Penguin Privacy Policy

Last Updated: March 27, 2026

1. Introduction

Penguin ("we", "our", or "us") values your privacy. This Privacy Policy explains how we collect, use, store, and share your information when you use the Penguin mobile application, website, and related services (collectively, the "Service").

By accessing or using the Service, you consent to the practices described in this Privacy Policy. If you do not agree, do not use the Service.

2. Information We Collect

We may collect the following types of information:

a. Information You Provide

• Account registration details (name, email, date of birth, phone number)
• Profile information (photos, biography, preferences)
• Messages and communications with other users
• Payment or subscription information

b. Automatically Collected Information

• Device information (model, operating system, device ID)
• Log data (IP address, browser type, pages visited, timestamps)
• Cookies and similar technologies
• Analytics data on app usage

c. Information from Third Parties

• Social media profile information if you link an account
• Information from service providers assisting with identity verification, fraud prevention, or analytics

3. How We Use Your Information

We use your information to:

• Provide, maintain, and improve the Service
• Enable matching and communication with other users
• Personalize content and recommendations
• Verify identity and prevent fraud
• Send service updates and important notices
• Conduct analytics and research
• Comply with legal obligations

4. Sharing Your Information

We do not sell your personal information. We may share information in the following circumstances:

• With other users: your profile and content may be visible to other users as part of the Service
• With service providers: vendors assisting with hosting, analytics, identity verification, or payments
• For legal reasons: to comply with legal obligations, enforce our Terms of Service, or protect rights and safety
• For child safety purposes: we may disclose information to the National Center for Missing & Exploited Children (NCMEC), law enforcement, or other relevant authorities where required by law or where we become aware of CSAM or CSAE activity on the Service
• Business transfers: in connection with mergers, acquisitions, or sale of assets

5. Cookies and Tracking

We use cookies and similar technologies to:

• Enable core functionality of the Service
• Analyze usage and improve performance
• Personalize content and marketing

You may control cookies through your device or browser settings, but some features may not function properly if cookies are disabled.

6. Your Choices

You may:

• Access and update your account information
• Delete your account at any time (subject to retention requirements)
• Opt out of promotional emails
• Control location sharing and other device permissions

Requests may be made via the app or by contacting us at info@thepenguinapp.com.

7. Data Retention

We retain your information as long as your account is active or as needed to provide the Service. Some data may be retained to comply with legal obligations, resolve disputes, enforce agreements, or prevent harm.

Where we become aware of CSAM or CSAE activity, we may retain relevant data for the purpose of reporting to NCMEC or law enforcement, even after account deletion.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your information. However, no system is completely secure, and we cannot guarantee absolute protection.

9. Children's Privacy

The Service is intended for users 18 years and older. We do not knowingly collect information from children under 18. If we learn that we have inadvertently collected data from a minor, we will delete it promptly.

We strictly prohibit the use of the Service to exploit or abuse minors in any way. If we become aware of child sexual abuse material (CSAM) or child sexual abuse and exploitation (CSAE) on the Service, we will remove the content, ban the responsible account, and report to the National Center for Missing & Exploited Children (NCMEC) via cybertipline.org or the relevant regional authority, as required by applicable law.

To report child safety concerns, contact us at: info@thepenguinapp.com

10. International Users

If you access the Service from outside Canada, your information may be transferred to, stored, and processed in Canada. Data protection laws may differ from those in your country.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will update the "Last Updated" date and, when required by law, notify users of material changes. Continued use of the Service constitutes acceptance of the updated policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy, you may contact us at:

Penguin IP Holdings Inc
770 Brookfield Rd, Suite A206
Ottawa, Ontario, Canada
Email: info@thepenguinapp.com