Privacy Policy

Version 1.0 — draft of 17 September 2026. Effective on the first public paid release.

8789916 Canada Inc. publishes PenguinSlide and is responsible for the personal information described here. Questions, requests and complaints: matthew.balazsi@medical-parachute.com

This policy covers the PenguinSlide desktop application and the licensing service it contacts. It explains three separate things, which are easy to confuse:

1. where your files are stored, 2. what is transmitted when you generate a document, and 3. what the companies receiving that transmission do with it.

1. The short version

- Your documents stay on your computer. We never receive them and cannot read them. - The free trial requires no email address, no payment card and no hardware identifier. - If you create an account, we hold your email address, your subscription status and the records needed to bill and support you. Nothing else. - We run no analytics, no telemetry and no crash reporting. - Your AI provider API key is stored by your operating system on your own computer. We never receive it. - When you generate a document, its content goes to the AI provider you chose. That provider's privacy policy governs what happens to it.

2. What stays on your computer

These are stored locally and are never transmitted to us:

| What | Where | |---|---| | Your documents, brands, presentations and proposals | Your workspace folder, by default `Documents/PenguinSlide` | | Application settings and update preferences | The application data folder (`desktop.json`) | | Your AI provider API key | Encrypted by macOS Keychain or Windows Credential Manager (`connection.enc`), saved only after you explicitly consent | | Your trial or licence state and its signed lease | The application data folder |

Deleting the application does not delete your documents. You control that folder.

3. What we collect

### 3.1 During the anonymous trial

When the application checks your trial status, our licensing service receives:

- a random identifier generated on your computer when the trial starts. It is not derived from your hardware, your name or your email address, and it identifies the trial, not you; - the request metadata that any internet service receives: your IP address, the time of the request, and the application version.

We use this to issue and verify a signed trial lease, to enforce the 14-day term, and to detect abuse. We do not use it to build a profile of you.

### 3.2 If you create an account

- Email address — to sign you in, to send the one-time verification code, to send renewal reminders and billing notices, and to answer support requests. - A customer identifier and session record — to keep you signed in and to authenticate your requests. - Subscription and device records — your plan, its status, renewal date, and the activations that count against your device limit.

### 3.3 If you buy a subscription

Payments are processed by Stripe. Your card number, expiry and security code go directly to Stripe and never reach us or the application. We store the identifiers and status Stripe returns — customer, subscription, payment state, amount, currency, country for tax — and keep the transaction records that tax and accounting law require.

### 3.4 If you contact support

We keep what you send us: your message, your email address, and anything you choose to attach.

4. What we do not collect

- Document content. No part of a document, brand kit, prompt or generated output ever reaches our servers. - Usage analytics or telemetry. The application reports no feature usage, no session data, no behavioural events. - Crash or diagnostic reports. None are sent automatically. If we ever add a support-bundle feature, it will show you the contents before anything is sent and will exclude document content and credentials. - API keys or credentials of any kind. - Hardware fingerprints. Device activation uses a random installation identifier, not a fingerprint of your machine.

5. When you generate a document

Generation sends your instructions and the relevant document material from your computer directly to the AI provider you connected — currently Anthropic or OpenAI, or a local Claude Code installation that itself contacts Anthropic. This traffic does not pass through us.

Before it sends, the application shows you the destination. What that provider does with the content — whether it retains it, how long, and whether it is used for training — is governed by your agreement with that provider, under the account whose key you supplied. Read their policies:

- Anthropic: https://www.anthropic.com/legal/privacy - OpenAI: https://openai.com/policies/privacy-policy

We cannot see, control or delete data once it is with them.

6. Others who process data for us

| Recipient | Purpose | Data | |---|---|---| | Stripe | Payments, subscriptions, invoices | Payment details, email, billing country | | [EMAIL PROVIDER] | Delivering sign-in codes and billing notices | Email address | | [HOSTING PROVIDER] | Running the licensing service | Account records, request logs | | GitHub | Distributing installers and updates | Your IP address, when the application checks for or downloads an update |

We do not sell personal information, we do not share it for cross-context behavioural advertising, and we do not disclose it for anyone else's marketing.

We may disclose information if the law requires it, to enforce our terms, or to protect the rights and safety of users or the public. Where we are permitted to, we will tell you first.

7. Cookies

The licensing service sets one session cookie when you sign in, and holds a CSRF token. Both are strictly necessary to keep you signed in and to protect your account. There are no advertising, analytics or tracking cookies.

8. Why we are allowed to hold this (GDPR/UK GDPR)

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

| Purpose | Lawful basis | |---|---| | Providing the application, the trial and your account | Performance of a contract | | Billing and renewals | Performance of a contract | | Preventing trial abuse and securing accounts | Legitimate interests | | Keeping tax and accounting records | Legal obligation | | Answering support requests | Performance of a contract; legitimate interests |

9. How long we keep it

- Trial records — until the trial expires, and up to 24 months afterwards for abuse prevention. - Account records — for as long as your account exists, and up to 24 months after you close it or your last subscription ends. - Billing and tax records — 7 years, as Canadian tax law requires. These cannot be deleted on request before then. - Service logs — 90 days. - Support correspondence — 24 months.

10. Where your data is processed

Our licensing service and our processors operate in [HOSTING REGION], and Stripe and GitHub operate internationally, including in the United States. Personal information may therefore be processed outside your country and may be accessible to courts and authorities there. For transfers out of the EEA or the UK we rely on the European Commission's Standard Contractual Clauses and the UK Addendum with our processors.

11. Your rights

Whatever country you are in, you can ask us to:

- tell you what personal information we hold about you and give you a copy, - correct it if it is wrong, - delete it (subject to the records we must keep by law), - give it to you in a portable, machine-readable format, - stop processing based on legitimate interests, or withdraw a consent you gave.

Write to matthew.balazsi@medical-parachute.com. We will respond within 30 days. We may need to verify that the request comes from the account holder. We do not charge for this and we will not treat you differently for asking.

Canada. We handle personal information under the *Personal Information Protection and Electronic Documents Act*. You may complain to the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca. *[If the corporation carries on an enterprise in Québec, Québec's Law 25 also applies: the person responsible for the protection of personal information is named above, and complaints may be made to the Commission d'accès à l'information at https://www.cai.gouv.qc.ca.]*

EEA/UK. You may complain to your national supervisory authority, or to the UK Information Commissioner's Office at https://ico.org.uk.

California. We do not sell or share personal information as those terms are defined in the CCPA/CPRA, and we have not in the preceding 12 months. You may exercise the rights above without discrimination.

12. Automated decisions

We make no decisions about you by automated means that produce legal or similarly significant effects. Licence checks verify a cryptographic signature and a date; they do not profile you.

13. Security

- Sign-in and licence traffic uses HTTPS. - Licences are signed with Ed25519 keys. The application contains only public verification keys; private signing keys never leave our service, and no part of the application can change which keys it trusts. - Your API key is encrypted by your operating system's credential store, is written only after your explicit consent, and is never written into documents, history files or logs. - Session credentials are held in the application's main process memory and in OS-protected storage, not in the editor interface.

No system is perfectly secure. If a breach affects your personal information and creates a real risk of significant harm, we will notify you and the relevant regulators as the law requires.

14. Children

PenguinSlide is a business tool and is not directed at children. We do not knowingly collect personal information from anyone under 16. If you believe a child has given us information, write to us and we will delete it.

15. Changes to this policy

We will post any change here and update the version and date. For a change that materially affects your rights we will give notice in the application or by email at least 30 days beforehand.

8789916 Canada Inc. matthew.balazsi@medical-parachute.com