Penguin Privacy Policy

Last Updated: June 17, 2026

1. Introduction

Penguin ("we", "our", or "us") respects your privacy. This Privacy Policy explains how Penguin IP Holdings Inc. collects, uses, stores, shares, and protects your personal information when you use the Penguin mobile application, website, and related services (collectively, the "Service").

Penguin is a community app. Some people use it to date and look for relationships; others use it to meet people and take part in the community without dating. Some features, including dating and matching, are optional, and you choose whether to use them. What we collect depends in part on which features you use.

We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, for our users in Quebec, the Act respecting the protection of personal information in the private sector (Quebec Law 25). Please read this Policy together with our Terms of Service.

2. Person Responsible for the Protection of Personal Information

Penguin has designated a Privacy Officer responsible for the protection of personal information and for handling your requests and complaints:

Louis Yoon, Chief Executive Officer
Penguin IP Holdings Inc.
770 Brookfield Rd, Suite 206
Ottawa, Ontario, Canada
Email: info@thepenguinapp.com

You may contact our Privacy Officer at any time with questions, requests, or complaints about your personal information.

3. Information We Collect

a. Information You Provide

• Account and identity information: name, email address, date of birth, and phone number.
• Profile information: photos, biography, prompts, and dating preferences.
• Sensitive information (dating and matching users only, with express consent): sexual orientation; and, optionally, race or ethnic background. We do not collect this from users who use Penguin only for community and social connection. See Section 5.
• Communications: messages you exchange with other users or with us.

b. Information Collected Automatically

• Device and usage information: device and app details, identifiers, IP address, access times, and how you interact with the Service.
• Approximate location: derived from your IP address for security and regional functionality.
• Precise location: only when you grant permission. See Section 5 and Section 6.
• Analytics: only when you have consented to analytics tracking. See Section 5.

c. Information from Third Parties

• Information from service providers that help us with hosting, analytics, fraud prevention, and photo screening.
• Profile information from a linked third-party account, if you choose to link one.

4. Device Permissions

The Service requests the following device permissions. You control them and can change them at any time in your device settings.

• Camera: To scan QR codes, including to start sharing your location with a person you are meeting on a date. We do not store video.
• Photos: To let you select images to add to your profile, which are shown to other users.
• Precise Location: To show you your own location, and to let you share it with the person you are meeting on a date (Section 6). Not used for advertising.
• Contacts: To let you invite people you know, and to suggest people you may already know who are on Penguin (Section 7).
• Push Notifications: To send matches, messages, and important service or safety updates.

5. Sensitive Information and Consent

Some of the information we handle is sensitive personal information, which we collect only with your express, opt-in consent, given separately from your agreement to this Policy. We collect the sensitive information below only from users who use Penguin for dating and matching. If you use Penguin only for community and social connection, we do not ask for or collect it. You can withdraw consent at any time, and doing so will not affect your access to the community side of the Service.

Sexual orientation. If you use Penguin for dating and matching, we collect your sexual orientation so the Service can surface potential matches consistent with who you are interested in. We do not collect it from users who are not using the matching features.

Race or ethnic background (optional). If you use Penguin for dating and matching, you may choose to provide your race or ethnic background. This field is optional and not required to use the Service. Where you provide it, we use it to support an optional preference feature that helps users find others who share a similar cultural background. You can leave it blank, change it, or delete it at any time, and you can turn the feature off at any time. We do not use this information for advertising, and we do not sell it.

Precise location. Collected only when you grant permission, to show you your own location and to let you share it with a person you are meeting on a date. Sharing begins only when you scan that person's QR code. See Section 6.

Analytics tracking. We ask for your consent before using analytics that track your activity in the app. If you decline, we will not track your usage for analytics, and the Service still works. You can change this anytime in the app's privacy settings.

We will not use your sensitive information for any purpose other than those described here without your further express consent.

6. Location During a Date

When you grant location permission, the Service can use your precise location only to:

• Show you your own location within the app.
• Let you share your location with the specific person you are meeting on a date, for safety.

Location sharing with your date is not automatic. It begins only when you scan that person's QR code in the app, which requires you to be physically together. You can stop sharing at any time. Your precise location is shared only with the person whose QR code you scan, and with no other user, advertiser, or third party. We will not use your precise location for any other purpose without first updating this Policy and, where required, obtaining your consent.

7. Contacts

If you grant Contacts permission, Penguin uses your contacts to:

• Invite people you know. You initiate and send each invitation from your own device. Penguin does not send invitations on your behalf.
• Suggest people you may know. We match your contacts against our user base to suggest people already on Penguin.

We use your contacts only for these purposes. We do not build profiles of people who are not on Penguin, we do not sell contact information, and we do not retain information about non-users beyond what is needed for these features. You can control whether others can find you through their contacts in your privacy settings. Granting Contacts permission is optional.

8. Photo Screening (Face Detection)

We use Amazon Rekognition (provided by Amazon Web Services) to perform face detection on profile photos, determining whether a photo contains a human face so we can screen out images that do not show a person.

This does not create a faceprint or other biometric identifier, and does not identify you or match your face against other images or databases. Profile images are sent to AWS for this single purpose. See Section 11 for where this processing occurs.

9. How We Use Your Information

We use your information to operate, maintain, and improve the Service, including to create and manage your account, enable matching, conversations, and other core features, and screen profile photos for authenticity (Section 8). We also use it to keep the Service safe, by detecting and responding to fraud, abuse, and safety risks, to send you service, security, and (where you have opted in) promotional communications, to conduct analytics where you have consented (Section 5), and to meet our legal obligations and enforce our Terms.

We rely on your consent for sensitive information and analytics tracking. For other processing, we rely on the basis that the information is necessary to provide the Service you requested, or on our legitimate need to operate and secure it, consistent with applicable law.

10. How We Share Your Information

We do not sell your personal information. We share information only as described below.

• With other users: your profile and the content you choose to share are visible to other users. Information you send in messages is shared with the recipient.
• With service providers acting on our behalf, under contracts that require them to protect your information and use it only for the services they provide to us. These help us with hosting and storage, product analytics (where you consent), email delivery, and photo screening (Amazon Rekognition, Section 8).
• For legal and safety reasons: to comply with law, respond to lawful requests, enforce our Terms, or protect the rights, safety, and security of users, the public, or Penguin.
• For child safety: we may disclose information to NCMEC, Cybertip.ca, law enforcement, or other authorities where required by law or where we become aware of CSAM or CSAE activity (see Section 15).
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy and applicable law.

11. Where Your Information Is Stored

We use service providers based in Canada and the United States, and your personal information, including, for matching users, sensitive information, may be stored or processed in either country.

Privacy laws in the United States differ from those in Canada. Before allowing personal information to be processed outside Quebec, we assess whether it will receive adequate protection, taking into account its sensitivity, the purpose, the contractual and security protections in place, and the legal framework that applies where it is processed. If you access the Service from outside Canada, your information may be processed in Canada and the United States.

12. Cookies and Similar Technologies

On our website, we use cookies to enable core functionality and, where you consent, to measure usage. You can control them through your browser settings, though some features may not work if you disable them. In the app, analytics tracking is governed by your consent choice described in Section 5.

13. Your Rights and Choices

Subject to applicable law, you may:

• Access the personal information we hold about you.
• Correct or update inaccurate or incomplete information.
• Delete your account and personal information, subject to the retention exceptions in Section 14.
• Withdraw consent to sensitive information or analytics tracking, at any time.
• Receive a portable copy of the computerized personal information you provided, in a structured, commonly used format (data portability under Law 25).
• Opt out of promotional emails using the unsubscribe link or by contacting us.
• Control device permissions and location sharing through your device and in-app settings.

To exercise these rights, use the in-app settings or contact our Privacy Officer at info@thepenguinapp.com. We will respond within the timeframes required by law. If we refuse a request, we will explain why and how to complain.

If you are in Quebec and not satisfied with our response, you may complain to the Commission d'accès à l'information du Québec. Elsewhere in Canada, you may contact the Office of the Privacy Commissioner of Canada.

14. Data Retention

We retain your personal information for as long as your account is active and as needed to provide the Service. When you delete your account, we delete or de-identify your personal information within a reasonable period, except where we must retain certain information to meet legal, tax, or regulatory obligations, resolve disputes, enforce our agreements, prevent fraud or abuse (including records of banned users to prevent re-registration), or address safety matters, including information related to CSAM or CSAE for reporting to authorities, even after account deletion, as required or permitted by law.

We keep sensitive information only as long as necessary for the purpose you consented to.

15. Children's Privacy and Child Safety

The Service is intended only for adults 18 and older. We do not knowingly collect personal information from anyone under 18, and if we learn we have, we will delete it promptly.

We strictly prohibit any use of the Service to exploit or abuse minors. 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 NCMEC via cybertipline.org, to Cybertip.ca, or to the relevant regional authority, as required by applicable law. To report a child safety concern, contact info@thepenguinapp.com.

16. Data Security and Breach Notification

We implement reasonable administrative, technical, and physical safeguards to protect your personal information. No system is completely secure, and we cannot guarantee absolute security.

If a confidentiality incident (data breach) occurs that presents a risk of serious injury, we will notify affected individuals and the relevant authority, including the Commission d'accès à l'information du Québec where required, and we will keep a register of confidentiality incidents, in accordance with applicable law.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will update the "Last Updated" date and, where required by law, notify you of material changes and obtain any consent the law requires before the change takes effect.

18. Contact

If you have questions or concerns about this Privacy Policy, contact our Privacy Officer at:

Penguin IP Holdings Inc.
770 Brookfield Rd, Suite 206
Ottawa, Ontario, Canada
Email: info@thepenguinapp.com