date.

7.4. Prohibition on Retroactive Price Changes

ROCCIBEL will not retroactively modify, or modify without prior notice, the amount applicable to the recurring charges of an active subscription. Any change to the price of a Subscription Plan will be notified to the Subscriber with reasonable advance notice and, where required under applicable regulations, will require the Subscriber's express re-acceptance to take effect. Price changes on the Website applicable to new Subscribers will not automatically affect the terms of subscriptions already active.

8. PAYMENT FAILURE MANAGEMENT (DUNNING)

8.1. Detection of Payment Failure

In the event a recurring charge is declined by the Payment Processor - for reasons such as insufficient funds, an expired card, a blocked card, or any other cause - the Processor will record the failure in the system and automatically activate the payment-failure management protocol (Dunning), without immediately canceling the subscription.

8.2. Notification of Failed Payment

Upon detecting the failure, the Processor will send the Subscriber an email informing them of the declined charge, identifying the probable cause to the extent reported by the Payment Processor, and including a secure link for the Subscriber to update their payment method. The Subscriber may update their card details directly from the Customer Portal, without needing to contact customer service.

8.3. Automatic Charge Retries

Following an initial failure, the Processor will automatically execute charge retries in accordance with the rules configured by ROCCIBEL, with a frequency of three (3) total retries. Each retry will be communicated to the Subscriber by email, keeping them informed of the status of their subscription and of the actions required on their part to bring the payment current.

8.4. Effects of Persistent Payment Failure

Once the automatic retries have been exhausted without success, the subscription will be suspended or canceled in accordance with the operating rules configured by ROCCIBEL. Suspension or cancellation due to persistent payment failure will not relieve the Subscriber of payment for cycles already executed and delivered, nor will it affect ROCCIBEL's rights with respect to unsatisfied monetary obligations.

9. CUSTOMER PORTAL

9.1. Function and Scope of the Customer Portal

The Customer Portal constitutes the Subscriber's primary self-service mechanism during the term of their subscription. Through the Portal, the Subscriber can view the status of their subscription, the history of orders executed, cancel subscriptions, the date of the next charge, and the applicable terms, as well as carry out the modifications described in Section 10 of this Policy and proceed with cancellation of the subscription under Section 11.

9.2. Access via Magic Link

Access to the Customer Portal is via Magic Link, without needing to remember or manage a password. The Subscriber requests access by entering their email address in the Portal's form and receives, at that same address, a unique and temporary link that allows them to enter the Portal directly. The Magic Link automatically expires after a limited period of time or after its first use, ensuring the security of access.

This passwordless authentication architecture reduces the risks associated with the Subscriber's storage and management of passwords.

9.3. Availability of the Customer Portal

The Customer Portal is available twenty-four (24) hours a day, seven (7) days a week, subject to the operational maintenance windows or technical interruptions inherent to the platforms of the Processors. ROCCIBEL is not responsible for technical failures or unavailability of the Portal attributable to those platforms in their capacity as technical Processors.

10. MODIFICATIONS TO THE SUBSCRIPTION

Through the Customer Portal, the Subscriber may independently make the following modifications to their active subscription, without needing the intervention of customer service:

  • Quantity change: the Subscriber may increase or decrease the quantity of the product to be received in each Billing Cycle, subject to the operational limits configured by ROCCIBEL.

  • Shipping address change: the Subscriber may update the delivery address for subscription orders. Address changes will apply only to the next Billing Cycle and will not affect orders already processed or in transit.

  • Delivery frequency change: the Subscriber may change the frequency with which they wish to receive the products in their Subscription Plan, within the options enabled for the corresponding product.

  • Subscription pause: the Subscriber may pause their subscription indefinitely, suspending recurring charges until they decide to reactivate it. No charges or shipments will occur while paused.

  • Cycle skip: the Subscriber may skip the delivery of a specific cycle, deferring the next charge and delivery to the following cycle.

  • Payment method update: the Subscriber may update their card details or change the payment method associated with the subscription. The update operates under the same security architecture described in Section 6.4 of this Policy.

  • Out-of-stock product: In cases where the product subject to the subscription is out of stock, the Subscriber may switch products for that cycle or pause the subscription.

10.1. Modification Management Mechanism (Customer Portal)

The modifications described in this Section are designed primarily as self-service through the Customer Portal, generated and administered by the Processor. The Subscriber may access the Portal in two ways: (i) by email, through the Magic Link included in each subscription transactional notification, which automatically authenticates the user without requiring a password and is valid for seven (7) days from its issuance; or (ii) from the Website, by logging into their customer account and accessing the URL. Additionally, ROCCIBEL's customer service team may make any of these modifications manually from the administration panel, if the Subscriber experiences technical difficulties accessing the Customer Portal or expressly requests it through the enabled Contact Channels under Section 15 of this Policy.

All modifications made through the Customer Portal are recorded with the date, time, and details of the change, forming the Subscriber's subscription management history.

11. TERM AND CANCELLATION

11.1. Free Cancellation

The Subscription Program of ROCCIBEL does not require a minimum commitment period. The Subscriber may cancel their subscription at any time, from the first Billing Cycle, without needing to provide any justification and without early-termination charges. Additionally, the Subscription Plan will have a maximum duration determined by the plans offered on the Website, at the end of which the subscription automatically terminates without the need for express cancellation by the Subscriber (a subscription with a scheduled expiration). This feature means that the Subscription Program does not constitute an indefinite automatic-renewal contract for purposes of Sections 601.001 et seq. of the Texas Business & Commerce Code (SB 838), and therefore the obligation to provide 15-to-90-day advance renewal notice applicable to contracts with terms of 12 months or more does not apply. In any event, ROCCIBEL complies with the general disclosure, consent, and cancellation-mechanism standards required by SB 838.

11.2. Cancellation Mechanism

Cancellation is carried out independently by the Subscriber through the Customer Portal, accessed via Magic Link, by selecting the option to cancel the subscription. The cancellation process is simple, direct, and does not require the Subscriber to go through disproportionate steps. Alternatively, the Subscriber may request cancellation through the enabled Contact Channels, by sending an email to support@zenttu.com with the subject line 'SUBSCRIPTION CANCELLATION' and clearly indicating their request.

11.3. Effects of Cancellation

Cancellation of the subscription will produce the following effects, regardless of the channel through which it was processed: discontinuation of future recurring charges; cessation of the scheduling of future orders associated with the canceled Subscription Plan; and continued access to the Customer Portal to view the history of the canceled subscription, in accordance with the retention periods established in Section 13 of this Policy.

11.4. Cut-off Time

If the Subscriber executes the cancellation after the system has already generated the order corresponding to the current cycle and processed the associated charge, the cancellation will apply to the next cycle. The order already generated and the charge already processed will be deemed final and will be subject to the refunds and returns policy described in Section 12 of this Policy.

11.5. Re-enrollment

A Subscriber who has canceled their subscription may enter into a Subscription Plan again at any time, following the ordinary contracting process described in Section 6 of this Policy. Re-enrollment will generate a new Consent Record, independent of the prior one.

12. REFUNDS AND RETURNS

12.1. Applicability of the General Returns and Refunds Policy

Orders executed under the Subscription Program are subject to the general returns and refunds policy set forth in ROCCIBEL's Website Terms and Conditions of Use. Accordingly, and in view of the nature of the beauty products sold, returns are not accepted for makeup, skincare, hair-care, or body-care products that have been opened, used, or unsealed, except where they present manufacturing defects or damage attributable to the shipping process.

12.2. Returns for Defective Products or Shipping Errors

If the Subscriber receives a damaged, defective, or incorrect product as part of a subscription order, they may request a return within thirty (30) business days following receipt of the order, by contacting support@zenttu.com and attaching the order number, a description of the issue, and photographic evidence of the affected product. Once the request has been validated, ROCCIBEL will bear the return shipping costs and will arrange for the replacement or refund, as applicable.

12.3. Refund Processing Procedure

The Subscriber should bear in mind that the Processor does not process refunds automatically. When a refund is approved by ROCCIBEL in accordance with applicable policies, it will be processed manually by ROCCIBEL's authorized personnel from the platform's order-management panel, to the original payment method used by the Subscriber in the purchase. Refund processing will take seven (7) to ten (10) business days, subject to the policies of the relevant bank or payment processor.

12.4. Refund Exclusions

Refunds will not be processed for subscription orders in the following cases: items returned showing signs of use; opened products, except where they present manufacturing defects; items for which the request is submitted after the thirty (30) business day period from receipt; sale or promotional items, except where they present manufacturing defects; and original shipping costs, except where the return is due to an error by ROCCIBEL.

13. PROCESSING OF PERSONAL DATA ASSOCIATED WITH THE SUBSCRIPTION

13.1. Personal Data Collected

Within the framework of the Subscription Program, ROCCIBEL and the applicable Processors may collect and process the following Subscriber personal data: full name; email address; shipping address; Payment Token associated with the registered payment method; Consent Record with the date, time, and IP address of the contracting act; subscription order history, including amounts, dates, and products; history of modifications made to the subscription; and a record of transactional communications sent to the Subscriber.

13.2. Purposes of Processing

Personal data under the Subscription Program is processed exclusively for the following purposes: performance of the subscription contract and management of recurring charges; sending transactional notifications associated with the Program, such as order confirmations, pre-charge notifications, payment-failure alerts, and cancellation confirmations; retaining evidence of the Subscriber's consent for ROSCA regulatory compliance and other applicable regulations; handling Subscriber rights requests under the TDPSA; compliance with legal, tax, and accounting obligations arising from the contractual relationship; and internal analysis of the Program's operation, on an aggregated basis and without individual Subscriber profiling.

13.3. Financial Data Security Architecture

As described in Section 6.4 of this Policy, ROCCIBEL does not directly store or process the Subscriber's card data. Financial data is managed exclusively by the Payment Processor in a secure environment certified under the PCI-DSS standard. This technical architecture constitutes a material security guarantee for the Subscriber and limits exposure of their financial data solely to the Payment Processor.

13.4. Data Retention Period

ROCCIBEL will retain the Subscriber's personal data for the duration of the subscription relationship and for the additional period necessary to comply with legal obligations, defend claims, or undergo regulatory audits. Once the retention period has elapsed, the data will be securely deleted or anonymized in accordance with the practices described in ROCCIBEL's Privacy Policy.

13.5. Right to Data Deletion

If the Subscriber requests deletion of their personal data, ROCCIBEL will execute the 'Delete personal data' function on the platform, which purges the profile information and consent history within up to ten (10) days. This deletion is irreversible and, when carried out on an active subscription, will entail prior cancellation of that subscription. The request will be processed in accordance with ROCCIBEL's Procedure for Handling Consumer Requests Regarding Personal Data Protection.

13.6. Security of Subscription Program Data

ROCCIBEL adopts the technical, organizational, and administrative measures necessary to ensure the security, confidentiality, and integrity of the personal data processed under the Subscription Program. In the event of a security breach compromising Subscription Program personal data, ROCCIBEL will apply the notification protocol set forth in Texas Business & Commerce Code § 521.053, notifying affected Subscribers without undue delay and in any case within sixty (60) days following determination of the incident.

14. AMENDMENTS TO THE POLICY

ROCCIBEL reserves the right to amend this Policy at any time, in order to reflect regulatory, operational, or technical changes related to the Subscription Program. The current version will always be available at https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version).

Material changes to the Policy - understood as those that modify substantial rights or obligations of Subscribers, including changes to applicable amounts, charge frequency, or the cancellation policy - will be notified to the Subscriber with reasonable advance notice, through their registered email address, indicating the new effective date. Where required under applicable regulations, material changes will require the Subscriber's express re-acceptance to take effect. The Subscriber's continued use of the Subscription Program after notification of material changes, without express objection, will constitute acceptance of the updated version of the Policy. Non-material changes, such as typographical corrections or clarifications that do not modify rights or obligations, will take effect immediately upon publication on the Website.

15. CONTACT CHANNELS AND MECHANISMS AVAILABLE FOR HANDLING REQUESTS, INQUIRIES, AND COMPLAINTS RELATED TO THE SUBSCRIPTION PROGRAM

In order to ensure the exercise of rights related to the Subscription Program and the protection of associated personal data, ROCCIBEL makes the following official Contact Channels available to Subscribers:

  • ROCCIBEL website: https://zenttu.com/ (English version) and https://zenttu.com/es (Spanish version)

  • Customer Portal: The primary self-service channel for the Subscriber to view, modify, and cancel the subscription, accessible via Magic Link from the registered email address.

  • Electronic Support: You may send a formal request to our email address designated for the Subscription Program, support@zenttu.com, indicating in the subject line the nature of your request (for example, 'SUBSCRIPTION CANCELLATION', 'REFUND REQUEST', 'SUBSCRIPTION DATA UPDATE') and providing the information necessary to process it.

  • Mailing Address: You may also send us a written request to our physical address at 24285 Katy Freeway, Suite 300, Katy, TX 77494, United States, clearly indicating your request and providing the documentation required for validation.

All requests will be processed in accordance with the timeframes and conditions established under applicable regulations, including the Restore Online Shoppers' Confidence Act (ROSCA) and the Texas Data Privacy and Security Act (TDPSA) for consumers located in Texas. If requests are received from consumers in other states or countries, ROCCIBEL will apply the requirements that correspond in a proportional and reasonable manner, preferentially applying the TDPSA unless a supplementary law offering broader coverage and protection to the consumer exists.