Effective Date: June 26, 2026

This Privacy Policy (“Policy”) describes how Peny, LLC (“Peny”) collects, uses, shares, and safeguards Personal Information when you use the Peny communication platform (the “Platform”).

This Policy is part of Peny's broader legal framework, which includes the Master Services Agreement (“MSA”) and Terms of Use (“Terms of Use”), each available at https://www.penyapp.com/legal. If you are a Customer or Authorized User acting on behalf of a local government, your use is also governed by a separate agreement with Peny. In the event of conflict, that agreement will control.

This Policy describes Peny's practices. Where applicable law requires your consent for a specific practice, such as non-essential cookies, Peny requests it separately.

Capitalized words or phrases used in headings, titles, or section labels are formatted for readability only and are not intended to indicate defined terms unless explicitly stated. Certain other capitalized terms, including Customer Data, AI Interaction, Resident Submission, Resident Account Data, Account Relationship Information, and Content Engagement Data, are defined in Peny's Terms of Use.

With respect to data that Customers or their Authorized Users submit or collect through the Platform, Peny acts as a service provider on the Customer's behalf. Customers determine what information is collected from Residents through forms, submissions, and other Platform features. Peny processes such information only as necessary to provide the Platform and related services. With respect to Resident Account Data, such as name, email address, and home address collected during account creation, and information collected automatically through Platform use, such as device type, IP address, and usage activity, Peny acts as an independent data controller.

1. Scope and Application
   

This Policy applies to:

• Residents who access or interact with content from one or more Customers using the Platform,
  
• Authorized Users designated by a Customer to manage or publish content,
  
• Visitors to Peny’s public website.
  

This Policy does not apply to third-party websites, tools, or services linked to or accessed through the Platform. Peny is not responsible for the privacy practices of such third parties.

This Policy also applies to content submitted by individuals through the Platform, including AI Interactions and Resident Submissions, as defined in Peny's Terms of Use.

1. Defined Terms
   

• Authorized User: An individual designated or permitted by a Customer to access or use the Platform on the Customer's behalf, including elected officials, employees, officers, contractors, or partners acting within the scope of their authority.
  
• Customer: A local government entity (such as a city, county, or other governing body) that subscribes to the Platform and manages its own account and Authorized Users.
  
• Personal Information: Any information that identifies, relates to, describes, or can reasonably be associated with or linked to an individual, such as name, email address, home address, profile photo, IP address, or location data.
  
• Resident: A member of the public who accesses the Platform to view content, ask questions, or engage with information and features made available by a local government through the Platform.
  

1. Information Peny Collects
   

Peny may collect the following categories of information, depending on your role and how you use the Platform:

• Account and Contact Information: For Authorized Users and Customers, Peny may collect name, email address, phone number, job title, organization, and similar information provided during account setup or Platform use. For Residents, Peny collects the following information during account creation: name, email address, and home address. Residents may also optionally provide a profile photo and may provide additional information voluntarily when submitting questions, comments, or other content through the Platform. Peny does not collect a phone number from Residents. A phone number may be included in records a Customer uploads or imports, which remain available only to that Customer, or in information a Resident types into a form or other submission, which is delivered to the Customer that receives the submission. If you use the Platform without creating an account, Peny does not collect Account or Contact Information unless you voluntarily provide identifying information during an AI conversation or other interaction.
  
• AI Interactions: Private conversations between an individual and the Platform's AI features, whether or not the individual has created an account. AI Interactions are not shared with any Customer unless the individual explicitly chooses to do so, at which point the shared content becomes a Resident Submission. AI Interactions from unauthenticated users are stored by Peny but are not associated with an identified individual unless the user voluntarily provides identifying information within the conversation. AI Interactions are processed on Peny's behalf by third-party AI service providers acting as Peny's service providers, solely to generate responses.
  
• Cookies and Tracking Technologies: See Section 9 for more information.
  
• Financial Information: Peny does not collect, store, or process payment card numbers, bank account information, or other financial account data. If payment functionality is offered through the Platform, such transactions are processed by third-party payment providers and are subject to those providers' terms and privacy policies.
  
• Location Data: Peny handles three kinds of location information separately. Your home address is the address you enter when setting up your account; it is part of your Resident Account Data, used to connect you to your local government and to determine the content, alerts, zones, routes, and eligibility relevant to you, and shown to your home local government as a pin based on that stated address. It is the address you provide, not your device’s location, and it does not change unless you change it. Approximate location may be inferred from your IP address for regionally relevant content and security; it is coarse and is not precise device location. The Platform does not currently collect precise location (such as GPS) from your device. If Peny introduces features that use precise location in the future, precise location would be collected only if you grant permission through your device settings, and only when you use a feature that uses it. Any such feature would follow these commitments: Peny would use precise location only at the time you use the feature; would not track your location in the background or continuously; would not retain your precise location associated with you, except location you choose to attach to something you submit, which would be retained as part of that record; and would keep only aggregated, de-identified results that it may share with the relevant local government. Peny will update this Policy and notify you before any feature that collects precise location becomes available. Precise location is sensitive information; you would be able to grant or withdraw permission at any time in your device settings, and declining would not prevent you from using the rest of the Platform. Peny will not use precise location for materially different purposes without your consent. Peny uses third-party mapping and geocoding services, such as Google Maps, to help you enter and confirm your address; your use of those features may be subject to the third party’s terms and privacy policy. Peny does not sell location data or share it with third-party advertisers.
  
• Resident Submissions: Content directed to a Customer through the Platform. This includes form submissions, which are automatically delivered to the applicable Customer, and AI conversations the Resident explicitly chooses to share. Once directed to a Customer, this content may be accessed and managed by that Customer.
  
• Third-Party Sources: Peny may receive information from third-party services that integrate with the Platform at the direction of a Customer, such as authentication providers or external data sources. Peny processes such information in accordance with this Policy.
  
• Usage Data: Device type, IP address, browser type, operating system, and pages or features accessed. This includes logs, timestamps, and interaction data. This data is collected from all users of the Platform, including those who do not create an account.
  

The Platform is not intended for children under 16 to create an account or submit information. Peny does not knowingly collect Personal Information from individuals under 16. Peny does not collect date of birth, age, or similar demographic information during account creation and does not independently verify the age of any person accessing the Platform. If Peny becomes aware that Personal Information has been collected from an individual under 16, Peny will promptly delete that information and terminate the associated account.

1. How Peny Uses Information
   

Peny uses the information Peny collects for the following purposes:

• To provide, maintain, and operate the Platform and related services,
  
• To deliver notifications, confirmations, or responses related to submitted content,
  
• To communicate with Customers and Authorized Users,
  
• To respond to questions or feedback submitted by Residents,
  
• To analyze usage trends and maintain system performance,
  
• To comply with legal obligations, including those related to public records or accessibility,
  
• To detect and prevent fraud, abuse, or technical issues.
  

AI-Generated Responses

The Platform includes an AI assistant that generates responses using content supplied or authorized by Customers. These responses are for general informational purposes only and may be incomplete, outdated, or inaccurate. Peny does not independently verify the accuracy of AI-generated responses and disclaims any liability for reliance on them. Peny does not provide legal, financial, emergency, professional, or official government advice through automated tools.

Peny does not use Personal Information to train or fine-tune generative AI models, and Peny's AI service providers are contractually prohibited from doing so.

For more detail on AI-generated content, including disclaimers, emergency limitations, and liability, see Section 7 of Peny's Terms of Use.

1. How Peny Shares Information
   

Peny may share Personal Information in the following limited circumstances:

• With the applicable Customer: Resident Submissions are shared with the applicable Customer as described in Section 3. AI Interactions that have not been shared by the Resident remain private. Once a Resident Submission reaches a Customer, the copy the Customer receives is the Customer's record, and the Customer may use, retain, or disclose it in accordance with its own policies and applicable law.
  
• With service providers: Peny may share information with trusted third-party vendors who help operate and maintain the Platform (e.g., cloud hosting, analytics, customer support, security). These providers are contractually required to use Personal Information only as necessary to deliver services on Peny’s behalf.
  
• For legal compliance: Peny may disclose information if required by law, regulation, subpoena, or valid governmental request.
  
• To protect rights and safety: Peny may share information to detect, investigate, or prevent security issues, fraud, or abuse, and to enforce Peny’s legal rights.
  
• In connection with a business transaction: If Peny is involved in a merger, acquisition, reorganization, or sale of assets, Personal Information may be transferred as part of that transaction. In such event, the acquiring entity will be subject to the terms of this Policy with respect to any Personal Information transferred.

On the Platform, Peny does not sell Personal Information, does not share Personal Information for cross-context behavioral advertising, does not display third-party advertising, and does not use Personal Information for advertising. Peny's marketing and informational websites use standard analytics and marketing tools as described in Section 9, and you can exercise choices about them as described there.

Depending on your state of residence, you may have the right to access, correct, or delete your Personal Information, to obtain a copy of it, to limit the use of sensitive personal information, and to opt out of any sale of Personal Information or its use for targeted advertising or certain profiling. To exercise a right, contact Peny at the contact information in Section 10. Peny will verify your request and respond within the time required by applicable law. If Peny denies your request, you may appeal by replying to Peny’s decision, and Peny will inform you of the outcome and, where required, how to contact your state attorney general.

Platform Insights and Aggregated Usage

Peny may collect and analyze usage patterns, feature interactions, and anonymized or aggregated data across the Platform to maintain service quality and better understand how Residents and Customers engage with the Platform. This may include submission frequency, feature usage trends, or general engagement metrics, but not information that identifies any individual.

Peny may also provide aggregate engagement reports to Customers to help them understand patterns of community interaction. These reports do not include Personal Information. These aggregate reports are separate from, and in addition to, the account and relationship information a home local government can access, which is described in the section below titled What Your Local Government Can See About You.

Peny maintains anonymized or aggregated data without attempting to reidentify any individual and contractually prohibits recipients of such data from attempting reidentification.

What Your Local Government Can See About You

What a local government can access about a Resident through the Platform depends on whether the Resident has a home address within that government's jurisdiction. A Resident's home local government, meaning the local government in whose jurisdiction the Resident's address is located, can access that Resident's account information (name, email address, home address, and profile photo) and the Resident's relationship information with that government (newsletter subscription status, whether the Resident uses the app or the web, account creation date, signup source, whether the account has been recently active, the fact and count of non-anonymous submissions to that government, and event registrations for that government's events). It can view the home address the Resident provided, shown on a map, and can export this information and use it to communicate with the Resident.

A local government cannot see what a Resident reads. Information about which posts, newsletters, notifications, or pages a Resident views, opens, or clicks is provided to local governments only in aggregated or segment-level form that does not identify any individual Resident. Two exceptions apply. First, content a Resident intentionally submits, such as a form, poll response, or event registration, is delivered to the applicable local government. If a Resident submits while signed in, the Resident's name and email address are included with the submission and displayed to the Resident before submitting, unless the submission is made anonymously. Individuals without accounts may also submit; in that case only the information typed into the submission is delivered. Aggregated reports provided to local governments may describe how many Residents from an area viewed or participated in something, but are designed so that groups are never small enough to identify an individual. For anonymous submissions, a local government may learn at most whether the submission came from a verified resident of its jurisdiction, meaning an account whose self-reported home address is within that jurisdiction, where that setting is enabled and disclosed to the Resident before submission. Anonymous submission means only that the Platform does not attach the Resident's account identity to the submission; information the Resident enters into the submission itself, including a name or contact information entered into a form field, is delivered to the Customer as part of the submission content. Second, for notifications designated as emergency alerts, the Resident's home local government can see whether the alert reached the Resident's household during the emergency, to support any follow-up the government chooses to conduct; this delivery information is generated automatically and may be inaccurate, incomplete, or delayed.

A local government a Resident only follows, where the Resident has no address, receives only aggregated, de-identified information and does not receive the Resident's name, contact information, or individual activity, except for Resident Submissions the Resident directs to it, which are delivered as described above. No local government, whether home or followed, can access a Resident's conversations with the AI assistant unless the Resident chooses to share a specific conversation with it. A local government cannot see a Resident's relationship with, or activity on, other local governments through the Platform. If a Resident changes the home address associated with the account, the prior local government retains a record of the Resident's account information and relationship from the period the address was within its jurisdiction but loses access to current profile information and ongoing activity, and the new local government gains access from that point forward.

When a local government accesses or exports a Resident’s account information or engagement data, it acts as an independent controller of that information under its own policies and applicable law, and Peny is not responsible for the government’s use of it. Some local governments publish their own privacy policies governing their own data practices. Those policies apply only to the local government’s own use of information and do not govern Peny’s practices. This Policy governs Peny’s collection and use of information, and in any conflict regarding Peny’s practices, this Policy controls.

1. Data Retention and Security
   

Peny retains Personal Information only as long as necessary to fulfill the purposes described in this Policy or to comply with applicable law.

• Breach Notification: In the event of a security incident involving unauthorized access to or disclosure of Personal Information, Peny will notify affected parties in accordance with applicable breach notification laws.
  
• Customer Departure. If a Customer terminates its relationship with Peny, Resident Submissions directed to that Customer will be handled in accordance with the applicable Master Services Agreement. Resident Account Data and AI Interactions that are not specific to a single Customer will remain under Peny's control and subject to this Policy. Peny will not delete a Resident's account solely because a local government the Resident followed has left the Platform. Account Relationship Information and Content Engagement Data likewise remain under Peny's control, and Peny will not delete your account solely because your home local government leaves. When a local government leaves the Platform, it loses access to your information, but anything it exported or recorded while active remains in its possession, governed by that local government’s own policies and applicable law, and Peny cannot retrieve or delete it.
  
• Deletion: Residents may request deletion of their account and all associated data by contacting Peny. Peny does not offer deletion of individual records, submissions, or conversations separate from account deletion. Deletion requests will be processed in accordance with applicable law, subject to any legal retention requirements, anonymization or aggregation that has already occurred, or residual copies in backups as described under Retention below. If you use the Platform without an account, Peny will honor a request where it can reasonably associate the data with you, such as identifying information you provided in a conversation; otherwise Peny cannot process the request because there is no account or verified identity to associate with your activity.
  
• Retention: Peny retains Personal Information for the following periods, unless a longer period is required by law or a legal preservation obligation: (a) Resident Account Data, for the life of the account, deleted within 90 days after account deletion; (b) AI Interactions associated with an account, for the life of the account; (c) AI Interactions from users without an account, and Resident Submissions from users without an account, are retained only as long as needed for security, abuse prevention, and Platform operation, and are then deleted or de-identified; (d) individual-level Content Engagement Data is retained only as long as needed for the purposes described in this Policy and is then deleted or retained only in aggregated form; (e) Resident Submissions held by Peny for a Resident with an account, for the life of the account, it being understood that a copy delivered to a local government is that government's record and is retained under its policies; (f) Account Relationship Information, for the life of the account, including the historical snapshot available to a prior home local government as described above; and (g) security and system logs, retained only as long as needed for security and operations. Deletion timelines refer to removal from Peny's active systems. Deleted data may persist in encrypted backups until those backups expire in the ordinary course, no longer than thirty (30) days after deletion; backups are not used for any other purpose, and if data is restored from a backup, prior deletions are re-applied.
  
• Security: Peny uses industry-standard safeguards, including encryption, access controls, and system monitoring, to protect data in transit and at rest.
  

While Peny strives to protect your data, no system can be guaranteed 100% secure. Peny encourages Customers, Authorized Users, and Residents to follow strong security practices, including safeguarding account credentials.

Peny's liability for any claim arising under this Policy is subject to the limitations and disclaimers set forth in Peny's Terms of Use, including the limitation of liability described therein.

1. Resident Submissions and Control
   

How Peny handles Resident Submissions and AI Interactions is described in Peny's Terms of Use. In the event of any conflict between this summary and the Terms of Use, the Terms of Use will control.

Resident Submissions remain under Peny's technical control unless formally incorporated into a Customer's internal records, at which point they become Customer Data governed by that Customer's obligations. Peny retains this control to operate the Platform, maintain system integrity, enforce policies, provide support, maintain and operate Platform features, and comply with legal obligations.

Resident Submissions directed to a Customer are managed by that Customer. If you have questions about a submission, or want to remove a submission you sent, contact the relevant local government directly. To delete your account, see the Deletion bullet in Section 6. Peny is not responsible for content that has been accessed, archived, exported, or retained by a Customer, or that is subject to public records or legal retention obligations.

If you interact with the AI assistant without an account and choose to share a conversation with a local government, it will appear as a guest submission. That local government will be able to view the full conversation, including any personal information you voluntarily included. Peny cannot retrieve, modify, or delete anonymous shared conversations on an individual basis.

In short, you keep your own AI conversations, your record of what you submitted, and the notifications you received for as long as your account exists, regardless of any local government's status. Peny deletes data at the account level and cannot remove your data from one local government while keeping your account active for others. A submission carries only what it collects and any contact details you add, not your broader profile, home address, or activity with other local governments; once a local government receives or acts on a submission, the copy the government receives is its record and is not removed by deleting your Peny account. The full description is in Section 6 of the Terms of Use.

1. Public Records and Individual Rights

• Customer Responsibilities: Customers are responsible for complying with applicable laws related to public records, privacy, and accessibility, including how data is collected, published, or archived on the Platform.
  
• Deletion Requests: You may request deletion of your Personal Information by deleting your account as described in Section 6. For Personal Information contained in Resident Submissions directed to a Customer, contact the relevant local government directly. Peny processes requests in accordance with applicable privacy law. If you are an Authorized User, contact the Customer on whose behalf you act regarding account changes or deletion.
  
• Public Records Requests: Some Resident content may be accessed or retained by Customers and may be subject to public records laws under their jurisdiction. Peny provides content retention and export capabilities as described in the applicable Master Services Agreement, does not make legal determinations about what qualifies as a public record, and does not warrant that use of the Platform satisfies any jurisdiction-specific legal requirement. Customers are solely responsible for determining whether supplemental records systems or compliance tools are necessary to meet their obligations.
  

Peny will cooperate with Customers in good faith to assist with data-related requests, provided such cooperation does not require Peny to make legal determinations, impose unreasonable operational burdens, or exceed a reasonable scope without separate written agreement.

If Peny receives a subpoena, court order, or other legal process seeking access to Personal Information, Customer Data, or Resident Submissions, Peny will notify the relevant Customer (unless prohibited by law) and provide a reasonable opportunity to object or seek protective relief before disclosure. Peny may charge reasonable fees for administrative costs incurred in responding to such requests.

1. Cookies and Analytics
   

Peny uses cookies and similar technologies to operate the Platform, maintain session continuity, and understand how the Platform is used.

Cookies fall into two categories:

Essential cookies are required for core Platform functionality, such as keeping you logged in and maintaining security. These cannot be disabled.

Non-essential cookies and analytics tools support Platform performance monitoring, usage analysis, and session recording. These tools may record user interactions within the Platform, including clicks, scrolls, and navigation patterns, for both authenticated and unauthenticated users. Non-essential cookies and analytics tools are only activated with your consent.

You may accept or decline non-essential cookies when first accessing the Platform. You can change your preferences at any time through your account settings or the cookie preferences link in the Platform footer.

On the Platform, Peny does not use cookies or analytics tools to track you across unrelated websites and does not work with third-party advertising networks. Peny’s marketing and informational websites, such as https://www.penyapp.com, use standard web analytics and marketing tools, including Google Analytics and HubSpot, and may use similar tools in the future; these tools use cookies and may collect usage information for analytics and marketing, and you can exercise choices about them through the cookie controls on those sites, your browser settings, and recognized opt-out preference signals.

For a complete list of cookies and analytics tools used on the Platform, including their names, purposes, and durations, visit https://www.penyapp.com/legal. This page is updated as tools are added or changed and does not require a Privacy Policy update.

1. Changes and Contact Information

   Peny may update this Policy from time to time to reflect legal, technical, or operational changes. Updated versions will be posted on the Platform. Non-material changes are effective upon posting. For material changes, Peny will notify active users through an in-app notification and, where appropriate, require acceptance of the updated Policy before continued use of the Platform. Your continued use of the Platform after a change that is not subject to an acceptance prompt constitutes your acceptance of the revised version. Peny encourages you to review this Policy periodically.

   For questions or concerns about this Policy or Peny’s data practices, contact Peny at:

   Peny, LLC

   2326 Washington Boulevard, Ogden, UT 84401
   privacy@penyapp.com

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