Our Policy

Welcome to Pennee, Inc. (“ Pennee ”, “we”, “us” and/or “our”) provides financial tracking and businesscoaching services (together with the Site and the App, the “ Services ”). We provide the Services throughour pennee mobile and web applications (collectively, the “ App ”) and we provide information about theServices through our website available at www.pennee.co (the “Site”). This Privacy Policy describes theinformation including personally identifiable data (“ Personal Data ”) and other information that iscollected from visitors to the Site and users of the Services, how we use and share that information, andyour choices concerning our data practices.By providing us with your Personal Data, accessing the Site or using the Services, you agree to thepractices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not accessthe Site, use the Services, or provide us with your Personal Data. Before you access the Site, use theServices, or submit any Personal Data to us, please review this Privacy Policy carefully and contact us ifyou have any questions.

Information We Collect:

We may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide

We collect Personal Data from you when you voluntarily providesuch information, such as when you contact us with inquiries, respond to one of our surveys or enterone of our sweepstakes, register for access to the Services, use certain Services, or interact with us in aworkshop. The Personal Data collected during these interactions may vary based on what you choose toshare with us, but it will generally include your name, email address, and phone number.

Information We Collect Through the Service

We may collect transaction data (the date, itemsand units sold/purchased, price, discount, location, and whether the amount owed has been paid) aswell as customer, supplier, and investor data (such as contact information) when you provide suchinformation through the Service. Where you allow employees to access or use the Services, or whereyou provide us with employee information through the Services, we will also collect Personal Data aboutemployees. The Personal Data we collect from employees varies, but may include contact and salaryinformation.

Information We Collect Through Our Social Media Pages

We have pages on social media siteslike Facebook, Twitter, LinkedIn, and Instagram (“ Social Media Pages ”). We may collect Personal Datafrom you when you interact with our Social Media Pages, including your name, user name, and publiclyavailable profile information. In addition, the companies that host our Social Media Pages may provideus with aggregate information and analysis regarding the use of our Social Media Pages.

Information We Receive From Your Use of the Site

When you visit, use and interact with the Site, wemay receive certain information about your visit, use or interactions. For example, we may monitor thenumber of people that visit our Site, peak hours of visits, which page(s) are visited on our Site, thedomains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use toaccess and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information,and Site-navigation pattern. In particular, the following information is created and automatically loggedin our systems:

Log data

Information (“log data”) that your browser automatically sends whenever you visit theSite. Log data includes your Internet Protocol (“IP”) address (so we understand which countryyou are connecting from when you visit the Site), browser type and settings, the date and timeof your request, and how you interacted with the Site.

Cookies and similar technologies

Please see the “Cookies and Other Technologies” sectionbelow to learn more about how we use cookies and other technologies.

Device information

Includes name of the device, operating system, and browser you are using.Information collected may depend on the type of device you use and its settings.

Usage Information

We collect information about how you use our Site, such as the types ofcontent that you view or engage with, the features you use, the actions you take, and the time,frequency and duration of your activities.

Location Information

Our Service may collect and use your location information (for example, byusing the GPS on your mobile device) to provide certain functionality of our Service if you choose toenable our location features.

Cookies and Other Technologies

We and our partners use cookies and other technologies tooperate and administer our Site, make it easier for you to use the Site during future visits, gather usagedata on our Site and for advertising purposes. In operating the Services, we may use a technology called”cookies.” A cookie is a piece of information that the computer that hosts our Services gives to yourbrowser when you access the Services. Our cookies help provide additional functionality to the Services,including helping us analyze Services usage more accurately. For instance, our Site may set a cookie onyour browser that allows you to access the Services without needing to remember and then enter apassword more than once during a visit to the Site. On most web browsers, you will find a “help” sectionon the toolbar. Please refer to this section for information on how to receive notification when you arereceiving a new cookie and how to turn cookies off. You can also find more information and opt out ofinformation collection from certain advertising service providers. We recommend that you leave cookiesturned on because they allow you to take advantage of some of the Service features.

Tracking and Analytics

We may, and we may allow third party service providers, including Facebook, to use cookies (as noted above), pixels, or other tracking technologies to collect informationabout your browsing activities over time and across different websites following your use of the Site anduse that information to target ads. We use Google Analytics, a web analytics service provided by Google,Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhanceyour experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/

Our Use of Your Personal Data and Other Information

We may use Personal Data for the following purposes:

To provide our Services and help you manage your business;
To respond to inquiries, comments, feedback or questions;
To send administrative information to you, for example, information about the Site or Services, and changes to our terms, conditions, and policies;
To analyze Site usage and provide, maintain and improve the content and functionality of the Site. For example, we regularly fix bugs and user experience issues. We use cookies and similar technologies to analyze how users interact with our Site on an anonymized and aggregate basis. And that analysis can help us improve the Site;
To conduct analytics to inform our marketing strategy and enable us to enhance and personalize the Services;
To prevent fraud, criminal activity, or misuses of our Site and to ensure the security of our IT systems, architecture and networks;
To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, customers, or other third parties; and
If you ask us to delete your data and we are required to fulfill your request, we will keep basic data to maintain a record of your request, our response to it and prevent further unwanted processing.

Marketing. We may contact you to tell you about services we believe will be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing messages you receive by updating your settings. In addition, if at any time you do not wish to receive future marketing communications, please contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding our Site and Services and to respond to your requests.

Our Disclosure of Your Personal Data and Other Information:

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with providers of hosting, applicant tracking, messaging, live chat, scheduling, marketing, and sales/customer relationship management services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.

Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction, and may be transferred to a successor or affiliate as part of that transaction along with other assets.

Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of Users of the Site, or the public, or (v) protect against legal liability.

Aggregate Business Data: With your permission, we may share aggregate business data with our enterprise partners, who may send you sponsored business tips.

Your Choices:

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

Exclusions:

This Privacy Policy shall not apply to any unsolicited information you provide to us through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children:

Pennee does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites:

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Pennee (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that PENNEE endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Integrating Social Networking Services:

The Service may allow you to enable or log in to the Services via various social networking services like Facebook or Twitter (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in

accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and we shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

Other Terms and Conditions:

Your access to and use of the Services is subject to the Terms of Service at www.pennee.co/terms-of-use

Changes to PENNEE’s Privacy Policy:

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information:

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.

Contacting PENNEE:

Please also feel free to contact us if you have any questions about PENNEE’s Privacy Policy or the information practices of the Services.

You may contact us as follows: swift@pennee.co