PRIVACY POLICY

Effective Date: March 28, 2025

Introduction

We at Pena Holdings LLC., d.b.a. Pena Technologies ("we," "us," "our") respect your privacy. This Privacy Policy is designed to explain how we collect, use, and protect the personal information you provide to us when you access our website, purchase or use our goods or services (the "Services"), including services made available through this website and any other software or services offered by Pena Technologies, engage with our AI-powered features, or interact with us on social media, as well as your own rights to the information we collect.

Please read this Privacy Policy carefully. We will alert you to any changes to this Policy by changing the "Effective Date" at the top of this Policy. Any changes become effective immediately upon publication on our website, and you waive specific notice of any changes to the Policy by continuing to use and access our site(s) and Services. We encourage you to review this Privacy Policy periodically when you use our website or Services for any purpose, engage with our AI technologies, or interact with us on social media. You are deemed to have accepted any changes to any revised Privacy Policy by your continued use of our website and Services after the revised Privacy Policy is posted.

INFORMATION THAT WE COLLECT

We collect a variety of information from you when you visit our website, express interest in or register for our Services, make purchases, interact with our AI-powered features, or engage with us on social media. By accepting this Privacy Policy, you are specifically consenting to our collection of the data described below, to our use of the data, to the processing of this data, and to our sharing of the data with third-party processors as needed for our legitimate business interests. The information we collect may include:

PERSONAL DATA

Personal Data is information that can be used to identify you specifically, including your name, company name, shipping/billing address, email address, telephone number, or demographic information like your age, gender, or hometown. You consent to giving us this information by providing it to us voluntarily on our website, when registering for or using the Services, or when expressing an interest in obtaining information. You provide some of this information when you register with or make purchases related to our Services. You may also provide this information by participating in various activities associated with our site, including contacting us with questions. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website or Services or from making purchases.

SERVICE DATA

When using Pena Technologies’s Services, you may be able to create, upload, store, and share information such as company descriptions, email IDs, logos, photos, custom emails, user email IDs, etc. (collectively, "Service Data"). This information will be stored and maintained as part of the Services provided to you.

DERIVATIVE DATA

Derivative data is information that our servers automatically collect about you when you access our website or use our Services, such as your Internet Protocol (“IP”) address, browser type and language, the dates and times that you access our website, and the specific pages you view and links clicked ("Website Navigational Information"). If you are using a mobile application, our servers may collect information about your device name and type, your phone number, your country of origin, and other interactions with our application. Derivative data may also include data collected by third-party service providers, such as advertising and analytics providers (like Google Analytics), and may include cookies, log data, or web beacons. Cookies are discussed more fully below. Derivative data collected by third-party service providers generally does not identify a specific individual. This category may also include certain login information maintained in a cookie stored locally on your computer to streamline the login process ("Login Information") and, if you grant permission in case of technical errors, diagnostic information such as crash reports, Operating System version, hardware details, browser version, and potentially your email address ("Diagnostic Information").

VOICE AND CONVERSATION DATA

When you interact with our AI voice agents or text-based AI assistants, we may collect and process voice recordings, transcripts, and contextual information from these interactions. This data is used to provide the requested services, improve our AI systems, and enhance your user experience. We collect this information with your explicit consent, which you provide when you engage with these features. You can withdraw this consent at any time by contacting us, though this may limit your ability to use certain AI-powered features.

FINANCIAL DATA

Financial data is data that is related to your payment method, such as billing name and address, credit card number, or bank transfer details. We collect financial data in order to allow you to purchase, order, return, or exchange products or services from our website and related Services. We store limited financial data. Most financial data is transferred to our payment processor, Stripe, and you should review Stripe's Privacy Policy to determine how they use, disclose, and protect your financial data. As a courtesy, Stripe's Privacy Policy can be found here:

Stripe: https://stripe.com/privacy

SOCIAL NETWORKING DATA

We may provide you with the ability to link your Service Data to third-party sites or we may access personal information from social networking sites and apps, including Facebook, Twitter, LinkedIn, or other social networking sites or apps not named specifically here. This may include your name, your social network username, location, email address, age, gender, profile picture, and any other public information. If you do not want us to access this information, please go to the specific social networking site and change your privacy settings. Your use of links to third-party sites is at your discretion, and we are not responsible for how these third-party sites use such links or the data associated with them.

MOBILE DEVICE DATA

If you use our website or Services via a mobile device or app, we may collect information about your mobile device, including device ID, model and manufacturer, and location information. We do not currently collect real-time geo-location information but may do so in the future, in which case we will request your permission before collecting such information.

OTHER DATA

On occasion, you may give us additional data in order to enter into a contest or giveaway or to participate in a survey. You will be prompted for this information and it will be clear that you are offering this kind of information in exchange for an entry into such a contest or giveaway.

MOBILE APPLICATION INFORMATION

If you connect to us using a mobile application, we may request geolocation information, which includes permission to track your mobile device, in order to provide you with location-based services. We may also request access to certain features on your device, including your device's calendar, camera, contacts, social media accounts, Bluetooth, and storage. We may also send you "push notifications" regarding your account or our mobile application. If you wish to change our access to any of this information, you may do so by changing your device settings.

AI TECHNOLOGIES AND DATA PROCESSING

AI-POWERED FEATURES AND SERVICES

We incorporate artificial intelligence (AI) technologies in various aspects of our services, including but not limited to:

- AI text agents for customer support and communication

- AI voice agents for automated assistance

- AI-powered Quality Assurance systems

- AI features integrated into our products and services

HOW WE USE AI WITH YOUR DATA

Our AI systems may process your personal data for various purposes, including:

- Analyzing customer interactions to improve service quality

- Automating responses to common inquiries

- Providing personalized recommendations

- Quality assurance monitoring

- Enhanced security and fraud detection

- Content moderation and filtering

AI DATA PROTECTION COMMITMENTS

We are committed to using AI technologies responsibly and ethically. When processing your data with AI systems, we:

- Do not use AI to make automated decisions with significant legal or similar effects without human oversight

- Implement technical safeguards to prevent unauthorized access to data processed by our AI systems

- Train our AI systems on properly authorized data in compliance with applicable laws

- Maintain transparent AI processes with appropriate human supervision

- Regularly test and audit our AI systems for bias, security vulnerabilities, and compliance with this privacy policy

- Apply the principle of data minimization to ensure our AI systems only process the data necessary for their intended functions

- Provide you with the right to opt out of AI-based processing where feasible

VOICE RECORDING AND PROCESSING

When you interact with our AI voice agents:

- Voice recordings are processed to provide the requested service and may be retained for quality assurance, training purposes, and service improvement

- You will be notified when voice recording begins and have the option to opt-outVoice data may be transcribed into text for further processing

- We implement enhanced security measures for voice data

- You can request deletion of your voice recordings by contacting [email protected]

HOW WE USE YOUR INFORMATION

Your information allows us to offer you certain products and Services, including the use of our website and AI-powered features, to fulfill our obligations to you, to customize your interaction with our company and our website/Services, and to allow us to suggest other products and services we think might interest you. We generally store your data and transmit it to a third party for processing. However, to the extent we process your data, we do so to serve our legitimate business interests (such as providing you with the opportunity to purchase our goods or services and interact with our website, Services, AI systems, or mobile app).

Specifically, we may use the information and data described above to:

- Create and administer your account;

- Develop, deliver, administer, and improve our Services;

- Process your transactions and manage your account;

- Correspond with you, including providing updates and product announcements;

- Process payments or refunds;Contact you about new offerings that we think you will be interested in (subject to your communication preferences);

- Interact with you via social media;

- Send you a newsletter or other updates about our company or website (subject to your communication preferences);

- Deliver targeted advertising;Request feedback from you;

- Notify you of updates to our product and service offerings;

- Resolve disputes and troubleshoot any problems, including analyzing diagnostic information;

- Administer contests or giveaways;

- Generate a profile that is personalized to you, so that future interactions with our website/Services will be more personal;

- Compile anonymous statistical data for our own use or for a third party's use (such as usage statistics);

- Monitor and analyze use of the Services for technical administration, functionality, user-friendliness, and authorization verification;

- Assist law enforcement as necessary;

- Prevent fraudulent activity on our website, mobile app, or Services;

- Analyze trends to improve our website and offerings;

- Train and improve our AI systems;

- Provide AI-powered customer support and product features;

- Conduct quality assurance reviews of interactions.

WHEN DO WE COLLECT INFORMATION?

We collect information from you when you subscribe to a newsletter, fill out a form, enter information on our site, register for or use our Services, make a purchase, interact with our AI-powered features or agents, or engage with our customer support systems.

HOW DO WE PROTECT VISITOR INFORMATION?

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information. All payment transactions are processed through a gateway provider (Stripe) and are not stored or processed on our servers beyond what is necessary for transaction confirmation and record-keeping.

For AI-processed data, we implement additional security measures, including:

- Encrypted storage of voice recordings and transcriptsAccess controls limiting which staff can access AI-processed data

- Regular security audits of our AI systems

- Data anonymization techniques where appropriate

- Regular deletion of AI training and processing data when no longer needed

DATA SHARING COMMITMENT

WE DO NOT SELL YOUR DATA

We do not sell, rent, trade, or otherwise transfer to outside parties your personally identifiable information for their marketing or promotional purposes. Your information will never be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested and as outlined in this Policy.

LIMITED SHARING WITH SERVICE PROVIDERS

We may share your information with trusted third-party companies and individuals who assist us in operating our website, conducting our business, providing, analyzing, and improving the Services (including, but not limited to, data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Services’ features). These service providers may have access to your information strictly for the purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy. These service providers include:

- Payment processors (Stripe) – solely for the purpose of processing your payments

- Email service providers – solely for sending communications you have opted intoWebsite hosting services – solely for the purpose of hosting our website and its content

- Analytics providers (like Google Analytics) – for monitoring and analyzing use of the Services

- SMS message aggregators and providers – solely for delivering text messages you have opted into receiving

- AI technology providers – to power our AI-enabled features and services

- Cloud storage providers – for secure storage of data processed by our systems

These third parties are obligated to protect your information and are contractually prohibited from using your personally identifiable information for any other purpose beyond providing services to Pena Technologies. They are authorized to use your personal information only as necessary to provide these services to us.

AI SERVICE PROVIDER LIMITATIONS

When we engage third-party AI service providers, we impose the following limitations:

- AI service providers may only process your data for the specific purposes outlined in our agreements

- They must implement appropriate technical and organizational security measures

- They cannot use your data to train their AI models for purposes outside of providing services to us without your explicit consent

- They must comply with all applicable data protection laws and regulations

- They must promptly notify us of any security incidents or unauthorized data access

- They must delete or return all personal data upon termination of services

Important Note About SMS Data:

All text messaging originator opt-in data and consent information will not be shared with any third parties, excluding aggregators and providers of the Text Message services necessary to deliver the SMS service. Your mobile information will not be shared with third parties or affiliates for marketing or promotional purposes.

OTHER LIMITED DISCLOSURES

We may also disclose your information:

- As required by law, such as to comply with a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or similar legal process, including subpoenas from private parties in a civil action. If a subpoena seeks information about an identified subscriber or limited group of subscribers, we will make reasonable business efforts to contact the subscriber(s) before providing information, where permissible and feasible.

- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or other illegal activity, or respond to a government request.

- To enforce our Terms of Service or other agreements.

- To your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

- In the event of a merger, acquisition, bankruptcy, sale of assets, or other business transition. If such an event occurs, the successor company would have access to the information maintained by Pena Technologies but would continue to be bound by this Privacy Policy until it is amended. Users will be notified via prominent notice on the site or via email for 30 days after a change of ownership or control affecting their personally identifiable information.

- To our parent companies, subsidiaries, and joint ventures to help coordinate the services we provide, enforce our terms and conditions, and promote trust and safety.

- We may disclose your non-private, aggregated, or otherwise non-personal information, such as usage statistics of our Services, at our discretion.

COOKIES

We may use cookies and similar technologies like web beacons ("Website Navigational Information") for tracking purposes and to operate and improve the Services. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information (e.g., standard information from your web browser like type and language, IP address, actions taken on the site).

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer, Chrome, Firefox, or Safari) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

If you disable cookies, some features may be disabled, and some of our Services may not function properly.

THIRD PARTY INTEGRATIONS

GOOGLE

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users.

https://support.google.com/adwordspolicy/answer/1316548?hl=en

We may use Google services such as Google Analytics and Google Ads. This may involve implementing:

- Remarketing with Google Ads

- Google Display Network Impression Reporting

- Demographics and Interests Reporting

We, along with third-party vendors such as Google, may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Google's use of advertising cookies enables it and its partners to serve ads to users based on their visit to our sites and/or other sites on the Internet.

- Opting out of Google Analytics:You can opt out of having your activity on our website made available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents Google Analytics from retrieving information about your visits to our website. For more information about Google's Privacy Policy, please visit:https://policies.google.com/privacy.

- Opting out of Personalized Advertising:Users may opt out of personalized advertising by visiting Google's Ads Settings or by visiting www.aboutads.info.

FACEBOOK

Facebook's advertising requirements can be summed up by Facebook's Advertising Principles.
https://www.facebook.com/policies/ads/

We may implement:

- Advertising with Facebook AdvertisingRetargeting with Facebook AdvertisingDemographics and Interests Reporting

- We, along with third-party vendors such as Facebook, may use first-party cookies (such as the Facebook Pixel) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

- Opting out of Facebook's interest-based ads: You can opt out of Facebook's interest-based ads by visiting:https://www.facebook.com/help/568137493302217.

- You can learn more about Facebook's Privacy Policy at: https://www.facebook.com/full_data_use_policy.

GROUNDS FOR USING AND PROCESSING YOUR DATA

The information we collect and store is used primarily to allow us to offer and provide the Services. In addition, we may collect, use, and process your information based on the following grounds:

- LEGITIMATE BUSINESS INTERESTS: We may use and process your data for our legitimate business interests, which include, among other things, providing and improving our Services, communicating with you, ensuring security, preventing fraud, analyzing usage, and providing you with information or products you have requested.

- PERFORMANCE OF A CONTRACT: We may use and process your information to enter into a contract with you (like our Terms of Service) and to perform our contractual obligations to you.

- CONSENT: We may use your data, or permit selected third parties to use your data, based on your consent to our use and sharing of that data (e.g., for certain marketing communications, SMS messaging, AI voice interactions, or optional features). You may withdraw your consent at any time, but doing so may affect your ability to use our website or Services.

- AS REQUIRED BY LAW: We may also use or process your data as required for us to comply with legal obligations.

INTERNATIONAL DATA

Our website and Services are hosted on servers located in the United States. Therefore, if you reside outside the United States, some of your data will be transferred internationally to and stored on those servers. In addition, we may use third-party processors and subcontractors located in the United States. We use reasonable methods to protect the safety of your data during transfer, including hosting on reputable servers and engaging reputable third-party processors. By using our Site and Services and providing us with information, you consent to this transfer, processing, and storage of your information in the United States. Note that the privacy laws in the United States may differ from those in other countries. Please be aware that:

- We may transfer data that we collect to locations outside of our headquarters for processing or storing, and the data may be processed by our staff or by third-party processors. By submitting your personal data, you agree to this transfer, storing, and processing. We take reasonable steps to ensure your data is treated securely and in conformity with this Privacy Policy.

- Data that is provided to us is stored on secure servers. Payment information and other sensitive data will be encrypted where appropriate.

- The transmission of data via the internet is never completely secure, and we cannot guarantee the security of data sent to us electronically. Your transmission of data to us is at your own risk.

- Where data that you have transmitted to us is password protected, you are responsible for keeping the password confidential. You are exclusively responsible for any breaches of your data that result from your own disclosure of or failure to protect your password.

DATA RETENTION

We retain personal data for as long as your account is active or as needed to provide you the Services, conduct our legitimate business purposes, or comply with our legal obligations, or until you ask us to delete your data. For example, we will retain certain personal information indefinitely for the purposes of maintaining your account, unless and until you delete your account. Data that we gather for a specific and particular purpose, such as assisting law enforcement or analyzing trends, will be kept for no longer than is necessary for that particular purpose. Data that is no longer needed by us for any of the purposes listed above will be appropriately deleted or anonymized.

If you wish to cancel your account or request that we no longer use your information to provide you the Services, you may request account deletion by contacting [email protected] (subject to verification). If you delete your account, your Service Data stored within the active service environment will be removed. Please be aware that there may be a delay between your request and the removal of data, and some data may persist for a limited period in backup copies or logs before being permanently deleted, as necessary for business continuity, legal, or compliance purposes.

For AI-processed data, including voice recordings and interaction data:

- Voice recordings are typically retained for no more than 90 days unless a longer retention period is necessary for legal compliance, dispute resolution, or ongoing service improvement.

- Conversation transcripts may be retained for up to 12 months to improve our AI systems and service quality.

- Anonymized or aggregated data derived from AI interactions may be retained indefinitely for analytical purposes.

We will honor your request to delete your data, as described more fully below, unless we are required by law or have a compelling legitimate interest (e.g., defense of legal claims) to retain access to the data. Note that we cannot control the retention policies of third parties. If you wish to have any third parties, including those to whom we've transmitted your data, delete that data, you will need to contact those third parties directly.

We may retain usage data (that is, data gathered by our company or third-party analytics companies for analyzing website/Service use) as needed for internal analysis purposes. This type of data is usually retained for a shorter period than personal data, unless the data is necessary to improve security or functionality, or we are legally obligated to retain it longer.

SECURITY OF YOUR INFORMATION

We take reasonable steps and implement generally accepted standards of security to protect your personal data and keep your information secure from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We use recognized online secure payment systems and technical safeguards like encryption (e.g., SSL) where appropriate. However, no security measure is foolproof, and no method of data transmission can be guaranteed against interception or misuse. We cannot guarantee the complete security of any information you transmit to us.

By consenting to this Privacy Policy, you acknowledge that your personal data may be available, via the internet, around the world. We cannot prevent the use or misuse of your data by other parties.

We will notify you promptly, as required by applicable law, of any known breach of our security systems or your data which might expose you to serious risk.

SENSITIVE DATA

We request that you do not submit any sensitive personal data (e.g., social security number, health data, genetic data, information related to racial or ethnic origin, political opinions, religious beliefs, trade union membership, or criminal history) to us through general contact forms, public postings, email correspondence, or similar methods, unless specifically required for a particular Service feature and collected through a secure, designated channel. If you do send us this information through non-designated channels, then by doing so you are consenting to our use, storage, and processing of this information in accordance with this privacy policy, although we do not intend to collect or process such data.

SPECIAL NOTE ABOUT AI VOICE AND TEXT INTERACTIONS

Our AI systems are designed to detect and prevent the collection of sensitive data where possible. However, if you inadvertently share sensitive information during an interaction with our AI technologies:

- We will make reasonable efforts to delete such information upon detection.

- We may implement automatic filtering systems to identify and remove sensitive data from AI training datasets.

- Human reviewers who may access conversation data for quality assurance purposes are bound by strict confidentiality obligations.

- You may request immediate deletion of any interaction containing sensitive information by contacting [email protected].

SMS/TEXT MESSAGE PRIVACY

If you have opted in to receive SMS/text messages from us, we are committed to protecting your privacy regarding these communications:

- No Data Sharing: All text messaging originator opt-in data and consent information will not be shared with any third parties, excluding the aggregators and providers necessary to deliver the SMS service.

- Marketing Restrictions: Your mobile information will not be shared with any third parties or affiliates for marketing or promotional purposes via SMS unless you have explicitly consented to such use.

- Limited Use: Your SMS opt-in data will only be used for the specific purposes you have consented to (e.g., service updates, alerts, support, or promotions you opted into).

- Opt-Out Control: You can stop receiving text messages at any time by replying "STOP" to any message you receive from us. Upon doing so, we will confirm your opt-out status via SMS and will cease sending you text messages for that specific program.

YOUR RIGHTS

You have certain rights with respect to your personal data, as outlined below. Note that we may charge you a reasonable fee for actions that you ask us to take with respect to your data if requests are manifestly unfounded or excessive. In addition, we reserve the right to request that you provide us with evidence of your identity before we take any action with respect to the exercise of your data rights. Further, your rights may be restricted or nullified to the extent they conflict with our compelling business interests (e.g., security, fraud prevention, legal compliance), the public interest, or the law.

UPDATE ACCOUNT INFORMATION

You have the right to update or change information you have provided to us. You may be able to do this through your account settings or by contacting us at [email protected].

CONFIRM PERSONAL DATA AND ITS USE

You have the right to request that we confirm what data we hold about you, and for what purposes. You also have the right to confirmation of whether we process your data or deliver your data to third-party processors, and for what purposes. We will supply you with copies of your personal data unless doing so would affect the rights and freedoms of others.

CHANGE CONSENT

You have the right to change or withdraw your consent to our use of your information where consent is the basis for processing. In such cases, we may require you to delete your account with us, and you may not have full access to our website or Services.

REQUEST A COPY OF DATA (Data Portability)

You have the right to request a digital copy of the personal data that we hold about you that you provided to us, in a commonly used and machine-readable format, where processing is based on consent or contract. Your first request for a copy of your personal data will be provided free of charge; subsequent requests may incur a reasonable fee.

TRANSFER YOUR DATA

Where technically feasible, you have the right to request that we transfer your data directly to another controller, under the conditions applicable to the right to data portability.

DELETE ALL DATA (Right to Erasure / "Right to be Forgotten")

You have the right to request that we delete personal data that we hold about you, and we must delete such data without undue delay under certain circumstances (e.g., the data is no longer necessary, you withdraw consent, you object and there are no overriding legitimate grounds). There are exceptions to this right, such as when keeping your data is required by law, is necessary to exercise the right of freedom of expression and information, is required for compliance with a legal obligation, or is necessary for the establishment, exercise or defense of legal claims. Such a request may result in a termination of your account with us and you may have limited or no use of our website or Services.

OBJECT TO PROCESSING

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on legitimate interests or the performance of a task carried out in the public interest. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Where personal data are processed for direct marketing purposes, you have the right to object at any time.

RESTRICT PROCESSING

You may, in some circumstances, obtain restriction of processing of your data, such as when you contest the accuracy of your data or when you have objected to processing, pending the verification of that objection. When processing has been restricted, we will continue to store your data but will generally not process it further without your consent, or as necessary to comply with legal obligations or protect rights.

AI-SPECIFIC RIGHTS

In addition to the above rights, you have the following rights specifically related to our AI technologies:

- Right to opt out of AI voice recording: You may opt out of having your voice recorded and processed by our AI voice agents at the beginning of an interaction or by contacting us.

- Right to access AI decisions: You may request information about the logic involved in any significant automated decisions made about you by our AI systems, where applicable.

- Right to human review: Where a decision made solely by automated means produces legal or similarly significant effects concerning you, you may have the right to request human review of that decision.

- Right to AI data deletion: You may request the deletion of specific voice recordings, transcripts, or other data collected through your interactions with our AI systems, subject to the general conditions for data deletion.

To exercise any of these rights, please contact us at [email protected].

EMAILS AND COMMUNICATIONS

You may opt out of receiving future non-essential email correspondence (like marketing or newsletters) from us by using the unsubscribe link found at the bottom of the email or by contacting us at [email protected]. We may still send you essential communications regarding your account or transactions, service updates, or security notices.

MARKETING COMMUNICATIONS

You may opt out of receiving any third-party marketing communications facilitated by us or having your personal information used for direct marketing purposes by contacting us at [email protected].

COMPLAINTS

If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, or certain other jurisdictions, you may have additional rights with respect to your Personal Data under laws like the EU’s General Data Protection Regulation (“GDPR”). If you believe we are misusing your data or have violated any of your rights under this Privacy Policy or applicable law, you have the right to file a complaint with us directly at [email protected] or with a relevant supervisory authority or data protection agency.

CALIFORNIA PRIVACY RIGHTS

The State of California has established its own unique regulations that apply to California residents, primarily under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

If you are a California resident, you may have the right to request, free of charge (up to twice per year), information about the personal information we have collected, disclosed, or sold/shared about you in the preceding 12 months. You may also have the right to request deletion or correction of your personal information and to opt-out of the "sale" or "sharing" (as defined under CCPA/CPRA, which may include certain types of online advertising or data transfers for value) of your personal information. For security purposes, we reserve the right to ask for verification of your identity and proof of your California residency at the time of your request.

California residents may have the right to request access to, deletion of, or correction of the personal data we have collected, which may include categories such as:

- Identifiers (e.g., real name, alias, address, IP address, email address, account name)Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., name, address, telephone number, employment)

- Commercial information (e.g., products or services purchased, obtained, or considered, purchasing or consuming histories)

- Internet or other electronic network activity information (e.g., browsing history, search history, interaction with a website, application, or advertisement)

- Geolocation data

- Professional or employment-related informationInferences drawn from other personal information to create a profileAudio, electronic, visual, or similar information (e.g., voice recordings from interactions with our AI systems)

We DO NOT "sell" your personal information in the traditional sense of exchanging it for money. However, certain data sharing practices, particularly related to online advertising or analytics, might be considered a "sale" or "sharing" under the broad definitions of CCPA/CPRA. California residents can contact us at [email protected] to exercise their rights, including requesting access, deletion, correction, or opting out of sale/sharing. You may also have the right to limit the use and disclosure of sensitive personal information.

We agree to comply with any verifiable consumer request made pursuant to the CCPA/CPRA in a reasonable timeframe and manner, as required by law.

COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)

Our Services are not directed to children under the age of 13. We do not specifically market to children under 13 and do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will take steps to remove that information from our servers. If you believe that we might have any information from or about a child under 13, please contact us at [email protected].

FAIR INFORMATION PRACTICES

The Fair Information Practices Principles form the backbone of privacy law in the United States. In order to be in line with Fair Information Practices, should a data breach occur that is likely to result in a high risk to the rights and freedoms of individuals, we will take appropriate responsive action, including notifying affected users via email or prominent website notice within a reasonable timeframe (e.g., 7 business days, or as required by law) and notifying relevant authorities where required.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law.

CAN SPAM ACT

The CAN-SPAM Act sets rules for commercial email. We collect your email address in order to send information, respond to inquiries, process orders, and send marketing communications (where consented). To be in accordance with CAN-SPAM, we agree to:

- NOT use false or misleading subjects or email addresses.Identify the message as an advertisement in some reasonable way (if applicable).

- Include the physical address of our business: 5900 Balcones Dr Ste 100, Austin, TX.

- Monitor third-party email marketing services for compliance, if one is used.

- Honor opt-out/unsubscribe requests quickly.

- Allow users to unsubscribe by using the link at the bottom of each non-essential email.

If at any time you would like to unsubscribe from receiving future marketing emails, you can email us at [email protected] or follow the instructions at the bottom of each email, and we will promptly remove you from relevant marketing correspondence.

CONTACT INFORMATION

If you have any questions regarding this Privacy Policy or wish to exercise your rights, please contact us at:

• Email: [email protected]

• Address: Pena Holdings LLC. d.b.a. "Pena Technologies" Attn: Privacy Inquiry 5900 Balcones Dr Ste 100

• Austin, TX

Last Updated: March 28, 2025