As you review our policy, keep in mind that it applies only to Pengwenz, Inc.’s (“Pengwenz“, “we“, “our“, or “us“) websites, mobile apps (Pengwenz), help center, and other associated services we provide (“Services”). 

If you are browsing and have an interaction, on any third-party website or service, including those that have a link on our website and inside the Pengwenz app, you are subject to that third party’s own rules and policies, and Pengwenz, Inc. is not responsible for the practices employed by those apps, websites, or services, nor the information or content contained therein. Any information that you provide on or to a third-party service, or that is collected by a third-party service, is provided directly to the owner or operator of the third-party service and is subject to that owner’s or operator’s privacy policy. Please remember that when you use a link to go to another website or app, or engage with a third-party service, our Privacy Policy does not apply to those third-party websites or services.

Before accessing or using our Products and/or Services, please ensure that you have read this Policy and understand how we collect, store, use, and disclose your personal information as described herein. 

1. INFORMATION WE COLLECT

The information Pengwenz collects depends on what Pengwenz Services you use and how you use them.  

Note that failure to provide necessary information when requested may result in you not being able to fully utilize our Products and/or Services.

A.  Information You Give Us Directly

When you create or modify a Pengwenz account, update your preferences, purchase and/or activate a Service, contact us (including by social media), participate in an online survey, or otherwise interact with Pengwenz’s Services, we may collect a variety of information, including:

• Account Information. Your username, email address, real name, nickname, date of birth, telephone number, password, shipping and billing addresses, and Products activated. You may also choose to provide a photo to associate with your Pengwenz account.
• My Huddle and Flock Information. When you create a My Huddle or a Flock in your Pengwenz app and invite a friend or family member to join your My Huddle and Flock, we collect their name, email address, mobile phone number, and photo if one is provided.
• Identity Verification. In certain circumstances, for instance, depending on the features of our Services you use or based on your age and relevant country of residence, we may collect additional information to verify that your parent or guardian has consented to your use of the Services which may include an image of their government-issued ID along with a selfie image may be used with facial recognition technology to produce a unique biometric identifier based on facial geometry. (Note: the digital age of consent may vary by jurisdiction and Pengwenz may adjust our parental consent process accordingly.)
• Payment and Transaction Information. When you place an order for a Product or upgrade to a premium subscription, you’ll need to provide an email address, a first and last name and/or a shipping address. Any payment information provided is processed by the relevant billing and/or payment processor. We may also collect information such as which version of the Product or subscription service you are using, the date and time that you activated your account, the duration of your subscription, the data related to any subscription cancellation request, and any in-app purchases you may make.
• Optional Account Information. You may also customize your in-app map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite places and to provide alerts when My Huddle of Flock members leave and arrive. Pengwenz members may have the option to provide us with additional information including emergency information such as their legal first and last name, height, weight, medications, allergies, and medical conditions.
• Contest Prize and Tax Information. If you are the recipient of a contest or sweepstakes prize that requires tax reporting, we may collect identifiers associated with your government-issued documents (such as a social security number).
• Other Information You Provide to Us. Information you provide in response to surveys about our Services; any information about people that you provide us through our referral services, any information you provide to us through invitations to possible members of your Flock or My Huddle, any information or content that you voluntarily submit or post to the Pengwenz websites or blogs, or comments you post to our Facebook page (or other social media pages), information you provide when seeking help from us, such as your name, email address, telephone number, mailing address and records (including call recordings) and technical information related to the issues you experience.

 B.  Information We Collect When You Use or Interact with our Services

We may collect other information when you use our Services, such as:

• Device Information. Information about your device, those devices around you, hardware, and software information, such as your mobile device identifiers, IP address, or browser information (including browser type and language preference), 
• Location and Movement Information. We collect your location and motion information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device, motion information such as altitude, heading, and speed.
• Messages and Member Content. We collect information when you message other members of your My Huddle through the use of our Services, when you provide Pengwenz with feedback, when you make a blog post, or comment in a chat or when you tag Pengwenz in a social media post, any photos or videos you send via the in-app messaging to other members of your My Huddle or Flock.

Certain data we collect may be considered sensitive under applicable law.  To the extent we collect sensitive personal information, we process such information for disclosed purposes as permitted by and in compliance with applicable law. 

C. Information Provided to Us by Third Parties

We may receive information about you from other sources, including through third-party services that you connect to your Pengwenz account, or third-party services and organizations to supplement information provided by you. For example:

• When you choose to connect or interact with our Services through a third-party social networking service (“Social Network”), such as when you Like us on Facebook or post a comment to our Facebook page, we may collect information that you have already made public on your Social Network account.
• We may use social plugins, widgets, and other features (each, a “Social Feature”) that are made available by and/or access third-party Social Networks. These Social Features allow these Social Networks to place cookies on your browser and to collect certain information, which may be associated with your personal Social Network account such as your name, your Social Network user identification number, your Social Network username, location, gender, birth date, email, profile picture, and your contacts on the Social Network.  

2. HOW WE COLLECT INFORMATION

When you visit our websites, use our apps, read our emails, or otherwise engage with us, we may automatically collect certain information about your device through a variety of technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “Tracking Technologies”), and we may combine this information with other personal information we collect about you. We may use these Tracking Technologies to collect your usage on your devices along with any other devices that emit a public signal that are located near you and can be identified.

• For example, your device’s telephone number (if it has one), your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, phone number, mobile carrier, date, and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, whether the device is connected to WiFi, and other such information. With your permission, we may also access your photo or camera roll.

We may also use Analytics, Advertising, and Anti-Fraud technologies in our Services. These technologies may utilize the same cookies or similar mechanisms as further described below.

 A.  Cookies and Similar Technologies

Cookies are pieces of code that allow for personalization of our website experience by saving your information such as user ID and other preferences – if your browser is set to accept cookies. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes. 

Web beacons (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including delivering or communicating with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the member’s device, web beacons are typically embedded invisibly on web pages (or in an e-mail).

B.  Analytics and Advertising Technologies

We may collect analytics data, or use third-party analytics tools such as Google Analytics, which may use Tracking Technologies, to help us measure traffic and usage trends for our websites and services. The types of data that analytics technologies may capture are as follows:

• referral/exit pages; 
• how frequently you access our Services; 
• whether you open emails or click the links contained in emails; 
• whether you access our Services from multiple devices; 
• the features you use; 
• the links you click; 
• the ads you view and click on; 
• purchase transaction information; 
• your location when you access or interact with our Services; 
• Technical-related information about your computer or device and operating and/or network systems (such as IP Address and device ID);
• information about your engagement with certain features and usage statistics; and 
• other similar actions.

We may collect and share your personal information, including your unique identifiers or Advertising IDs and other data such as app events, with third-party ad networks, and social media companies, including without limitation, to inform and improve tailored advertising, attribution, analytics, or research purposes. 

These advertising partners collect and use information such as:

• click stream information; timestamp; hashed email address; device ID or AdID; and
• your use of third-party applications

and may combine this information with information they collect directly through Tracking Technologies or that they receive from other third parties. These third-party partners may use the information they have gathered independently according to their own privacy policies.

You have the right to object to and opt out of certain third-party tracking and advertising. Where you have consented to Pengwenz’s processing of your information, you may withdraw that consent at any time and opt out of certain processing activities, such as targeted marketing communications. Even if you opt-out, we may still collect and use information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.

3. HOW WE USE YOUR INFORMATION

We may also aggregate the information we collect, in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law.

We may use and disclose your information to service providers to provide, maintain, and improve our Services to develop new products and features, to determine which new products or services may be of interest to you, and to promote our Services.

A.  Administrative Purposes

 We may use information about you for our administrative purposes, including to:

• Provide the Products and Services to you;
• Measure interest in Pengwenz’s Services; 
• Develop new Services; 
• Ensure the integrity, security and perform internal quality control and optimization of our Products and Service; 
• Verify individual identity; 
• Communicate about individual accounts and activities utilizing Pengwenz’s Products, Services, and systems;
• Make changes to any Pengwenz policies; 
• Send messages to the email address or telephone number you provide to us to verify your Account; 
• For informational, transactional, marketing and operational purposes, such as Account management, customer service, or system maintenance; 
• To process payment for products or services purchased; 
• To process applications and transactions; 
• To prevent potentially prohibited or illegal activities; and 
• To enforce our Terms of Use, this Privacy Policy or any other agreement 

B.  Marketing Pengwenz Services

Pengwenz may use information, and Individuals who provide us with personal information may receive periodic emails, newsletters, SMS messages, mailings, or phone calls from us, as allowed by applicable law, for marketing purposes such as to:

• Provide you with information related to Pengwenz’s or our business partners’ Services that may be of interest to you;
• Notify you of upcoming special offers/events we believe may be of interest;
• Conduct individual or market research;
• Conduct research and drive marketing analytics;
• Conduct online behavioral advertising;
• Tailor content, advertisements, and offers that may be of interest to you; 
• Introduce new content, features, Services.; and 
• For other purposes disclosed at the time that you provide us your information, or otherwise with your consent. 

C.  Research and Development

We may use information to create non-directly identifiable information that we may use alone or in the aggregate with information obtained from other sources as set forth herein, in order to:

• Help us to optimally deliver our existing Services;
• To develop new Services;
• For research and internal analysis;

For instance, from time to time, Pengwenz may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf (all survey responses are voluntary). The survey responses may be utilized to:

• Determine the effectiveness of our Services, 
• Perform various types of communications, advertising campaigns, and/or promotional activities. 
• Learn more about our members and potential members and their individual and collective needs.

If an individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analytics purposes.

D.  Connecting with Social Media 

If you use these Social Features the supplemental information provided will allow us to verify information that you have provided to Pengwenz and to enhance our ability to provide you with information about our business, products, and Services.

These Social Features are operated solely by the respective Social Networks, and their service providers, and we recommend that you carefully read their privacy policies before you decide to use them. We have no control over or access to the information collected, stored, or used by such Social Networks, and the information practices of such Social Networks are not covered by this Privacy Policy.

E.  Information Collected Automatically Through the use of Tracking Technology

We use information collected through the use of Tracking Technologies (e.g. cookies and web beacons) to: 

• Remember information so that you will not have to re-enter it during your visit or the next time you visit our website or use our Services; 
• Authenticate your access;
• Keep track of your in-app specified preferences or choices;
• Display a personalized browsing history
• Provide custom, personalized content and information, including targeted content and advertising;
• Record your device’s location and movements; 
• Identify and contact you across multiple devices; 
• Provide and monitor the effectiveness of our Services and our marketing campaigns; 
• Monitor aggregate metrics such as total number of visitors, members, traffic, and demographic patterns; 
• Provide specific technical support (diagnose or fix technology problems reported by our members or engineers that are associated with certain IP addresses or User IDs;
• Detect or prevent fraud or other harmful activities; 
• Automatically update our mobile application on your system and related devices; and 
• Otherwise plan for and enhance our Services.

4. INFORMATION WE DISCLOSE TO THIRD PARTIES

We disclose your information to select third parties as set forth below.

We may also use and disclose your information for our protection and the protection of others to prevent fraud, misappropriation, infringements, identity theft, and other illegal activities and misuse of our Services.

We may disclose this information within Pengwenz and with third parties for our or their purposes in an aggregated form that is designed to prevent anyone from identifying you.

A.  Disclosing to Others in My Huddles or Flock

Depending on which tools and functionalities are enabled, you may choose to disclose your personal information to other members of your Pengwenz My Huddle or Flock including, but not limited to, your:

• Full Name; 
• Email Address; 
• Precise Location; 
• Battery Level;
• Emergency Situations;
• Membership Level;
• Permissions;
• Information about your use of our Service with members of your My Huddle or Flock (e.g. whether you have logged in on a new device); and

In addition, other members of your My Huddle or Flock may disclose your personal information in certain circumstances, such as:

• Escalated events such as SOS or I’m Nervous that may include such things as Group Chats and other functionalities; or
• if a member of your My Huddle or Flock enables voice actions on Google Assistant-enabled or Alexa-enabled devices, your personal information may be displayed to your My Huddle or Flock members on screen or via audio response on any device with the voice action enabled.

To prohibit this data disclosure, you must ask your My Huddle member to disconnect his or her account from the voice action-enabled devices, or you can leave the My Huddle shared with that member.

B.  Information Posted to our Blogs, Community Forums, or Other Public Websites

Any information or content that you voluntarily submit, or post to the Pengwenz website or blog. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third-party websites.

We shall not be responsible for any information you (or members or members of your Flock or My Huddle) choose to provide on social media pages, or for any content or communications you receive as a result of sharing such information.

To request the removal of your information from our website or blogs, please contact us at peng-privacy (at) pengwenz.com.

C.  Service Providers, Business Partners, and Advisors

We may disclose some of your personal information to our vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, email or chat services, marketing or analytic services, fraud prevention, bot detection, web hosting, and to other third-party partners or service providers who agree to process personal information solely as necessary to provide services or features to our members on our behalf or behalf of our permitted business partners. 

We will never disclose your telephone number (in a non-obfuscated format) with any of our third-party business partners, vendors, or consultants for their independent SMS marketing purposes without your explicit, affirmative opt-in consent.

D.  Purchasers and Other Third Parties in Connection with a Business Transaction

We may at any time buy or sell/divest the company, or any portion or combination of its products, services, assets and/or businesses. Personal information such as member names and email addresses, and other member information related to our Services will likely be one of the items transferred in these types of transactions. We may also disclose, transfer, or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, or similar transactions or proceedings.

E.  Law Enforcement, Regulators, and Other Parties for Legal Reasons

We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, this Privacy Policy, other agreements, to take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of Pengwenz, our employees, members or others. 

F.  De-Identified Information 

We may share with third parties, including advertisers and service providers, anonymized, aggregated, and/or anonymous data we collect about you and other members, such as de-identified demographic information, de-identified location information, and information about the computer or device from which you access our Services, or the results of hashing your email address. 

5. YOUR CHOICES ABOUT YOUR INFORMATION

We believe in transparency and providing you with the opportunity to make important decisions about how your information is used, processed, stored, and shared as outlined in this section under Section 5A (Modifying, Correcting, Reviewing, and Deleting Your I Information). 

A.  Modifying, Correcting, Reviewing, and Deleting Your Information

You may modify your account information, update, or amend your personal information (e.g. name, email address, or phone number), or change your password by logging in to your App, clicking on “Settings” and then “Account” (for Pengwenz).

You may review the information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information, and the categories of third parties with whom we disclose personal information, or request that your information be deleted by submitting a request as described below. Please note that the information provided via the in-app links described in this section does not include technical information or support records. If you would like to request information related to your support records, please contact us directly at Pengwenz.com. 

In the Pengwenz app, you may:

You may also request the closure and deletion of your account by contacting us at peng-privacy (at) pengwenz.com peng-privacy (at) pengwenz.com with your deletion request. Please include your full name, the email address associated with your Account, the service you are using, and a detailed description of your deletion request. 

B.  Communications from Pengwenz

We may periodically send you promotional newsletters and emails. You can opt-out of these by following the unsubscribe instructions provided in the emails you receive. Certain communications, like billing information and Service updates, are necessary for you to receive, you will not be able to opt out of those communications.

C.  Location and Movement Data Collection and Sharing in the Pengwenz App

As described in Section 2 herein, we collect precise location data and movement data from your device to provide the Pengwenz Services, and may share your personal information, including location and movement data, with other Pengwenz members in My Huddles you belong to, and with third parties for research, analytics, attribution, and tailored advertising purposes. You have many options to control this data collection and sharing activity through the App Settings.

If you no longer want to continue using the Products and/or Services, uninstalling the Pengwenz app (as applicable), and logging out of our Service will also stop us from collecting your location. 

D.  Web-Based Personal Information Sales

You may also exercise your opt-in and opt-out rights related to web-based personal information sales or sharing via all of our websites, please click the “Do Not Sell or Share My Personal Information” link in the footer of the website and adjust the toggles as applicable.

Please note these settings must be completed for each browser on each device you use and for each of our website Pengwenz.com separately and will not affect App-based settings. If you clear your cookies or your browser is set to do so, you will have to exercise the choice again.  If you wish to modify how data is collected through the Pengwenz application, you must do so separately by following the instructions above. If you have not visited our sites, no action is required. 

6. OUR POLICY TOWARDS CHILDREN

Under the Children’s Online Privacy Protection Act (“COPPA”) and various other regulations, Pengwenz does not knowingly collect personal information from children under the age of 16 without verifiable consent of a parent or guardian. Our Services are not to be used by children under 16 without significant parental or guardian involvement, approval, and supervision of the minor child/children.  

If Pengwenz learns that we have inadvertently collected personal information of a child without parental consent as required by law, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child has a registered account with our Services or is using our Products without your consent, please alert us immediately by emailing Pengwenz.com so we can take corrective action to not collect personal information.

By enabling your child to create a member account and/or permitting your child to use the Services, you have expressly agreed to the practices described in this Privacy Policy and you consent to the collection, use, and disclosure of your child’s personal information as described herein.

A.  Setting up a Child Account

If a parent wishes to add a member who is a child to our Services, we request the parent provide verifiable consent when required by COPPA, through one of several methods, such as by verifying the parent’s driver’s license or by submitting a parental consent form via mail or email. The child will then be able to participate in most aspects of the Pengwenz Services. In some instances, our Products are intended to be worn and used by children and pets. By providing the Products to a child, you represent and warrant to Pengwenz that you consent to such child’s use of our Services and further consent as a parent to enable and permit Pengwenz’s collection and use of the information from the Services used by the child as stated in this Privacy Policy and the Terms of Use. 

B.  Personal Information We Collect About Children

We take special precautions to collect only as much information as is reasonably necessary for the child to use our Services.

C.  Information sharing about Children

Per the Terms of Eligibility, Service 1. Pengwenz is designed for Users older than 16 years of age.  Pengwenz does not knowingly disclose a child’s personal information to our third-party vendors, service providers, and business partners as described in this Privacy Policy. The child’s profile information and location will be shared with other members of any My Huddle or their Flock which the child joins. Please note the child will be able to share his or her location with other members of My Huddle or Flock and may exchange messages with those My Huddle or Flock members. You, as a User, Guardian, Flock Organizer, parent, legal guardian, family member are responsible for monitoring your child’s account, permissions, access, location-sharing activity, and any other functions or abilities through our Services and for blocking or permitting location-sharing features.  Please see the Terms of Service 1. Eligibility for more information regarding minors.

D.  Minors Generally

Per the Terms of Service 1. Eligibility, Pengwenz is designed for Users older than 16 years of age.  We do not sell the personal information of members we know to be less than 16 years of age. If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at Pengwenz.com We may not be able to modify or delete your information in all circumstances. 

E.  Contact Us Regarding your Child’s Account or Information

The parent or legal guardian has a right to request to review or have deleted the child’s personal information and may withdraw consent for our Services to collect any further personal information from the child. Please contact us at Pengwenz.com to request to review and/or delete any personal information we may have collected from the child, or to withdraw permission for Pengwenz to collect any additional information from the child. We will require the parent or guardian to provide us with sufficient identification before providing access to or acting upon, such personal information.

7. HOW WE PROTECT YOUR INFORMATION

Pengwenz cares about the security of your information and we make great efforts to protect your personal information. We cannot guarantee and you cannot reasonably expect that our databases which may be stored on third-party servers such as Amazon S3 will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

A.  Security 

We have implemented appropriate standards to reduce the risk of unauthorized or unlawful access of your personal information. No security system is impenetrable, and we cannot absolutely guarantee the security of our systems and your information. 

We will never send you unsolicited messages or contact you by phone requesting sensitive information. This may include account ID, password, payment, or national ID numbers. Please note that e-mails and other communications you send to us are not encrypted, and we strongly advise you not to share any sensitive information through these means. 

If any information under our control is compromised because of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify the impacted individuals and take steps following any applicable laws and regulations.

B.  Accuracy and Confidentiality of Your Email Address and Password

You are solely responsible for the secrecy of your password and ensuring the email address associated with your account(s) is accurate. We use your email address to contact you about service updates, changes to our policies, and account activities such as requests for your information. We recommend using a strong password unique to this service. If you believe your account has been compromised, change your password immediately via the applicable app or website. 

Pengwenz is not responsible for information or data transmitted to a third party because of a member providing an incorrect phone number or email address.

C.  Data Retention

Pengwenz retains the information we receive as described in this Privacy Policy for as long as you use our Services or as otherwise necessary to fulfill the purpose(s) for which it was collected, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business interests, enforce our agreements, and to comply with applicable laws. Our retention is based upon the amount, nature, and sensitivity of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests.  The purposes for which we process information may dictate different retention periods for the same types of information. 

8. ADDITIONAL STATE, COUNTRY, AND REGION-SPECIFIC PRIVACY TERMS

If you are using the Pengwenz App you must be aware of your local, state, and international laws that may govern your use of the App. We at Pengwenz strive to abide by all local, state, and international laws.

Our legal basis for processing your personal information varies depending on the type of information we collect and the context in which we collect it as well as our records in your country of residence. Depending on where you reside, we may rely on different legal bases to process your information. As we are in the USA, you agree that all information collected via or by Pengwenz may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, in the cloud, on our servers, or the servers of our service providers. Your information may be accessible to law enforcement or other authorities according to a lawful request.

9. LINKS TO OTHER WEBSITES AND SERVICES

Our Services may contain links to websites and services that are owned or operated by third parties. Any information that you provide on or to a third-party service, or that is collected by a third-party service, is provided directly to the owner or operator of the third-party service and is subject to the owner’s or operator’s privacy policy. Please remember that when you use a link to go from the Pengwenz Services to another website or app or engage with a third-party service, our Privacy Policy does not apply to those third-party websites or services. You’re browsing and interaction, on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies, and Pengwenz is not responsible for the practices employed by those apps, websites, or services, nor the information or content contained therein.  

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, so please review it frequently. We’ll notify you of material changes thirty days before they go into effect. If we are required by applicable data protection laws to give you enhanced notice or seek out consent to any such changes, we will do so. Otherwise, changes to this policy will be effective when posted. 

If you object to any of the changes to this Privacy Policy, you must cease using our Products and/or Services and may request us to erase your personal information. Any information that is collected through your use of our Services is covered by the Privacy Policy in effect at the time such information is collected.

11. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS

If you have any questions about our privacy practices, this Privacy Policy, our Products, or Services, please contact us at peng-privacy (at) pengwenz.com or by postal mail:

Pengwenz, Inc.

8204 Fern Bluff Ave.

Round Rock, TX 78681

United States

 A. Authorized Agents

You may authorize another person (your “agent”) to contact us on your behalf. Authorized agents must submit the request via email to peng-privacy (at) Pengwenz.com and include a signed letter from the Pengwenz member confirming the agent has permission to submit the request on the member’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the member about whom the request is being made and/or to verify that the member has provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the Pengwenz member on whose behalf the request was made. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. 

12. No Waiver

No waiver of any term of this Agreement shall be deemed a further or continuing waiver of such term or any other term, and Pengwenz’s failure to assert any right or provision under this Agreement shall not constitute a waiver of such right or provision.

13. Contact

Please contact us peng-privacy (at) pengwenz.com with any questions regarding this Agreement.

This Agreement was last modified March, 2024.

14. Language

You and Pengwenz have each expressly requested and required this Agreement and all ‎documents that relate hereto be drawn up in the English language.