Penteraction, Inc. Privacy Policy

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 may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

Do we collect any information automatically? Some information (such as your Internet Protocol (IP) address and/or browser and device characteristics) is collected automatically when you visit our Services.

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.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have 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, 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.

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.

What Information Do We Collect?

Personal Information You Disclose to Us

In Short: We collect personal information that you provide to us.

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.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Usernames
• Passwords
• Contact preferences
• Contact or authentication data
• Billing addresses
• Debit/credit card numbers

Sensitive Information. We may process sensitive information when necessary with your consent or as otherwise permitted by applicable law.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

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, Twitter, or other social media account. If you choose to register in this way, we will collect certain information about you from the company's social media account, as described in the section called "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.

How You Found Us

When you create an account, we record how you arrived at our website: the campaign tags in the link you followed (the utm_ values that an ad or a newsletter adds to a link), the domain of the website that sent you, the first page you opened, and, if the link came from an ad, which ad network it came from. We do not keep the full address of the page that sent you, the ad network’s click identifier, or anything about visits that did not end in an account. This record is stored with your account and is deleted when your account is deleted.

How Do We Process Your Information?

In Short: 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 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. We may process your information so you can create and sign in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To manage your subscription and payments. We may process your information to start, renew, change, or cancel a paid plan, and to handle billing for it through our payment processor.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To act on feedback you send us. If you send us feedback through the app or by email, we process it to understand the issue and to improve the Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To learn which channels bring people to us. We use the sign-up source described under "How You Found Us", counted across accounts, to decide where to spend on advertising and outreach. We do not send it to advertisers or ad networks.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity.

Do We Use Cookies and Other Tracking Technologies?

In Short: We set a small number of strictly necessary cookies, and no advertising or cross-site tracking cookies.

We use a small number of strictly necessary cookies to keep you signed in and to protect your session. We do not use advertising cookies, cross-site tracking cookies, web beacons, or pixels. When you sign up with Google, Apple, or another provider, we hold your sign-up source in your browser’s session storage for that one tab until sign-in finishes. The full list of cookies and storage we use, what each one does, and how to control them is in our Cookie Notice: Cookie Notice.

How Do We Handle Your Social Logins?

In Short: We do not offer social logins.

You sign in to Penteraction with your email address and password. There is no option to register or sign in through a social media account, so we receive no profile information from any social media provider. Connecting a third-party app (such as Gmail or Slack) inside the product is a separate, explicit authorization you grant on that app’s own consent screen, and it is described in the sections above.

How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

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 (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

You can also set your own retention window. In Settings → Privacy, you can have conversations deleted automatically once they have been inactive for 24 hours, 7 days, 30 days, or 90 days. The same page has a "Delete All My Data" control that permanently removes your conversations, memories, documents, synced app data, and uploaded files from our servers, and a Private Mode switch that stops us from creating long-term memories and profiles derived from your conversations.

How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, 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.

Do We Collect Information from Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. 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 privacy@penteraction.ai.

What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

The email we send you: We do not send marketing email and we keep no marketing list, so there is no unsubscribe link in our messages. What we send is service email about your own account: sign-in and password messages, billing notices, results and approval requests from work you asked us to run, and a note when someone shares something with you. If you no longer want any of it, ask us to close your account: Contact.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Sign in to your account settings and update your user account.
• Delete your content data yourself at any time from Settings → Privacy ("Delete All My Data").
• Contact us using the contact information provided.

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 and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

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.

Do We Make Updates to This Notice?

In Short: 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 "Revised" date and the updated version will be effective as soon as it is accessible. 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 to be informed of how we are protecting your information.

How Can You Review, Update, or Delete the Data We Collect from You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. You can delete your content data yourself at any time from Settings → Privacy in the app. For anything else, or if you can no longer access your account, please visit: Contact.