1. Who we are
PennyAI LTD is registered in England and Wales under company number 17412793, with its registered office at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. In this policy, “we,” “us,” and “our” refer to PennyAI LTD. “Penny” means our AI telephone receptionist service.
For account, website, billing, and support information, we generally act as the business responsible for deciding how that information is used. When we handle caller information on behalf of a business customer, that customer generally decides why and how the information is processed, and we act as its service provider or processor.
2. Information we collect
Depending on how you interact with Penny, we may collect:
- Account and contact information, such as your name, email address, telephone number, login details, and workspace members.
- Business configuration, such as business hours, services, FAQs, instructions, routing rules, calendar settings, and other information you provide to configure an agent.
- Call information, such as caller and recipient phone numbers, call times, duration, status, caller requests, details collected during a call, transcripts, summaries, and recordings when recording has been enabled.
- Billing information, such as plan, usage, transaction, and payment status. Payment card details may be collected directly by our payment processor rather than stored by us.
- Integration information, including identifiers, permissions, and data exchanged with calendars, CRMs, telephone providers, and other services you connect.
- Device, usage, and support information, such as IP address, browser type, pages viewed, service logs, diagnostics, communications, and feedback.
3. How we use information
We use personal information for the purposes below. Google Workspace data is subject to the additional limits in Section 6, including our prohibition on generalized AI model training.
- provide, operate, secure, maintain, and improve the service;
- create and manage accounts, workspaces, agents, and phone numbers;
- answer and route calls, collect requested details, create call records, and support configured business workflows;
- process payments, measure usage, and administer subscriptions;
- provide support and send service-related communications;
- detect fraud, abuse, security incidents, and technical problems;
- comply with law and enforce our agreements; and
- send marketing communications where permitted. You can opt out of marketing emails at any time.
4. Legal bases
Where applicable law requires a legal basis, we process information as needed to perform our contract with you, comply with legal obligations, protect our legitimate interests or those of others, and with your consent where consent is required. You may withdraw consent at any time, without affecting processing that occurred before withdrawal.
5. How we share information
We may share information with:
- vendors that provide voice AI and telephony, cloud hosting, databases, authentication, payments, communications, analytics, security, and customer support;
- third-party services you choose to connect, such as a calendar or CRM;
- professional advisers and authorities when reasonably necessary to comply with law, protect rights and safety, or investigate abuse; and
- a buyer, investor, or successor in connection with a financing, reorganization, sale, or transfer of all or part of our business.
We require service providers to handle personal information only for the services they provide to us or our customers, subject to their contracts and applicable law. Our providers, their services, and the types of information they process are described in our Subprocessor List.
We do not sell personal information for money. We also do not share personal information for cross-context behavioral advertising.
6. Google Workspace data and AI
Your connected calendar data is not used to train general AI models. We do not use Google Workspace API data, including raw, aggregated, anonymized, or derived data, to develop, train, fine-tune, or improve generalized or foundational artificial intelligence or machine learning models. We do not sell or transfer this data for those purposes, or permit our AI providers to use it for those purposes.
When you connect Google Calendar, Penny accesses your connected account email, calendar availability, and event identifiers, titles, and times. We use this information to display your calendar, offer available appointments, and create or cancel appointments as authorized. Calendar access is separate from signing in.
Our AI service processes availability and booking results to answer callers and arrange the appointments you authorize. This information, including data derived from Google Workspace APIs, may appear in call transcripts, summaries, customer notifications, and recordings when enabled. Our Subprocessor List identifies the providers and the information they process for these features.
Our use and transfer of information received from Google Workspace APIs adheres to the Google API Services User Data Policy and the Google Workspace API User Data and Developer Policy, including the Limited Use requirements.
These restrictions govern Google Workspace data wherever this policy otherwise describes service improvement, marketing, aggregation, or sharing. We do not use this data for advertising. Transfers are limited to providing the authorized features with your consent, security, legal requirements, or a merger, acquisition, or asset sale with your explicit prior consent. Human access is limited to your documented consent, security needs, legal requirements, or aggregated and anonymized data used for permitted internal operations.
Calendar connection credentials are encrypted at rest. Disconnecting in Penny's Calendar settings removes the stored connection credentials and stops future calendar access; existing calendar events remain. You can also revoke access in your Google Account connections. Disconnecting does not automatically delete existing call records. To request deletion of retained information, contact privacy@pennysdesk.com. The Limited Use restrictions continue to apply to retained Google data and its derivatives.
7. Call recording and caller notices
Audio recording is disabled by default and can be enabled by the business customer. When enabled, Penny adds a spoken recording notice unless the configured greeting already mentions recording. Check any customized greeting for accuracy. A notice alone may not satisfy every applicable consent rule; the customer remains responsible for any additional notices, consent, and lawful instructions required for its callers and business.
Turning off audio recording does not stop the audio processing needed to answer a call. Transcripts, summaries, call metadata, and temporary recovery records may still be created. Optional recordings are stored privately and accessed through authorized, time-limited links.
8. Data retention
We retain information for as long as reasonably necessary to provide the service, follow customer settings and instructions, maintain security and business records, resolve disputes, and meet legal obligations. Retention periods vary based on the type of information and why we process it. Recordings have a scheduled expiry under the service's configured retention period; transcripts and summaries have separate retention. Turning recording off does not delete earlier call records. Deletion may take longer during a storage or processing outage. We may retain de-identified or aggregated information where it can no longer reasonably identify a person. Retention does not expand our permitted uses: retained Google Workspace data and its derivatives remain subject to Section 6, including the prohibition on generalized AI model training.
9. Security
We use reasonable administrative, technical, and organizational measures designed to protect personal information. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
10. International transfers
We and our service providers may process information in countries other than the country where it was collected. Where required, we use recognized safeguards for international transfers, such as contractual protections.
11. Your choices and privacy rights
Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your personal information; restrict or object to certain processing; withdraw consent; or appeal a decision about a request. You may also have the right to complain to your local data protection authority. We may need to verify your identity before completing a request.
If we processed your information during a call on behalf of one of our business customers, please contact that business first. We will assist the business with valid requests as required by law.
12. Children
Penny is a business service and is not directed to children under 18. We do not knowingly collect personal information directly from children for account creation or marketing.
13. Cookies and website measurement
Necessary cookies support sign-in, security and preferences you request. Sign-in cookies are refreshed during use and cleared on sign-out; their browser expiry can be up to 400 days, while session validity is controlled separately. Temporary verification cookies protect sign-in and recovery. Calendar connection security cookies expire after 10 minutes. We remember your last sign-in method for up to one year and your sidebar preference for seven days.
The penny_consent cookie records your analytics choice and when you made it for 180 days. It applies to our website and app in this browser. You can reject optional cookies or change your choice using the control below at any time. Blocking necessary cookies in your browser may prevent sign-in.
Optional analytics cookies
With your consent, we measure page visits, traffic sources and campaigns, signup-button clicks, visible sections, scroll depth, signup attempts and completion, checkout starts and confirmed subscription payments. This helps us understand where people leave the signup journey and which campaigns lead to customers.
Cookies named _ga and _ga_* distinguish browsers and sessions for up to 180 days, refreshed during use. The penny_measurement cookie holds browser and session identifiers for up to 180 days, refreshed during use, so our server can associate confirmed conversions with your visit. A pseudonymous account identifier can link your consented visits across sessions and signed-in devices. We store consented measurement identifiers against your account while consent is valid. Withdrawal and sign-out remove that association; expired associations cannot be used and are cleaned up during preference updates. We retain a consent withdrawal timestamp for up to 180 days to prevent delayed requests restoring an old choice. Account deletion removes this record.
Analytics includes general device, browser, approximate location, campaign and interaction information, with account and transaction identifiers that do not contain your name or email. We do not send form contents, passwords, authentication tokens, caller information, transcripts or recordings to analytics. User and event-level analytics data is retained for up to 14 months; aggregate reports may remain longer.
Our analytics processor is named in the Subprocessor List. See how the analytics provider uses information from sites and apps, including processing outside the UK. Optional analytics relies on your consent. Declining it does not affect your access to Penny.
We do not enable personalized advertising, session replay or heatmaps. We honor Do Not Track and Global Privacy Control signals. Withdrawing consent stops future measurement and removes analytics cookies; it does not automatically erase data already collected. Contact privacy@pennysdesk.com to exercise your data rights.
14. Changes to this policy
We may update this policy from time to time. We will post the updated version here and change the effective date. If a change is material, we will provide additional notice when required by law.
15. Contact us
For privacy questions or requests, email privacy@pennysdesk.com.