Terms of Use

Terms of Use

Effective Date: February 24, 2026

These Terms of Use (“Terms”) govern access to and use of the Peny communication platform (the "Platform"), operated by Peny, LLC ("Peny”), and are part of Peny’s legal framework, which includes the Master Services Agreement (“MSA”) and Privacy Policy ("Privacy Policy"). If a separate written agreement (such as an MSA) governs your use of the Platform, that agreement will control in the event of a conflict with these Terms.

By accessing or using the Platform, you agree to comply with these Terms and all applicable laws. If you do not agree, do not use the Platform. The Platform is used by Customers, Authorized Users, and Residents, each as defined in Section 2.

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.

  1. Eligibility and Age Requirements

You must be at least sixteen (16) years old to create an account or use the Platform. If you are under 16, you may only use the Platform with the consent of a parent or legal guardian. The Platform is not intended for children under 16, and Peny does not knowingly collect Personal Information from children under 16. If Peny becomes aware that an account has been created by or for a person under 16 without parental consent, or by or for a person under 13 regardless of consent, Peny may terminate that account and delete any associated Personal Information.

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. Peny's obligations under this section are limited to actions taken upon actual knowledge. Peny is not liable for inaccurate or incomplete information provided during registration.

  1. Defined Terms
  • AI Interaction: A private conversation between a Resident and the Platform's AI features. AI Interactions are not shared with any Customer unless the Resident explicitly chooses to do so, at which point the shared content becomes a Resident Submission.
  • Anonymized or Aggregated Data: Data derived from Platform usage or content provided through the Platform that has been de-identified such that it does not identify any individual, specific Customer, or Resident.
  • 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.
  • Customer Data: Content submitted or generated by a Customer or its Authorized Users in connection with its account, as well as Resident Submissions that have been formally incorporated into a Customer's internal records. Customer Data may include Personal Information but excludes Anonymized or Aggregated Data, AI Interactions that have not been shared with a Customer, and Resident Account Data.
  • 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.
  • Platform Analytics: Anonymized or aggregated data about how the Platform is used, such as post view counts and engagement trends. Platform Analytics do not identify any individual.
  • 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.
  • Resident Account Data: Personal Information a Resident provides when creating or maintaining an account, such as name, email address, home address, and profile photo.
  • Resident Submission: Content a Resident intentionally directs 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. Resident Submissions are hosted by Peny and remain under Peny's technical control unless formally incorporated into a Customer's internal records.
  1. Platform Purpose

The Platform is designed to help local governments communicate with their communities in a centralized and accessible environment.

Residents may use the Platform to:

  • Follow and interact with one or more Customers,
  • View announcements and updates published by Customers,
  • Ask questions or provide feedback.

Authorized Users may use the Platform to publish content, manage communications, and respond to Resident Submissions on behalf of their Customer.

Peny operates the Platform as a shared service across all participating Customers. Peny is a neutral technology provider and does not represent, speak on behalf of, or assume responsibility for any Customer's content, decisions, or communications. Peny does not moderate or verify the accuracy of Customer content and does not guarantee that Resident Submissions will be reviewed or responded to by any Customer.

The Platform may contain links to third-party websites, tools, or resources. These links are provided for convenience only and do not constitute endorsement, sponsorship, or recommendation by Peny. Peny is not responsible for the availability, content, accuracy, or privacy practices of any third-party site or resource. Your use of third-party links is at your own risk.

Peny reserves the right to modify, update, or discontinue any feature or functionality of the Platform at any time, with or without notice. Peny will not be liable to you or any third party for any modification, suspension, or discontinuance of any part of the Platform.
Peny does not guarantee that files or content available through the Platform will be free of viruses, malware, or other harmful components. You are responsible for implementing appropriate safeguards on your own devices.

  1. Acceptable Use

All Customers, Authorized Users, and Residents must comply with the following requirements when using the Platform:

  • Do not use the Platform for illegal, fraudulent, or harmful purposes.
  • Do not post content that is defamatory, obscene, harassing, misleading, or otherwise objectionable.
  • Do not upload or distribute malware, viruses, or other malicious code.
  • Do not impersonate others or misrepresent your identity or affiliation.
  • Do not use the Platform to infringe intellectual property or other proprietary rights.
  • Do not attempt to bypass security features or access unauthorized areas of the Platform.
  • Do not use bots, scrapers, crawlers, or other automated tools to access, extract, copy, or interact with the Platform or its content, including for the purposes of training artificial intelligence or machine learning models. This prohibition does not apply to commercially recognized search engines (such as Google and Bing) indexing publicly available content. Peny reserves the right to block any automated access at its sole discretion.

You are solely responsible for all content you post, submit, or transmit through the Platform, including its accuracy, legality, and appropriateness. Peny does not control, verify, or endorse content provided by Customers, Authorized Users, or Residents, and will not be liable for any content posted by any party other than Peny.

Peny may suspend or remove content or access to the Platform at its sole discretion if these Terms are violated.

Prohibited Commercial Use

The Platform may not be used by Customers or Authorized Users to sell, distribute, or generate revenue from commercial advertising, paid placements, or third-party promotional campaigns. Customers may reference event sponsors or partners in connection with legitimate government activities (such as listing sponsors of a community event), but may not use the Platform as an advertising channel for third parties. Peny reserves the right to remove or restrict such content at its sole discretion.

  1. Accounts

Certain features of the Platform, including browsing content and interacting with the AI assistant, are available without creating an account. If you use the Platform without an account, these Terms still apply to your use. However, Peny will not be able to associate your activity with an identifiable individual unless you voluntarily provide identifying information (such as your name) during an AI conversation. If you use the Platform without an account, Peny cannot process data access or deletion requests because there is no account or verified identity to associate with your activity.

Some features of the Platform may require you to create an account. If you register, you agree to:

  • Provide accurate, current, and complete information,
  • Maintain the confidentiality of your login credentials,
  • Notify Peny or your local government of any unauthorized access or security incident.

You are responsible for all activity that occurs under your account. If you are an Authorized User acting on behalf of a Customer, that Customer is responsible for managing your access, permissions, and compliance with these Terms. Peny will have no liability for any loss, damage, or claim arising from unauthorized access to the Platform through your account credentials, regardless of how such credentials were obtained by an unauthorized party.

Your account is personal to you and may not be transferred, assigned, or shared with any other person. Any rights to your account and its contents terminate upon your death.

If you are an Authorized User, your account access is subject to the control of the Customer on whose behalf you act, which may reassign, suspend, or deactivate your access at any time.

Peny reserves the right to establish limits on storage, usage, or other Platform features, and to suspend or deactivate accounts that remain inactive for an extended period. Peny is not responsible for the deletion or failure to store any content or data maintained on the Platform.

  1. Resident Submissions and Control

Different types of data are generated when you use the Platform, including AI Interactions and Resident Submissions, each as defined in Section 3.

Peny retains technical control over all Resident Submissions and AI Interactions to operate the Platform, maintain system integrity, enforce policies, provide support, operate and maintain Platform features, coordinate with Customers when necessary, and comply with legal obligations. Customers may access or manage Resident Submissions directed to them, but Peny may also access Resident Submissions and AI Interactions for any of the purposes described in this section.

Peny does not use Resident content for unrelated purposes. Access is limited to authorized personnel, logged for accountability, and governed by internal controls.

If you wish to access or delete a Resident Submission, you should contact the relevant local government directly. If you wish to delete your account and all associated data, including AI Interactions, you may contact Peny at the contact information in Section 15. Peny does not offer deletion of individual records, submissions, or conversations separate from account deletion.

If you interact with the AI assistant without an account, your conversation is stored by Peny but is not associated with an identified individual. If you choose to share an anonymous conversation with a Customer, it will appear as a guest submission and the Customer will be able to view the full conversation. Any personal information you voluntarily include in a conversation may become visible to the Customer upon sharing.

Peny may access, preserve, and disclose account information and content if Peny believes in good faith that such action is necessary to: (a) comply with applicable law or legal process; (b) enforce these Terms; (c) respond to claims that content violates the rights of third parties; (d) provide support; or (e) protect the rights, property, or safety of Peny, its Customers, or the public.

Requests to delete content will be honored only to the extent permitted by law. 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. Peny is not obligated to mediate, coordinate, or resolve disputes between Residents and Customers regarding data access or deletion.

  1. AI-Generated Responses

How the AI Assistant Works

The Platform includes an AI assistant that generates automated responses using content supplied or authorized by Customers. While the AI assistant is designed to respond using only Customer-supplied content, AI technology is inherently probabilistic and may occasionally misinterpret, oversimplify, or draw inferences beyond the information provided. Peny maintains visible disclaimers across all interfaces where Residents interact with AI-generated content, informing them that responses may be incomplete or inaccurate and that important information should be verified directly with the applicable Customer.

For Residents

AI-generated responses are for general informational purposes only and may be incomplete, outdated, or inaccurate. They do not constitute legal, financial, emergency, professional, or official government advice. For critical matters, including but not limited to building, zoning, permitting, code compliance, public safety, and legal requirements, you should confirm information through direct contact with the appropriate city department.

AI-generated responses may reference or summarize Customer-published content, but such references do not guarantee that the underlying content is current, complete, or applicable to your situation.

For Customers and Authorized Users

Peny does not originate, verify, or control any content published by Customers, including emergency communications. All emergency content on the Platform is published solely at the direction of the applicable Customer, and Peny has no obligation to monitor for, initiate, or ensure the timeliness of emergency communications. Peny is not responsible for any Customer's failure to publish, update, or maintain emergency information.

Liability

Peny disclaims all liability for reliance on AI-generated content and does not guarantee the accuracy, completeness, or suitability of any automated response. The absence of content on the Platform should not be interpreted as an indication that no emergency exists. Peny will have no liability for any harm arising from a Resident's reliance on content published on the Platform, or on the absence of content on the Platform, during an emergency event.

  1. Ownership and License

Peny's Ownership

All rights, title, and interest in the Platform, including its software, features, tools, interfaces, AI functionalities, and underlying technology, are owned by Peny. Peny retains ownership and control over all Resident Submissions, AI Interactions, Resident Account Data, and Platform Analytics, except as otherwise required by law or under a specific agreement with a Customer or Resident. Peny may use, publish, and sublicense Anonymized or Aggregated Data for analytics, benchmarking, operational purposes, and other lawful business purposes.

Customer Data

Customers retain ownership of their Customer Data. By using the Platform, Customers grant Peny a limited license to use, process, and transmit Customer Data solely to provide and operate the services. This license does not transfer ownership of Customer Data to Peny.

Your License to Use the Platform

You receive a limited, non-exclusive, non-transferable license to use the Platform solely for its intended purposes and in accordance with these Terms. You may not copy, modify, reverse-engineer, decompile, disassemble, resell, sublicense, distribute, or create derivative works based on the Platform or any of its components. Any unauthorized use may violate applicable intellectual property, copyright, and trademark laws.

Feedback

If you provide Peny with any feedback, suggestions, or ideas regarding the Platform, you agree that Peny may use, disclose, or incorporate such feedback for any purpose without obligation, compensation, or attribution to you. All feedback becomes the sole property of Peny.

Copyright Infringement Notices

Peny respects the intellectual property rights of others. If you believe that content on the Platform infringes your copyright or other intellectual property rights, you may submit a notice to Peny at notice@penyapp.com with the following information: (i) a description of the copyrighted work you claim has been infringed; (ii) a description of where the allegedly infringing content is located on the Platform; (iii) your contact information; (iv) a statement that you have a good faith belief that the use is not authorized by the copyright owner, its agent, or the law; and (v) a statement, made under penalty of perjury, that the information in your notice is accurate and that you are the copyright owner or authorized to act on the owner's behalf. Peny may remove or disable access to content that is alleged to infringe.

  1. Compliance Disclaimer

Peny is not a system of record, public records archive, or compliance platform. Peny does not warrant that use of the Platform will satisfy jurisdiction-specific legal obligations related to recordkeeping, retention, public notice, or disclosure. Customer is solely responsible for determining whether its use of the Platform meets applicable legal requirements. Customers, Authorized Users, and Residents are solely responsible for determining whether supplemental tools, workflows, or procedures are necessary to meet regulatory, public records, or accessibility requirements.

  1. Accessibility Disclaimer

    Peny designs the Platform with the goal of supporting accessibility, using the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA as a reference standard across the Platform's user interface. However, Peny does not review, audit, or certify the accessibility of any content or communications published by Customers. Each Customer is solely responsible for ensuring that its use of the Platform, including all content, services, and interactions, complies with applicable accessibility laws, including the Americans with Disabilities Act (ADA), Section 508 of the Rehabilitation Act, and other jurisdiction-specific standards.

  2. Disclaimers and Limitations of Liability

    The Platform is provided “as is” and “as available.” Peny makes no warranties, express or implied, regarding the accuracy, availability, or reliability of the Platform or any content provided through it.

    To the fullest extent permitted by law, Peny disclaims all warranties, whether express, implied, statutory, or otherwise, including implied warranties of merchantability, fitness for a particular purpose, non-infringement, and quiet enjoyment. These disclaimers apply regardless of the legal theory under which any claim is brought, whether in contract, tort, negligence, strict liability, or otherwise.

    Peny is not liable for any direct, indirect, incidental, special, consequential, punitive, or exemplary damages, or for any damages of any type, including loss of data, use, goodwill, profits, revenue, costs of breach notification, credit monitoring, regulatory fines, or reputational harm, even if Peny has been advised of the possibility of such damages, regardless of how such damages are characterized.

    Peny’s total liability to any individual Resident for any claim related to use of the Platform will not exceed one hundred dollars ($100), regardless of the nature of the claim or any fees paid by a Customer. This limitation applies to all claims, including those arising from reliance on AI-generated content.

    Some jurisdictions do not allow certain warranty disclaimers or limitations of liability, so some of the above may not apply to you.

    Indemnification

    You agree to indemnify, defend, and hold harmless Peny and its officers, directors, employees, and agents from and against any third-party claims, losses, damages, expenses, and costs (including reasonable attorney's fees) arising from: (i) your use or misuse of the Platform; (ii) content you submit through the Platform; (iii) your violation of these Terms or applicable law; or (iv) your violation of any third-party rights. This obligation survives termination of your account or these Terms. If you are a Customer or Authorized User, your indemnification obligations are governed by the applicable Master Services Agreement, and this paragraph does not expand or modify those obligations.

  3. Termination

    You may stop using the Platform at any time. Peny may suspend or terminate your access if:

  • You violate these Terms or applicable law,
  • You interfere with the Platform’s operation or integrity,
  • Required by legal or governmental request,
  • The applicable Customer terminates its relationship with Peny.

If you delete or deactivate your account, or if Peny suspends or terminates your access under this section, your access to the Platform will be disabled. Data associated with your account will be handled in accordance with Peny's Privacy Policy. Resident Submissions that have been incorporated into a Customer's records are Customer Data and will be retained in accordance with the applicable Customer's obligations. If you request deletion of your personal data, Peny will process your request in accordance with applicable law, subject to any legal retention requirements, anonymization or aggregation that has already occurred, or operational needs of the Platform.

If your access is terminated because a Customer ends its relationship with Peny, your account data will be handled in accordance with Peny's Privacy Policy.

  1. Governing Law and Dispute Resolution

    These Terms are governed by the laws of the State of Utah, without regard to conflict-of-law principles.

    Any dispute, claim, or controversy arising out of or relating to these Terms will first be subject to good-faith negotiation between the parties. If the dispute is not resolved within thirty (30) days, either party may pursue any remedies available at law or in equity in the state or federal courts located in Salt Lake City, Utah. Each party consents to the personal jurisdiction and venue of those courts.

    Nothing in this section prevents either party from seeking injunctive or equitable relief in court for claims related to intellectual property rights or unauthorized access to the Platform.

    If you are a Customer or Authorized User, nothing in these Terms waives any non-waivable immunities or procedural rights under applicable law.

    Each party will bear its own attorney's fees and costs, except that if Peny prevails in any action to enforce these Terms against a party who has materially violated them, Peny may recover its reasonable attorney's fees and costs.

    TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU AGREE THAT ANY CLAIMS OR DISPUTES ARISING OUT OF OR RELATED TO THESE TERMS OR YOUR USE OF THE PLATFORM WILL BE RESOLVED ON AN INDIVIDUAL BASIS ONLY. YOU WAIVE ANY RIGHT TO PARTICIPATE IN A CLASS ACTION, COLLECTIVE ACTION, OR REPRESENTATIVE PROCEEDING, WHETHER AS A NAMED PLAINTIFF, CLASS MEMBER, OR IN ANY OTHER CAPACITY.

    ​​Peny's failure to enforce any provision of these Terms will not constitute a waiver of that provision or any other provision. Any waiver must be in writing and signed by Peny to be effective.

    If any provision of these Terms is found to be unenforceable or invalid by a court of competent jurisdiction, that provision will be enforced to the maximum extent permitted and the remaining provisions will continue in full force and effect.

    These Terms do not confer any rights, remedies, or benefits upon any person or entity other than you and Peny, except as expressly provided herein.

    These Terms, together with Peny's Privacy Policy and any applicable Master Services Agreement, constitute the entire agreement between you and Peny regarding use of the Platform and supersede all prior or contemporaneous communications, whether written, oral, or electronic.

  2. Changes to These Terms

    Peny may update these Terms from time to time. Updated Terms will be posted on the Platform and are effective upon posting.

    Your continued use of the Platform after any changes constitutes your acceptance of the revised Terms. If you do not agree to the changes, you must stop using the Platform.

    Peny encourages you to review the Terms periodically to stay informed about your rights and responsibilities.

  3. Contact Information

    If you have questions about these Terms or the Platform, you may contact Peny at:

    Peny, LLC

    2326 Washington Boulevard
    Ogden, UT 84401

    notice@penyapp.com

Thank you for using Peny.

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Privacy Policy

Privacy Policy

Effective Date: February 24, 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 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.

By accessing or using the Platform, you consent to the practices described in this Policy.

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, such as Customer Data and AI Interactions, 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. 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.
  • 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 may collect approximate location data based on IP address. If Residents or Authorized Users grant permission through their device settings, Peny may also collect precise geolocation data, such as GPS coordinates, to support location-based features including targeted notifications, geographic content relevance, route-based alerts, and other municipal communication functions. Geolocation data is collected only with the consent of the individual and may be used to improve the relevance and timeliness of content delivered through the Platform. 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 individuals under the age of 16. Peny does not knowingly collect Personal Information from children 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 a person under 16 without parental consent, or from a person under 13 regardless of consent, Peny may 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.

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, that Customer may use, retain, or disclose the content in accordance with its own policies and applicable law.
  • With service providers: Peny may share information with trusted third-party vendors who help operate or improve 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.

Peny does not share Personal Information for cross-context behavioral advertising. Peny does not sell Personal Information. Depending on your state of residence, you may have additional rights regarding your Personal Information under applicable consumer privacy laws. To exercise any such rights, contact Peny at the contact information in Section 10. Peny will process your request in accordance with applicable law.

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, enhance the Platform experience, 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.

  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 Customer the Resident followed has left the Platform.
  • 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 operational needs of the Platform. If you use the Platform without an account, Peny cannot process individual data access or deletion requests because there is no account or verified identity to associate with your activity.
  • Retention: Data submitted through the Platform may be retained until deleted by the Resident, by Peny, or at the request of a Customer if the content falls under their domain. Certain submissions may also be retained to comply with records laws or internal system policies.
  • 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, contact the relevant local government directly. If you wish to delete your account and all associated data, you may contact Peny at the contact information in Section 10. Peny does not offer deletion of individual records, submissions, or conversations separate from account deletion. Requests to delete content will be honored only to the extent permitted by law. 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 Customer, it will appear as a guest submission. The Customer 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.

  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 7. 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 does not make legal determinations about what qualifies as a public record and is not responsible for compliance with such laws on behalf of any Customer. Peny is not a system of record or legal compliance service and does not guarantee the preservation, accessibility, or discoverability of content. 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 improve your experience, understand how the Platform is used, and support Platform functionality.

  • Analytics: Peny may also use session recording and error tracking tools to monitor Platform performance and monitor Platform performance and maintain the Platform experience. These tools record user interactions within the Platform, including clicks, scrolls, and navigation patterns, for both authenticated and unauthenticated users. These tools are configured to avoid capturing Personal Information where technically feasible, but may capture content displayed on screen during a session.
  • Cookies: These are small text files stored on your device. They help remember your preferences, keep you signed in, improve navigation, and maintain session continuity across the Platform.

You can modify your browser settings to block or delete cookies at any time. Disabling cookies may affect certain features or functions of the Platform.

Peny does not use cookies to track you across unrelated websites, and Peny does not work with third-party ad networks.

  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 and are effective upon posting.

    Your continued use of the Platform after a Policy update 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

    v.PP20260224