Privacy Policy

1.Introduction, Operator and Scope

1.1 Who we are. This Privacy Policy applies to Penny App Inc. services (the “Services”), which include Penny apps, websites, software, and related services, accessed via any platform or device, that link to this Privacy Policy. This privacy policy explains how Penny App Inc. ("Penny”, “Explore Penny”, "we", "us" or "our") collects, uses, shares and protects personal information when you use the Penny mobile application, explorepenny.com and related services. Penny App Inc. operates the Service.

1.2 Our technology. Penny App Inc. runs the Service using technology that it licenses from an affiliate. The affiliate acts only on our behalf and does not use your personal information for its own purposes.

1.3 What this Policy covers. This Policy applies to the Service, including map discovery, profiles, communities, venue and event listings, Penny Drops, Dimes messaging, venue and community Broadcasts, and related support and website interactions. It does not apply to third-party websites, apps or services that the Service links to, such as event-ticketing partners.

1.4 Your consent where the law requires it. We ask for your separate, explicit consent before collecting information that the law treats as sensitive, including precise location. Using the Service does not by itself give that consent.

1.5 Ages. You must be at least 18 to use Penny.

1.6 We do not sell your personal information. We do not sell personal information, and we do not share it for cross-context behavioral advertising. Penny is supported in part by sponsorships and advertising.

2.Information We Collect

2.1 Information you provide.

• ✦Account information: name, email address, date of birth, and optionally a phone number.
• ✦Profile information: username or @handle, photos, bio, interests, and any other details you add.
• ✦Assessment answers: answers to optional compatibility questions, which other users may see unless a question says your answer stays private.
• ✦User Content: Penny Drops (content you drop on the map or post to profile, community or venue timelines), Dimes messages (direct, group, LinkUp, event and community chats), photos, media, posts, event and community content, and any other content you submit, post or send through the Service.
• ✦Communications: support requests, feedback and survey responses.
• ✦Emergency contacts: if you use the Emergency Contact feature, the name and phone number or email of each person you add, and whether they accepted your invitation.
• ✦Venue partner information: if you claim or manage a venue, your name, business name, business email, and verification details.
• ✦Payment information: if you buy a paid plan, a sponsorship or a Paid Community membership, or receive creator payouts, payments are processed by Apple, Google or our payment processor (such as Stripe). We receive limited information, such as what was purchased, the amount, the date, the status and a processor reference. For creators who receive payouts, our payment partner also collects identity and tax details. We do not store full card numbers. If you join the Referral Program, our payment partner also collects your payout and tax details, and we keep your commission balance.

2.2 Information collected automatically.

• ✦Device and app information: device model, operating system, app version, language, and device identifiers.
• ✦Usage information: features used, pages and map areas viewed, interactions, and event or community activity.
• ✦Log and diagnostic information: IP address, access times, crash reports and performance data.
• ✦Approximate location: derived from your IP address (city or region level).
• ✦Device location: only if you give separate consent. Your device shares its location with us, and the map shows it as precise or, if you choose, as approximate (a position near, not at, where you are).
• ✦Safety and enforcement identifiers: device identifiers and, where you provide one, your phone number (verified by a one-time text code and a carrier check of the line type), used to detect fraud, prevent banned users from re-registering and keep the Referral Program fair.
• ✦Age information: the date of birth you enter, and, where your device's app store provides it, an age range signal. We use these only to apply our age requirement.

2.3 Information from other sources.

• ✦Event listings and venue information from external third-party event and ticketing providers and mapping and place-data providers such as Foursquare, Google Places and Mapbox, and whatever a venue claimant chooses to share on its venue profile. This is information about events and places, not about you.
• ✦Sign-in providers, if you choose to register with a third-party account.
• ✦Referral and subscription status: the referral link or code used when someone signs up, who referred whom, whether a referred person has joined, verified their phone and subscribed, and payment status from our subscription-management and payment providers.

2.4 Information we do not collect. We read your device contacts only if you choose "Sync & Share" and allow access in your device settings. We use them only to show you which of your contacts are already on Penny and to help you invite others, and we do not store them or share them with anyone. The only other people's contact details we keep are ones you give us on purpose, such as an emergency contact. We do not collect precise location while the app is closed unless you separately turn on background location in both Penny and your device settings.

3.Precise Location and Sensitive Data

3.1 What we treat as sensitive. Penny treats precise location as sensitive personal information for every user, whatever your age or where you live. "Precise location" means data that identifies where you are within a radius of about 1,750 feet (530 meters), such as GPS coordinates. Whether or not a particular law requires it, we apply the protections in this Section to all users, including Florida residents under the Florida Digital Bill of Rights. This includes the approximate setting described in Section 3.8 where the position we use or show is within that radius of where you are.

3.2 Separate consent, with a real choice. During onboarding we show a dedicated screen, separate from our Terms and this Policy. It explains why Penny needs your location, who may see your marker, and how long raw location is kept, and gives you equal-weight choices to allow or decline. We record your choice with the date, time and version of the notice. Precise location is off until you choose "Yes" and also grant your device's operating-system permission. Choosing "No" does not prevent you from creating an account or using Penny's other features.

3.3 How we use precise location. Only to:

• ✦show you nearby people, places, events and communities on the map, and show your marker to other users according to your visibility settings;
• ✦verify your presence where a community or event requires it;
• ✦protect the Service, including detecting location fraud and responding to safety reports.

We do not sell precise location or give it to advertisers or sponsors, and we do not currently use it to choose ads or sponsored placements. Advertisers and sponsors may see aggregated, de-identified statistics, such as visit counts for a venue or area. If we begin using location in other ways for ads or sponsored placements, we will update this Policy and ask for your separate consent first. Other users may see a marker for you on the map according to your choices in Section 3.8, and the marker's color reflects the viewer's alignment with you.

3.4 Retention. Raw precise-location coordinates are deleted from our production systems within 30 days by an automated daily process. Backup copies are handled under Section 6.

3.5 Withdrawing consent. You can turn precise location off at any time in Settings → Privacy → Location or in your device settings. Turning it off stops new collection. Map discovery near you will be limited.

3.6 Sensitive answers in optional assessments. Some optional assessment questions touch on sensitive topics, such as relationships, orientation, or substance use. Answering them is entirely optional, and you can skip any question. If you choose to answer, you consent to our using those answers inside the alignment calculation. Those answers are never displayed to other users. For other assessment answers, visibility depends on the question: unless a question states that your answer stays private, other users may see it, and each question tells you which applies before you answer. Answers that stay private may still be used in the calculation. You can change or delete your answers in Settings. The whole assessment is optional, and each sensitive-topic question offers a "prefer not to say" option.

3.7 No sale or advertising use. We do not sell sensitive personal information, and we do not use it for targeted advertising.

3.8 Your map visibility choices. You choose how you appear on the map. Where available, you can: (a) share your precise location, so your marker appears at your position; (b) share your approximate location, so your marker appears near, but not at, your position (the exact offset depends on your device and settings); or (c) turn on Cloak Mode, which hides your marker from other users, including connections, venues and communities. When you share location, anyone who can view the map may see your marker, unless you choose otherwise in Settings. Approximate location and Cloak Mode do not hide content you post or choose to share, such as Pennies, check-ins, RSVPs and Proximity Signals you send. With Cloak Mode on, you do not appear on the map at all. With approximate location, your marker appears as a general location, not a precise one. To stop location collection altogether, turn off precise location. Other privacy features, such as Incognito Mode, work differently and are described in the app. Cloak Mode, Incognito Mode and similar features may vary by plan, and we may add or change them.

4.How We Use Information

4.1 To provide the Service. To create and maintain your account, show profiles, venues, events and communities, deliver messages, and provide support.

4.2 Map and discovery tools. Penny's map and discovery features help you find places, events, communities and people. The map can show people (as markers), connection lines, venues, communities, events (from external third parties, and user-created LinkUps and events) and Pennies (content drops). People can react and comment on Pennies with Nickels, and can send Proximity Signals through Pennies when they are nearby. A Proximity Signal tells the owner of the Penny only that the sender is nearby and may want to connect; it does not share the sender's location. The owner can reply, react or connect, and connected users can chat in Dimes. They rank and display results using proximity, place and event categories, interests you have given us, and your settings. They are community discovery tools. They are not designed to maximize the time you spend in the app, and you can limit them through your location, notification and visibility settings.

4.3 Alignment feature (entertainment only). If you complete optional assessments, Penny's Quantum Alignment Algorithm™ compares answers you and another user have both given and may show an alignment percentage. Map marker colors and connection lines reflect these alignment results between you and other users, venues, communities or events. This is a playful snapshot for entertainment only. It is not a scientific, psychological, medical or relationship assessment, and it does not predict compatibility, behavior or outcomes. Where there is not enough overlapping data, we show that the alignment is still forming rather than a number. Other answers you give may be visible to other users unless the question says they stay private. Answers about sensitive topics are used only inside the calculation and are never displayed.

4.4 To communicate with you. To send account notices, safety alerts, and support replies. With your permission, we send marketing emails and push notifications, and you can opt out at any time. If you star a venue or join a community, it may send you Broadcasts through Dimes. Unstar the venue or leave the community to stop them. Venues and communities may see that you starred or joined.

4.5 Safety, security and enforcement. To detect and investigate spam, fraud, harassment, underage access, location falsification and other violations of our Terms and Community Guidelines. This includes using device identifiers and phone numbers to stop banned users from re-registering. We also use automated tools and human review. We may temporarily limit the visibility of an account or content during an investigation, as described in our Terms of Service. We do not use these identifiers for advertising.

4.6 To improve and secure the Service. To fix bugs, measure performance, and improve features, using de-identified or aggregated information where we can. We also use information to develop and train our AI features.

4.7 For legal reasons. To comply with law and legal process, enforce our agreements, and protect the rights, property and safety of Penny, our users and the public.

4.8 No automated decisions with legal effect. We do not make decisions that produce legal or similarly significant effects on you solely by automated means. Automated tools may flag content for human review.

4.9 Advertising, sponsorships and aggregate insights. Penny earns revenue from paid plans, commissions on Paid Communities, affiliate commissions on tickets and bookings, venue and community partnerships, sponsored events and placements, and advertising. Sponsored content is labeled as sponsored. We may choose which sponsored content to show you using information within Penny, such as the map area you are viewing, place and event categories, interests you have shared in Penny, and how you use the Service. Some placements also depend on a venue's or community's partnership or sponsorship plan. Whatever signals we use, these limits always apply: we do not use your sensitive-topic answers or your precise location for this unless you have given separate consent. We make these choices ourselves: advertisers and sponsors do not receive your name, contact details, precise location, messages or assessment answers.

We may also create aggregated, de-identified statistics, such as activity counts for an area, venue or event, and share them with advertisers, sponsors and venue partners to show how the platform performs. We take steps so that these statistics cannot reasonably be linked to you, we do not try to re-identify them, and we require recipients not to. If we change how we use personal information for advertising, we will update this Policy first and, where the law requires, ask for your consent or give you an opt-out.

4.10 AI features and model training. Penny offers or may offer AI features, such as the Penny AI Agent. When you use them, we collect what you send and what they return, and may use it to run and improve the feature. We may also use the text of content that other users can see, such as profile information, Pennies, posts, and community and event content, to develop, train, test and improve our AI features. We do not use the following to train AI models: your private Dimes messages, your answers to sensitive-topic assessment questions, your photos, videos or audio, your precise location, or any information from users under 18. If we use an outside AI provider to run a feature, we send it only what is needed for the request and require it not to use that information to train its own models. You can ask us to stop using your content to train our AI features by emailing support@explorepenny.com. The request applies going forward, and it may not remove content from models that have already been trained. AI output can be wrong, so do not rely on it for safety, legal, medical or financial decisions. If we begin using other kinds of information for AI training, we will update this Policy first and, where the law requires, ask for your consent.

4.11 Emergency Contact feature. If you add an emergency contact, we collect their name and phone number and/or email, and you confirm you have their permission to give it to us. We invite them first. Before they are confirmed, they must accept and agree to receive notices from Penny by text message and/or email. Message and data rates may apply. Once a contact has accepted, and only for the check-ins and check-outs you choose to notify them about, we may send them details of the venue or event. Those details may or may not include location, host or other information, depending on what the venue or host has provided. We do not send notices to a contact who has not accepted. We use a contact's details only to provide this feature, not for marketing, and we delete them when you remove the contact or delete your account. You can remove a contact at any time in Settings. A contact can stop notices at any time without a Penny account, by following the instructions in a message, replying STOP to a text, using the unsubscribe link in an email, or emailing support@explorepenny.com. Penny is not an emergency service, and notices may be delayed, missed or ignored (Terms of Service, Section 7.4).

4.12 Referral Program. To run the Referral Program, we verify phone numbers and check that they are real mobile numbers, record referral codes and who referred whom, and use device and network signals to catch fraud, duplicate accounts and self-referrals. We use payment status to calculate and pay commissions and to keep tax and accounting records. We store referral phone numbers in a hashed form we cannot read directly. We use this information only to run, protect and improve the program and not for advertising.

5.How We Share Information

5.1 With other users. Your profile, User Content and your assessment answers (except answers a question states will stay private) are visible to other users according to your settings. Content you post to a community or event may be visible to its members and hosts. Penny Drops may be visible to other users on the map or on the profile, community or venue timeline where you post them, and Dimes messages are visible to the people in that conversation or group. If you join Penny through a referral, the person who referred you sees only your @handle and your status (Joined, Verified or Subscribed). They never see your name, email, phone number, plan or payment amounts.

5.2 With service providers. With vendors that process information on our behalf and under contract, including cloud hosting, email and notification delivery, payment processing (Apple, Google and Stripe, where paid plans, sponsorships, creator payouts or referral payouts are offered), text-message verification and phone-carrier lookup, subscription management, referral tracking, and customer-support tools. They may use your information only to provide services to us, and we require them to protect it with safeguards at least as protective as those described in this Policy. Map and place providers, such as Google Maps Platform and Mapbox, receive the map area you view and technical data such as your IP address so they can deliver maps and place details, and they also handle that data under their own privacy policies.

5.3 With our technology affiliate. With an affiliate that provides technology to us, solely on our behalf and under contract.

5.4 Events, venues and ticketing partners. If you RSVP to or check in at an event, the host or venue may see that. If you tap through to an external third-party event or ticketing provider, that partner's own terms and privacy policy apply to what you do there. Some of these links are affiliate links, which we manage through an affiliate network such as impact.com. If you buy or book through one, Penny may earn a commission at no extra cost to you. When you tap an affiliate link, we send the network and the provider only a reference that identifies the link, not your name, contact details, location or Penny account, and they may use cookies or similar tools on their own sites under their own policies.

5.5 For safety and legal reasons. With law enforcement, regulators or other parties where we believe in good faith that disclosure is required by law or legal process, or is needed to protect someone's safety, investigate a violation, or prevent fraud.

5.6 Business transfers. If Penny is involved in a merger, financing, acquisition or sale of assets, information may be transferred as part of that transaction. We will give notice before it becomes subject to a different privacy policy.

5.7 With your consent. For other purposes, when you ask or permit us to.

5.8 Aggregated or de-identified information. We may share statistics that do not identify you, for example venue-level activity trends shown to venue partners, advertisers and sponsors.

5.9 With your emergency contacts. If you use the Emergency Contact feature, contacts who have accepted receive the notices, which may show the venue or event you checked in to. Only add people you want to know that.

6.SMS Text Messaging

6.1 How SMS consent works. Where you give your mobile number and agree, Penny sends text messages (SMS) to that number. You can opt in inside the app (for example, when you verify your phone, set up Emergency Contacts, or turn on text notifications) or on our website opt-in page at https://explorepenny.com/sms. We keep a record of your consent, including the date, the number and the consent language you were shown. Consent to receive texts is never a condition of creating an account, using Penny, or making any purchase.

6.2 Types of messages. Depending on your choices, texts may include: account and security notices; one-time passcodes and phone-number verification; Emergency Contact confirmations and the check-in or check-out notices a user chooses to send you; service notifications about activity on your account; and, only if you separately opt in, occasional marketing messages about features, events and offers. Message frequency varies with your activity and settings. Message and data rates may apply, according to your mobile plan.

6.3 How to stop. You can reply STOP to any Penny text to unsubscribe from that program, and reply HELP for help. You can also manage text preferences in the app under Settings → Notifications, use the unsubscribe link in any marketing email, or email support@explorepenny.com. Opting out of marketing texts does not stop security or account texts that are necessary to operate the Service.

6.4 We do not sell or share your mobile information for others' marketing. No mobile information — your phone number, your SMS consent, or the fact that you receive our texts — is sold, rented, or shared with third parties or affiliates for their own marketing or promotional purposes. We share your phone number only with the service providers that help us deliver and secure these messages (for example, our SMS provider Twilio and our phone-verification and carrier-lookup providers), and only so they can provide those services to us under contract. These providers may not use your mobile information for their own purposes. Text-messaging originator opt-in data and consent are not shared with any third party or affiliate for marketing or promotional purposes.

7.Retention, Deletion and Backups

7.1 How to delete. Go to Settings → Account → Delete Account, or email support@explorepenny.com from the address on your account. You can also submit a deletion request online at https://explorepenny.com/ec/delete-data (no login needed). When an account is deleted, we also ask our service providers to delete the information they hold for us, except where the law requires them to keep it.

7.2 Backups. Deleted information may remain in encrypted backups for the period above. We do not use backups to bring deleted accounts back. If we ever have to restore from a backup, we re-apply all deletions made since that backup was taken.

7.3 Retained records. We may keep limited information after deletion where the law requires it or where it is needed to enforce our Terms, such as a record that an account was banned. If you took part in the Referral Program, we also keep a hashed version of your phone number (stored in a form we cannot read directly) so the same number cannot be counted twice, and payout, tax and accounting records as the law requires.

8.Security

8.1 Our safeguards. We use administrative, technical and organizational measures designed to protect personal information, including encryption in transit using TLS, encryption of stored data at the infrastructure level by our cloud provider, access controls that limit production access to personnel who need it, and monitoring for misuse. We are continuing to strengthen these safeguards.

8.2 No guarantee. No system is completely secure, and we cannot guarantee the security of your information.

8.3 Messages are not end-to-end encrypted. Penny does not currently offer end-to-end encryption. This means Penny's systems can technically access message and other content where needed for safety, legal compliance, support or operating the Service. If that changes, we will update this Policy before we make any such claim.

8.4 Security incidents. If a security incident affects your personal information, we will notify you and regulators as required by applicable law.

8.5 Your part. Keep your device and account credentials secure and tell us promptly at support@explorepenny.com if you suspect unauthorized access.

9.Your Choices and Controls

• ✦Location: turn precise location on or off, and choose precise, approximate or Cloak Mode where available, in Settings → Privacy → Location and in your device settings.
• ✦Profile and answer visibility: manage who sees your profile in Settings → Privacy.
• ✦Notifications and marketing: manage push notifications in Settings → Notifications and in your device settings. Use the unsubscribe link in any marketing email. To stop Broadcasts from a venue or community, unstar it or leave it.
• ✦Edit or delete content: edit or delete your profile, answers and posts at any time.
• ✦Delete your account: Settings → Account → Delete Account.
• ✦Block and report: use Block and Report on any profile, message thread, event or community.
• ✦Access, correction and copies: email support@explorepenny.com. We respond within 45 days.

We will not penalize you for exercising these choices.

10.Age Requirement

10.1 Minimum age. Penny is for adults. You must be at least 18 to use Penny. We do not knowingly collect personal information from anyone under 18, and we delete any such account and data when we learn of it. If you are a parent or guardian and believe your child has created an account, email support@explorepenny.com and we will act on it.

10.2 How we apply the age requirement. We ask for your date of birth when you sign up and, where your device's app store provides an age range signal, we use it too. If the information shows you are under 18, we do not create your account.

11.U.S. State Privacy Rights

11.1 Who may use these rights. We offer the rights below to residents of California, Florida and other U.S. states with comprehensive privacy laws. We offer them whether or not a particular law technically applies to Penny.

11.2 Your rights. Subject to legal exceptions, you may ask us to: (a) tell you what personal information we collect, use and disclose; (b) give you a copy; (c) correct inaccurate information; (d) delete your information; and (e) not discriminate against you for exercising these rights. Because we do not sell personal information or share it for cross-context behavioral advertising, there is nothing to opt out of. We treat any Global Privacy Control signal on our website accordingly.

11.3 California categories (past 12 months).

We use sensitive personal information only to provide the Service you request, so the right to limit its use does not apply.

11.4 Florida. Florida residents have the rights above. Under Florida's Digital Bill of Rights, precise geolocation is sensitive data. We handle it as described in Section 3 and never process it without your opt-in consent.

11.5 How to make a request. Email support@explorepenny.com from the address on your account, or use the in-app controls in Section 9. We verify requests by matching information you give us to our records. An authorized agent may submit a request for you with your written permission. We respond within 45 days and may extend once by another 45 days, and we will tell you why.

11.6 Appeals. If we decline your request, you may appeal by replying to our decision email with the word "Appeal." We respond within 60 days. You may also contact your state attorney general.

11.7 California Shine the Light. We do not disclose personal information to third parties for their own direct-marketing purposes.

12.International Users

Penny launches in Miami, Florida, and is intended for use in the United States. Our systems and service providers are located in the United States. If you use the Service from elsewhere, including the European Economic Area, the United Kingdom or Switzerland, your information will be transferred to and processed in the United States, where data-protection laws may differ from those of your country. Where required, we use appropriate safeguards for those transfers, such as standard contractual clauses.

Our legal bases for processing are your consent (for example, for precise location and sensitive-topic answers), performance of our contract with you, our legitimate interests in operating and securing the Service, and compliance with legal obligations. If GDPR applies to you, you may also object to or restrict certain processing, withdraw consent at any time, and request that your data be ported. Email support@explorepenny.com. You may also complain to your local data-protection authority.

13.App Store and Google Play Data Disclosures

This table summarizes what Penny collects, for use with Apple's App Privacy details and Google Play's Data safety form. We do not use any data to track you across other companies' apps and websites, and we do not sell data. Because the approximate setting still places your marker near you, we report location you share as precise location in these disclosures.

You can request deletion of your account and data inside the app (Settings → Account → Delete Account) or by emailing support@explorepenny.com. You can also request deletion on the web, without logging in, using the form at https://explorepenny.com/ec/delete-data (no app needed).

14.Changes and Contact

14.1 Changes. We may update this Policy. For material changes we will notify you by email or in the app before they take effect. The effective date above shows the latest version.

14.2 Contact.