Privacy Policy

Pengo is trade-fair research software: it reads public exhibitor directories, company pages and event agendas, scores the companies it finds against a description of who a customer sells to, and presents the result. This Privacy Policy describes how we handle personal information collected through our website at trypengo.com, the product at app.trypengo.com, our MCP and API endpoints, and our email and support conversations (together, the "Service").

Who we are

The Service is run by Bhagyalakshmi S, a sole proprietor in India trading as Pengo ("Pengo", "we", "us" or "our"). Pengo is one person's business, not a company, so the controller of the personal information described here is that person. A postal address is available on request from the inbox below; write and ask, and you will get it.

A question about this policy, a data request, an objection or a complaint all go to hey@trypengo.com. Under India's Digital Personal Data Protection Act, 2023, Bhagyalakshmi S is the Grievance Officer and that is the address to reach them at. It is one inbox, watched by a person rather than a form, and a request sent to it does not need an account behind it.

Personal information we collect

Information you give us

Account data. Your name, email address and the credentials you set, handled by our authentication provider Clerk. We never see or store your password.
Profile and research settings. The description of who you sell to, your region, industry and home base, your company name, your time zone and your company website. These are the settings every score is decided against.
Communications data. What you write to us by email or in support, and our replies.
Transactional data. Your plan, your credit balance, the ledger of what each research pass cost, and your order history. Card details are taken and held by our payment provider Dodo Payments; they do not reach our servers.
Work you record in the product. The booths you mark as go, skip or visited, and the notes you type against a stand or a person. This is yours, it is stored separately from anything a research pass writes, and no research pass ever overwrites it.

Information we collect automatically

Device and log data. IP address, browser and operating system, pages requested and timestamps, collected by our hosting providers to serve the Service and keep it working.
Error reports. When something breaks, our error monitoring provider Sentry records the failure with the request that caused it, which can include your account identifier and the page you were on. This runs whether or not you agree to analytics, because a Service we cannot debug is one we cannot keep working.
Usage data. Which research passes ran, what they cost and whether they succeeded. This is what the spend view and the credit ledger are built from, and it is part of running the Service rather than a measurement of you.
Visits to the website. On trypengo.com, once you have answered the cookie banner either way, PostHog counts which pages are read, where visitors arrive from and which links get pressed. If you declined, this is done without a cookie: nothing is stored in your browser, and the visit is attributed to a hash of your connection and browser that PostHog's server derives with a salt it changes every day, after which your address is discarded. The same browser on two days is two visitors, and nothing can be joined to an account. The product at app.trypengo.com counts nothing without your agreement.

Information we collect only if you agree

Product analytics. PostHog records which features you use and when, tied to your account identifier, so we can see which passes fail and where people get stuck. It is hosted in PostHog's European region.
Session recordings. A sample of roughly one session in ten is recorded by Sentry's session replay, which reproduces what happened on the page. It is what turns an error report into something we can actually follow.

Neither of those starts until you press Allow on the banner that asks. Until then the analytics client is loaded but switched off, holding nothing outside the browser tab, and the session recorder is not loaded at all. You can change the answer at any time under Settings → Account → Analytics; turning it off stops a recording in progress, and takes effect for future sessions immediately.

We do not collect precise geolocation, financial account or government identification numbers, biometric data, or any of the special categories of data described under the heading on sensitive information below.

Information from public sources

The product's whole purpose is reading public pages: exhibitor directories published by fair organisers, company websites, published conference agendas, and public professional profiles and posts. Those pages often name people, and where they do, the research records what the page states. The section below is about that.

People our research finds

If you are named on a public exhibitor listing, a published conference agenda or a public professional profile, a Pengo customer's research may have recorded you. This section says exactly what that means, because it is the part of the Service most likely to concern somebody who has never used it. There are two kinds of record and they are not the same size.

A listing, from a fair

What is recorded: Your name, your job title, the company you were listed under, the fair and session you were listed for, a link to the page you were read from, and, only where the page itself states one, a business email address or a link to your professional profile. Nothing is inferred: an address that was not read on a page is discarded rather than guessed, and a profile link is stored only when the profile confirms the name.
Where it came from: A page a fair organiser or your employer published. Every listing carries the source URL it was read from, and it is shown to the customer beside your name.
How long: Until the listing stops being published. When a fair's roster is re-read and you are no longer on it, your listing is retired and stops being shown.

A profile, from a search aimed at you

A customer who knows your name and your employer can buy a search about you specifically. It reads your public professional profile and builds a page: your photograph, the biography your profile states, your job title, your city, the address of the profile, and your recent public posts with the passage the run thought relevant. That page is a profile of you in the ordinary sense of the word, and we are calling it one rather than describing it as a search result.

One further thing is written about you and is worth naming separately. Where a customer has bought a company search, a language model is given your name, your title and the fair you are appearing at, and writes two sentences for that one seller: who you are to them, and something they could open a conversation with. Those sentences are stored against that customer's account only. There is no score, no ranking and no assessment of you as a person. Pengo scores companies, not people. But a sentence about why you are worth twenty minutes is an assessment of a kind, and it should not take reading the source code to find that out.

What is never recorded, and what we never do

No home address, no personal phone number, no personal email address. Only a business address a page actually printed.
No special category data. Nothing about health, beliefs, politics, union membership, sex life or ethnicity is asked for, extracted or stored, and the extraction prompts refuse anything outside the professional record.
No email is ever sent to you by Pengo. The product has no feature that contacts the people it finds. A customer who writes to you did so themselves, under their own obligations, and we tell them in our Terms that those obligations are theirs.
Nothing is sold. No listing, profile or post leaves the Service to a data broker, an advertiser or a marketing list.

Why we are allowed to hold it, and how to make it stop

Our legal basis is legitimate interest, ours and our customers', in knowing who represents which company at a professional event, which is the same interest that makes an exhibitor directory public in the first place. We think it is a fair balance for a fair listing: the data is business-context information you or your employer published for exactly this audience, it is narrow, and it carries its source. A profile built by a search aimed at you is a heavier processing and we say so; if you object to it, we will not argue the balance with you.

To object, to correct something, or to be removed entirely, write to hey@trypengo.com with the name and, if you have it, the fair or the link. You do not need an account, we do not charge, and we will not ask you why. We will confirm when it is done.

Cookies and similar technologies

Strictly necessary cookies keep you signed in and protect the session against forgery. The Service cannot work without them, there is no version of it that does, and they are set without asking because there is nothing to ask about.

Analytics is the other kind, and it is the only other kind. PostHog sets a cookie so that visits by the same browser can be joined together; Sentry's session replay records a sample of what happened on the page. Both are optional, both are off until you press Allow on the banner, and both can be switched off again under Settings → Account → Analytics. Declining costs you nothing in the product.

The website at trypengo.com is different in one respect, and the banner there says so. It sets no cookie until you answer, and if you decline it sets none afterwards either: visits are then counted without a cookie, by the daily-changing hash described above, which cannot recognise you tomorrow and cannot be tied to an account. That count is the one thing this policy does on the basis of our legitimate interest in knowing whether the site is read, rather than your consent, and it is limited to what a count needs: pages, referrers, presses. Saying yes on the website sets the PostHog cookie, so that reading a page and later signing up can be seen as one journey.

We run no advertising cookies, no advertising pixels, and no cross-site tracking. We do not participate in interest-based advertising and we share nothing with advertising networks, which is why this policy has no advertising opt-out. There is nothing to opt out of.

Some browsers send a "Do Not Track" or Global Privacy Control signal. Because we neither sell personal information nor advertise on the basis of it, there is no such processing for those signals to stop; we honour them as opt-out requests where any applicable law requires it.

How we use personal information

Running the Service. Creating your account, running the research passes you buy, quoting and charging credits, keeping the ledger, sending you the emails the Service owes you about your account and your research, and supporting you when something goes wrong.
Security. Authenticating you, enforcing rate limits and daily spend caps, detecting abuse, and investigating incidents.
Keeping it working. Error reports, so a failure can be reproduced and fixed.
Understanding how it is used. Product analytics and session recordings, where you have agreed to them, to see which passes fail and where people get stuck.
Compliance and protection. Complying with law, responding to lawful requests, and establishing or defending legal claims.

We do not read your notes to improve the product, and we do not sell or rent personal information to anybody.

Artificial intelligence, and what happens to what you type

Pengo sends prompts to third-party model providers to extract facts from public pages, to score companies against your description of your buyer, and to answer the questions you ask in the Ask AI panel. Extraction requests carry the page being read. Scoring requests carry your seller description and rows already on file.

Ask AI is the one that deserves a plain sentence, because the obvious assumption about it is wrong. It answers about the screen you are looking at, so the server assembles the rows on that screen and sends them to the model. Where those rows carry notes you typed, the notes go with them. Your billing data and your credentials never do. If you would not send a note to a language model, do not type it into a booth on a tab you then ask about.

We do not use your data to train models, and our model providers are contractually prohibited from using data submitted through their APIs to train theirs. Pengo makes no automated decision about you that produces a legal or similarly significant effect: the scores in the product are one customer's ranking of companies, and they are advisory.

We do not sell personal information, and we do not share it for cross-context behavioural advertising. We disclose it in these situations only:

Service providers: Vercel (website and application hosting), Convex (database and backend), Clerk (authentication), Dodo Payments (payments, as merchant of record), Resend (transactional email), Sentry (error monitoring and session replay, European region), PostHog (product analytics, European region), OpenAI (extraction, scoring and Ask AI) and Exa (searching and reading public pages). Each is bound by contract to process data only on our instructions. Write to us for the current list. It is short enough to answer in a sentence, and we would rather tell you than publish a page that goes stale.
Systems you connect yourself: If you connect a CRM, HubSpot or Attio, pressing the push button sends the company and contact rows you selected into your own CRM. That happens only on your press, never on a schedule, and never in the background. What you send is then in your system under your policy, and we cannot retract it.
Agents you connect yourself: If you connect Pengo to an MCP client, that client reads what your account holds when you ask it to. What the client does with the answer is governed by whoever operates it.
Professional advisers: Lawyers, accountants, auditors and insurers, in the course of the services they provide us.
Authorities: Law enforcement and government authorities where we believe in good faith that disclosure is required by law, or necessary to protect the rights, property or safety of anybody.
Business transfers: A counterparty and its advisers in an actual or prospective investment, financing, merger, acquisition or sale of assets, and the acquirer or successor afterwards. You would be told before your information became subject to a different policy.

Retention

Account and billing data is kept while you have an account and afterwards for as long as tax, accounting and legal obligations require. Closing your account deletes your settings, your notes, your marks, your API keys and your CRM connections: the deletion is scheduled the moment the account closes and walks through the tables in batches. Research findings about companies are shared facts, are not yours or anybody's, and outlive any one account.

Findings about a person are retired when the page they were read from stops listing them, and deleted on request. Error reports, analytics events and session recordings are kept for the retention period each provider applies, which we have not shortened from their defaults; if a specific number matters to you, ask and we will tell you what it currently is rather than print one here that drifts.

Security

We use technical and organisational safeguards designed to protect personal information: encryption in transit, authentication and access control on the systems that hold it, rate limits and spend caps that bound what a compromised credential can do, and separation between what the research writes and what a customer records. Security risk is inherent in all internet technologies, so we cannot guarantee the security of information transmitted to us.

If a breach happens that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within the time the applicable law allows, 72 hours under the GDPR, and tell you directly where the risk to you is high. Reports of a vulnerability are welcome at hey@trypengo.com and will not be met with a lawyer.

Sensitive information

Please do not send us sensitive personal information through the Service or otherwise. That means data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, health, sex life or sexual orientation, biometric or genetic data, or criminal records. We do not ask for it, we have no field for it, and the free-text boxes in the product are not a place for it.

International transfers

We are based in India and our providers operate in several countries, including the United States and the European Union. Using the Service therefore involves transferring your personal information across borders. Where we transfer personal information out of the European Economic Area or the United Kingdom, we rely on an adequacy decision where one covers the destination, and otherwise on the European Commission's standard contractual clauses or the UK international data transfer addendum. India has not been the subject of an adequacy decision, so transfers here rest on those clauses. You can ask us which mechanism applies to a particular transfer.

If you are a customer with your own obligations

Most of what Pengo holds we decide about ourselves, which makes us the controller of it. Two things are different: the content you put into the Service, and the contacts you push into your own CRM. There you decide the purpose and we act on your instructions, which makes you the controller and us your processor. It is why the Terms say the lawful basis for contacting somebody you exported is yours to hold.

If you need a data processing agreement with the standard contractual clauses attached, write to hey@trypengo.com and we will sign one.

Children

The Service is for business use and is not intended for anybody under 18, which is the age India's Digital Personal Data Protection Act treats as the boundary. We do not knowingly collect personal information from children. If you believe a child has given us personal information, write to us and we will delete it.

Other sites

Pengo links out to exhibitor directories, company websites, professional profiles and organiser pages, and shows the source of every fact it holds. Those sites are not ours, we do not control them, and their privacy policies are their own.

Your rights

Wherever you are, you can ask us to give you a copy of what we hold about you, correct it, delete it, or stop a particular use of it, by writing to hey@trypengo.com. We answer within one month, which is what the GDPR requires and what we apply to everybody. We may ask for information to confirm who you are before we act, and we will tell you our reasons if we cannot do what you asked. We do not charge for this and we do not treat you differently for asking.

If you are in the European Economic Area or the United Kingdom

Bhagyalakshmi S, a sole proprietor in India trading as Pengo is the controller of the personal information described in this policy. Under the GDPR you have the rights to access, correct, delete, port and restrict your personal information, to object to processing carried out on the basis of our legitimate interests, and to withdraw consent where we relied on it. Withdrawing consent does not affect processing carried out before you withdrew it. We have not appointed an Article 27 representative; the contact address above reaches the controller.

The legal bases we rely on are these:

Running the Service and taking payment: Performance of our contract with you.
Security, abuse prevention and error monitoring: Our legitimate interest in keeping the Service working and safe, weighed against the limited business-context data involved.
Product analytics and session recordings: Your consent, given on the banner and withdrawable in the account settings. Nothing runs before it is given.
Counting visits to the website without a cookie: Our legitimate interest in knowing whether the site is read, weighed against a measurement that stores nothing on your device, discards your address once a daily hash is derived from it, and cannot recognise you the next day. You can object at any time by writing to us.
Recording people named on public exhibitor listings and agendas: Our legitimate interest, and our customers', in knowing who represents which company at a professional event. You can object at any time and we will remove the listing.
Building a profile from a search aimed at a named person: The same legitimate interest, at a heavier processing that we assess as such. If you object we will remove it rather than defend the balance.
Meeting legal obligations and defending claims: Compliance with law, and our legitimate interest in establishing or defending legal claims.

If you are not satisfied with how we have handled your information you can complain to the data protection authority where you live or work. In the United Kingdom that is the Information Commissioner's Office. We would rather hear from you first.

If you are in India

Under the Digital Personal Data Protection Act, 2023 you may ask for a summary of the personal data we process about you and how we process it, ask for correction, completion, updating or erasure, nominate somebody to exercise your rights if you die or become incapacitated, and complain about how we handled a request. Write to hey@trypengo.com and mark it for the Grievance Officer, Bhagyalakshmi S; we answer grievances within the period the Act requires. If you are not satisfied you may take the complaint to the Data Protection Board of India.

If you are in the United States

Where a state privacy law applies to us, you may request the categories of personal information we collected about you and the categories of third parties we disclosed it to, request a copy, correct it, delete it, and appeal a decision we make on any of those requests. Two answers that state laws require us to give plainly: we do not sell your personal information and we do not share it for targeted advertising, and we do not use it for profiling that produces legal or similarly significant effects. You may use an authorised agent, and we may need to verify their authority.

Changes to this policy

We may modify this policy. If we make material changes we will update the effective date at the top and, where the change affects you materially, tell you in the product or by email before it takes effect. Using the Service after a modified policy takes effect means the modified policy applies to you.

How to contact us

Write to hey@trypengo.com for anything in this policy: a question, a data request, an objection, or a complaint. It is one inbox, watched by a person rather than a form, and a request sent to it does not need an account behind it. Ask and we will give you a postal address.