PRIVACY POLICY

Introduction

This Privacy Policy (this “Policy”) applies to https://penroe.ai (the “Website”) and when you use our products and services. The Arete Production Company, operating as Penroe (“we” or “us”) operates this Website and provides the products and services to offer information about Penroe and to deliver the software and related services we make available.

This Policy describes the types of information we may collect from you or that you may provide to us, and our practices for collecting, using, maintaining, protecting, and disclosing that information when you visit the Website or access or use any content, functionality, and services offered on or through the Website or otherwise provided by Penroe (collectively, the “Services”).

Your use of the Services is governed by our Terms of Use.

Please read this Policy carefully to understand our policies and practices regarding your information and how we treat it. If you do not agree with our policies and practices, your choice is not to use our Services. We may update or revise this Policy from time to time (see Changes to this Privacy Policy). Your continued use of the Services after we update or revise this Policy will constitute your acceptance of those updates or revisions.

This Policy applies to the Personal Information we collect:

• Through the Services;
• In email, text, and other electronic messages between you and Penroe;
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy; or
• When you provide information, data, materials, text, prompts, images, or other content on or through the Services.

This Policy does not apply to information collected by:

• Us offline or through any other means; or
• Any third party, including through an application or content (including advertising) that may link to or be accessible from or on the Services.

Information We Collect About You and How We Collect It

Penroe recognizes any data related to an identifiable individual or that identifies an individual as “Personal Information” subject to this Policy. Depending on how you interact with Penroe, we collect and use different types of Personal Information. Types of information we may collect include:

• By which you may be personally identified, such as name, payment card information, postal address, e-mail address, telephone number, profile picture, or any other identifier by which you may be contacted online or offline; and
• About your internet connection, the equipment you use to access our Services, and usage details; and
• Authentication data such as tokens provided by third-party services to access specific permissions granted by you.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
• From third parties, for example, our business partners.

If you are located in the United Kingdom or the European Union, we process your Personal Information only where we have a lawful basis under applicable law. These bases include:

• Consent: You have given us consent to process your Personal Information for a specific purpose.
• Contract: Processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legal Obligation: Processing is necessary to comply with a legal obligation.
• Legitimate Interests: Processing is necessary for our legitimate interests, provided those interests are not overridden by your rights and interests.

Information You Provide to Us

The information we collect on or through our Services may include:

• Information that you provide (e.g. by using or filling in forms on the Services or while interacting with the Services). This includes information provided at the time of registering to use the Services, subscribing to the Services, posting or providing material, or requesting further services.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Details of transactions you carry out through the Services and of the fulfillment of your requests.
• Your search queries and activities on the Services or while interacting with the Services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to or interactions with our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through your interactions with our Services.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. This helps us to improve the Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to and interact with our Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Services.
• Web Beacons. Certain sections of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixels gifs) that permit us, for example, to count the users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
• Log Files. Like many websites and technology services delivered over the Internet, we collect and store information that your browser sends to us when you visit or interact with the Services. This information may include your IP address, browser type, browser version, domain names, the pages of the Services that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
• Google Analytics. We also use Google Analytics as a tool for tracking and analyzing web traffic to the Services. Google Analytics runs on Penroe's server and uses a combination of first-party cookies and Javascript code to compile information that is synthesized into reports about page visits, referring sites, user habits, and similar data. Penroe does not give Google access to any user information other than IP addresses.

Google has created an “Opt-out Browser Add-on” for users who wish to use the Services while preventing their data from being accessed or used by Google Analytics. If you want to opt out of the features on the Services that relies on Google Analytics, please follow the directions provided by Google here: https://tools.google.com/dlpage/gaoptout.

Cookies We Use

Purpose of Collection

We use information that we collect about you or that you provide to us, including any Personal Information to:

1. Provide the Services. We may use your Personal Information to provide the Services, and any other services you may request from us.
2. Monitor the Services. We collect your Personal Information for monitoring purposes to help us diagnose problems with our servers, administer and troubleshoot Services, calculate usage levels, analyze industry standards, and analyze transactions, trends, and statistics regarding the use of the Services.
3. Respond to Inquiries and Fulfill Requests. We may use your Personal Information to respond to your inquiries and to fulfill your requests for information.
4. Communicate with You. We may use your Personal Information to communicate with you about items that may be of interest to you. We may also contact you on behalf of our third-party business partners about a particular offering of theirs that may be of interest to you.
5. Improve the Services. We may use your Personal Information to make the Services more stable and user-friendly, to analyze issues with the Services, improve the design, content and functionality of the Services, personalize your experience, analyze how the Services are used, offer new Services, and to develop new marketing programs relating to the Services.
6. Customer Service. We may use your Personal Information when contacting you regarding customer service, to resolve disputes, or in response when you provide feedback. We may also use your information to send administrative emails regarding the Services or to inform you of any changes to this Policy, our terms, or other agreements with you.
7. Support Business Operations. We may use your Personal Information to support our internal business operations, including account management, marketing, security, and advertising.
8. Enforce Agreements. We may use your Personal Information to enforce separate agreements between you and Penroe, enforce this Policy, our Terms of Use, and other agreements with you.
9. Fulfill Other Purposes. We may use your Personal Information to fulfill: (a) any other purpose for which you provide it; (b) any legal or regulatory requirements and any of our internal policies; (c) other purposes disclosed at the time of collection; (d) any other purpose with your consent; and (e) any other purposes set forth in this Policy.

Sale or Sharing of Personal Information

We do not sell, rent, or trade your Personal Information to third parties for monetary or non-monetary consideration. We do not share your Personal Information with advertisers or advertising networks. We only disclose Personal Information to third-party service providers that perform services on our behalf and are necessary to operate and support the Services (such as cloud hosting, security, or technical infrastructure), or where disclosure is required by applicable law.

Third Party Links

As stated above, our Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us—and which may link to other websites, services, or applications. Please be aware that we are not responsible for the privacy or practices of other websites or third parties. We do not make any guarantee regarding those third-party websites, services, or applications, and we are not liable for any loss or damage caused by the use of such sites. Any data collected by third parties is not covered by this Policy. You should review the policies of the third parties and contact them directly if you have any questions about their services or practices.

Consent and Withdrawal

Where required by law, we will obtain your consent before collecting, using, or disclosing your Personal Information. You may withdraw your consent at any time by contacting us using the details in the Contact Us section. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Disclosure of Your Information

We may disclose deidentified and aggregated information about our users without restriction.

We may disclose Personal Information that we collect or that you provide as described in this Policy:

• To our subsidiaries, or affiliates;
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Penroe's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Penroe about users of the Services is among the assets transferred;
• To fulfill the purpose for which you provide it; for example, when using the Services, you may provide us with information to sign up for seminars, request specific information about programs, or register or apply for various programs or services, and we will use the information you provide us to evaluate and process your request or application or provide you with the services you request;
• For any other purpose disclosed by us when you provide the information; and
• With your consent.

We may use for other purposes and disclose to third parties information that does not constitute as Personal Information.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To enforce or apply the Terms of Use and other agreements between you and Penroe; and
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Penroe, our customers, or others, including by exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

How Long We Retain Your Information

We will keep your Personal Information while you have an account with us or while we are providing the Services to you. Thereafter, we will keep your Personal Information for as long as is necessary to respond to any questions, complaints, or claims made by you or on your behalf or to the extent necessary to keep records required by law.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please consult your browser's documentation to learn how. Note that certain portions of the Services may not operate as intended if you refuse certain cookies.
• Opt-out of marketing communications: You can opt-out anytime by following the opt-out instructions in our commercial e-mails or contacting us at security@penroe.ai. You will continue to receive emails relevant to your continued use of the Services. If you believe that SPAM has been sent from us, please contact us at security@penroe.ai so that we can investigate and rectify the situation.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Do Not Track

Our Services do not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track signals by visiting the preferences or settings page of your web browser.

Confidentiality and Security

Penroe has implemented appropriate administrative, technical, and physical safeguards designed to ensure the integrity and security of your Personal Information. We undertake commercially reasonable efforts to guard against unauthorized access, use, alteration, or destruction of Personal Information.

PENROE MAKES NO CLAIMS, PROMISES OR GUARANTEES ABOUT THE ACCURACY, COMPLETENESS OR ADEQUACY OF THE CONTENTS OF THE SERVICES, AND EXPRESSLY DISCLAIMS LIABILITY FOR ERRORS AND OMISSIONS IN THE CONTENTS OF THE SERVICES. NO WARRANTY OF ANY KIND, IMPLIED, EXPRESSED OR STATUTORY, INCLUDING BUT NOT LIMITED TO THE WARRANTIES OF NON-INFRINGEMENT, TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND FREEDOM FROM COMPUTER VIRUS, IS GIVEN WITH RESPECT TO THE SERVICES OR HYPERLINKS TO OTHER INTERNET RESOURCES. REFERENCE IN THE SERVICES TO ANY SPECIFIC COMMERCIAL PRODUCTS, PROCESSES OR SERVICES, OR THE USE OF ANY TRADE, FIRM OR CORPORATION NAME IS FOR THE INFORMATION AND CONVENIENCE ONLY AND DOES NOT CONSTITUTE ENDORSEMENT OR RECOMMENDATION BY PENROE.

Artificial Intelligence Usage

The Services rely on automated, AI-driven processing of information generated through your use of the Services, including but not limited to, communications content, prompts, feedback, usage patterns, and related contextual signals (collectively, “Service Interaction Data”). The collection and use of this data are essential to the operation of the Services, which cannot function without this processing. If you do not consent to this processing, you must refrain from using the Services.

Penroe uses Service Interaction Data for configuration and improvement, including evaluation and refinement of prompts, workflows, and responses (“Prompt Configuration”). Prompt Configuration includes identifying missed items, incomplete outputs, or suboptimal responses and improving how the Services respond to similar inputs over time. This may include adjustments to the instructions, prompts, and workflow logic used to operate the Services. Prompt Configuration is distinct from model training and does not train, retrain, or otherwise modify the underlying artificial intelligence or machine learning models used to provide the Services.

Service Interaction Data used for Prompt Configuration is used solely to improve the performance and outputs of the Services in connection with your use of the Services, and is not used to build or train any general-purpose artificial intelligence model or any model used outside the scope of providing the Services.

Updating Your Information

If you are a user who has a registered account on the Services, you can review and change some of your Personal Information by logging into the Services and visiting your account details page or by contacting us at the information listed in the Contact Us section below.

Children Under the Age of 18

Our Services are not intended for children under 18 years of age. We do not knowingly collect information from children under 18. If you are under 18, do not use or provide any information through the Services. If we learn we have collected or received information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at the information listed in the Contact Us section below.

Changes to this Privacy Policy

We may revise or update this Policy from time to time. If we make material changes to how we treat our users' Personal Information, we will notify you through a notice on the Services' home pages. The last date of revision of this Policy is set forth above. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting the Services and this Policy to check for any changes.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information.

These states may provide (now or in the future) their state residents with rights to:

• Confirm whether we process their Personal Information.
• Access and delete certain Personal Information.
• Correct inaccuracies in their Personal Information, taking into account the information's nature and processing purpose.
• Data portability.
• Opt-out of Personal Information processing for:
  • targeted advertising;
  • sales; or
  • profiling in furtherance of decisions that produce legal or similarly significant effects.
• Either limit (opt-out of) or require consent to process sensitive Personal Information.

The exact scope of these rights may vary by state. To understand if you have any of these rights, and to exercise any of these rights please contact us at the information listed in the Contact Us section below.

Your California Privacy Rights (CCPA/CPRA)

This privacy notice section for California residents supplements the information contained in this Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Information for business or commercial purposes:

• Identifiers
• Internet or other similar network activity
• Geolocation data

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Information were in fact disclosed.

Share of Personal Information

We may share your Personal Information identified in the above categories with the following categories of third parties:

• Service providers
• Our affiliates
• Our business partners
• Third party vendors whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

Shine the Light

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information (e.g., name, e-mail and mailing address and the type of services provided to the consumer) that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us as directed in the Contact Us section below with a reference to Shine the Light inquiry.

Purpose & Sources of Personal Information Collected

We may collect (and have collected during the 12-month period prior to the “Last Updated” date of this Policy) the categories of Personal Information from the sources and for the purposes as described in the above sections.

Children Under the Age of 16

Our Services are not intended for children under 16 years of age. We do not knowingly collect information from children under 16 nor do we sell or share the Personal Information of consumers under the age of 16. If you are under 16, do not use or provide any information through the Services. If we learn we have collected or received information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the information below.

Selling and Sharing Personal Information

We do not sell or share your Personal Information in exchange for monetary consideration; however, we may use tools described above (such as Google Analytics), which may be interpreted as sharing your Personal Information. As such, please see the above sections for more information regarding opting out of use of these tools.

Privacy Rights

Under California State Law, consumers have certain rights regarding their Personal Information, as described below.

• Right of Access. You have the right to request, twice in a 12-month period, that we disclose to you the following information about you, limited to the preceding twelve (12) months:
  • The categories of Personal Information that we collected about you;
  • The categories of sources from which the Personal Information is collected;
  • The business or commercial purpose for collecting Personal Information;
  • The categories of third parties with whom we share Personal Information;
  • The specific pieces of Personal Information that we have collected about you;
  • The categories of Personal Information that we disclosed about you for a business purpose (if any); and
  • For each category of Personal Information identified, the categories of third parties to whom the information was disclosed (if any).
• Right of Deletion. You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law. See our data deletion instructions.
• Right to Opt-Out. You have the right to opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You may request specific limitations on further sharing, use, or disclosure of your sensitive Personal Information that is collected or processed.
• Right to Correction. You have the right to request that we maintain accurate Personal Information about you and correct any Personal Information about you which we have collected from you, subject to exceptions within the law.
• Data Portability. You may request that your data be provided to you or transferred to another organization.

General Data Protection Regulation (GDPR)

Penroe seeks to ensure all individuals are provided with the rights mandated by their governing jurisdiction. Not all of the rights discussed herein will apply to each individual data subject and may not apply to you depending upon your jurisdiction. You may have certain rights regarding the Personal Information we process about you. Some of these rights may only apply in specific circumstances, depending on your location. If you wish to manage, update, restrict, or delete your Personal Information, please contact us as described in the Contact Us section below.

To the extent provided by the GDPR and UK GDPR, data subjects in the European Union (“EU”) or United Kingdom (“UK”) may exercise the following rights:

• Right to Access. You have the right to request copies of your Personal Information.
• Right to Rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete the information you believe is incomplete.
• Right to Erasure. You have the right to request that we delete any Personal Information about you which we have collected from you, subject to exceptions within the law. See our data deletion instructions.
• Right to Restrict Processing. You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
• Right to Object to Processing. You have the right to object to our processing of your Personal Information, under certain conditions.
• Right to Data Portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Right to Withdraw Consent. You have the right, at any time, to withdraw consent where processing is based on consent.
• Right to Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority in your jurisdiction.

If we process your Personal Information based on our legitimate interests as explained in this Policy, you can object to this processing in certain circumstances. In such cases, we will cease processing your Personal Information unless we have compelling, legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your Personal Information for direct marketing purposes, you can always object using the “unsubscribe” link in such communications or changing your account settings if you have registered for an account. However, please note you may not opt-out of Service-related communications, such as account verification, changes or updates to features of the Service, or technical and security notices.

Where you have provided consent to certain data processing, you have the right to withdraw that consent at any time by contacting us as described in the Contact Us section below. A withdrawal of consent will not affect the validity of our use of your Personal Information up until the point you have withdrawn your consent.

Discrimination

We will not discriminate against you for exercising any of your applicable GDPR, CCPA or other state privacy rights.

Request Processing and Verification

In order to protect your Personal Information from unauthorized access, deletion, rectification, or restriction, we may require you to verify your identity before we will process any request to know or delete Personal Information. If we cannot verify your identity to our satisfaction, we will not provide or delete your Personal Information.

You may submit a request to know or delete your Personal Information through an authorized agent. Such an agent must present signed written authority to act on your behalf and must be able to verify your identity to our satisfaction.

To exercise one of your rights, you should send a communication in writing to security@penroe.ai. We will attend to your request in a timely manner within 45 days of receiving your request. If, for any reason, we need to extend this period of time, we will contact you.

International Transfers of Personal Information

Penroe is based in the United States, and we process and store information on servers located in the United States. By accessing or using the Services or otherwise by providing information to us, you consent to the processing, transfer and storage of your information in and to the United States, where you may not have the same rights as you do under local law. Continually, by using our Services, or by providing any Personal Information to us, where applicable law permits, you consent to the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different. Where required by law, we implement appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission or UK authorities, to protect your Personal Information.

Contact Us

If you have any further questions, concerns, comments or you would like to exercise any applicable rights listed above, please use the contact information listed below.