Privacy Policy

This Privacy Notice for Penvoy (“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:

• Visit our website at https://www.penvoy.app or any website of ours that links to this Privacy Notice
• Engage with us in other related ways, including any marketing or events

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 support@penvoy.app.

Summary of Key Points

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? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

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 may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

How do we keep your information safe? We have adequate organizational 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 Personal Information?
4. When and With Whom Do We Share Your Personal Information?
5. Do We Use Cookies and Other Tracking Technologies?
6. How Do We Handle Your Social Logins?
7. How Long Do We Keep Your Information?
8. How Do We Keep Your Information Safe?
9. Do We Collect Information From Minors?
10. What Are Your Privacy Rights?
11. Controls for Do-Not-Track Features
12. Do United States Residents Have Specific Privacy Rights?
13. Do We Make Updates to This Notice?
14. How Can You Contact Us About This Notice?
15. How Can You Review, Update, or Delete the Data We Collect From You?

1. What Information Do We Collect?

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.

The personal information we collect may include the following:

• Email addresses
• Usernames
• Passwords
• Contact or authentication data
• Billing addresses

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Polar. You may find their privacy notice on their website.

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 “How Do We Handle Your Social Logins?” below.

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.

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

2. How Do We Process Your Information?

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
• To deliver and facilitate delivery of services to the user
• To respond to user inquiries and offer support to users
• To send administrative information to you
• To fulfill and manage your orders, payments, returns, and exchanges
• To enable user-to-user communications
• To request feedback and contact you about your use of our Services
• To protect our Services, including fraud monitoring and prevention
• To identify usage trends and improve our Services
• To save or protect an individual's vital interest, such as to prevent harm

3. What Legal Bases Do We Rely On to Process Your Personal Information?

We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK:

We may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when necessary to fulfill our contractual obligations to you.
• Legitimate Interests. We may process your information when reasonably necessary to achieve our legitimate business interests, such as analyzing how our Services are used, diagnosing problems, or preventing fraudulent activities.
• Legal Obligations. We may process your information where necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada:

We may process your information if you have given us specific permission (express consent) or where your permission can be inferred (implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted to process your information without your consent as permitted by applicable law.

4. When and With Whom Do We Share Your Personal Information?

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf. We have contracts in place with our third parties designed to safeguard your personal information.

The third parties we may share personal information with include:

• Cloud Computing Services: Google Cloud Platform and Amazon Web Services (AWS)
• Invoice and Billing: Polar
• User Account Registration and Authentication: Google Sign-In

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

• Business Transfers. We may share or transfer your information in connection with any merger, sale, financing, or acquisition of all or a portion of our business.
• Other Users. When you share personal information or interact with public areas of the Services, such personal information may be viewed by all users.

5. Do We Use Cookies and Other Tracking Technologies?

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. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice at https://penvoy.app/cookies.

6. How Do We Handle Your Social Logins?

Our Services offer you the ability to register and log in using your third-party social media account details (like your Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider, such as your name, email address, 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. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information.

7. How Long Do We Keep Your Information?

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. 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 anonymize such information, or securely store and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, 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 unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

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.

9. Do We Collect Information From Minors?

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 years of age or the equivalent age as specified by law in your jurisdiction.

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 support@penvoy.app.

10. What Are Your Privacy Rights?

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 to:

• Request access and obtain a copy of your personal information
• Request rectification or erasure
• Restrict the processing of your personal information
• Data portability (if applicable)
• Not be subject to automated decision-making

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you 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 by contacting us using the details provided in section 14 below. This will not affect the lawfulness of the processing before its withdrawal.

Opting out of marketing: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in emails we send, or by contacting us. We may still send you service-related messages necessary for account administration.

Account Information: You may review or change the information in your account or terminate your account at any time by logging in to your account settings. 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, or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at support@penvoy.app.

11. 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 recognizing and implementing DNT signals has been finalized. 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. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

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 recognizing or honoring DNT signals, we do not respond to them at this time.

12. Do United States Residents Have Specific Privacy Rights?

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, 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.

Categories of Personal Information We Collect

In the past twelve (12) months, we have collected the following categories of personal information:

• A. Identifiers — contact details such as name, email address, online identifier, and account name
• B. Personal information (California Customer Records statute) — name, contact information, and financial information
• C. Protected classification characteristics — gender, age, date of birth, and other demographic data
• D. Commercial information — transaction information, purchase history, and payment information
• F. Internet or other similar network activity — browsing history, search history, and interactions with our Services

We do not collect biometric information, precise geolocation data, audio/visual recordings, professional or employment-related information, education information, inferences drawn from collected personal information, or sensitive personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Your Rights

You have rights under certain US state data protection laws, including:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• 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

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request or by emailing us at support@penvoy.app.

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 support@penvoy.app. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83 permits California residents to request information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us using the details in section 14 below.

13. Do We Make Updates to This Notice?

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 “Last updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, 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.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at support@penvoy.app or contact us by post at:

Penvoy
Guatemala City, Guatemala
support@penvoy.app

15. 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 submit a data subject access request or contact us at support@penvoy.app.