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Data Processing Addendum

When Penny handles your customers' data, we act as your processor. This addendum explains that relationship and the safeguards behind it.

Last updated June 13, 2026

Scope and roles

This Data Processing Addendum supplements our Terms of Service and applies when Penny Labs, Inc. processes personal data on your behalf. You (the customer) are the controller; Penny is the processor. It covers personal data in calls, transcripts, captured details, and account information processed to provide the service.

Our commitments as processor

  • We process personal data only on your documented instructions — which include your settings and our agreement.
  • People who handle the data are bound by confidentiality.
  • We keep appropriate technical and organizational security measures (see our Security page).
  • We help you respond to data-subject requests and meet your own obligations where the law requires.
  • On termination, we delete or return personal data, except where we're required to retain it.

Sub-processors

We use a small set of vetted providers to deliver the service, each under contract to protect personal data:
  • Twilio — telephony: connecting and carrying your calls.
  • Amazon Web Services — cloud hosting, storage, compute, and transactional email.
  • Google — speech and language model processing, and calendar integration when you connect it.
  • Stripe — payment processing and billing.
We'll give reasonable notice before adding or replacing a sub-processor so you have a chance to object.

International transfers

Where personal data is transferred across borders, we rely on appropriate safeguards such as the Standard Contractual Clauses. Our providers above operate under their own transfer mechanisms as well.

Security and breach notification

We maintain the safeguards described on our Security page and will notify you without undue delay after becoming aware of a personal-data breach affecting your data, with the information you need to meet your own notification duties.

Audits and assistance

On reasonable request, we'll provide the information needed to demonstrate compliance with this addendum and assist with your data-protection obligations, including impact assessments where applicable.

How to request a signed copy

Need a countersigned DPA for your records, or have questions about our processing? Email support@pennyassistant.com and we'll take care of it.

Data Processing Addendum for Penny, operated by Penny Labs, Inc.. This page is provided for transparency and isn’t legal advice.

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