Privacy Policy

# Penfolio Studio — Privacy Policy **Effective Date:** October 12, 2026 **Last Updated:** October 12, 2026 **Version:** 1.0 ## 1. Introduction Penfolio Studio ("Penfolio," "we," "us," or "our") respects the privacy of visitors and customers. This Privacy Policy describes how information is collected, used, stored, disclosed, and protected when you visit https://penfoliostudio.com or use our publishing management application. Penfolio Studio is operated by **Rhiannon Barney**, an individual sole proprietor located in Washington State, United States. **Privacy Contact:** azebagaming@gmail.com ## 2. Information We Collect Depending on how you interact with Penfolio, we may collect the following information. ### Account Information - Email addresses. - Names and display names. - Authentication identifiers. - Account preferences. - Email verification status. - Records of consent and Terms acceptance. - Security and login events. ### Publishing Information Customers may provide: - Author and pen-name profiles. - Book and series information. - Publication schedules. - Production tasks. - Manuscripts and uploaded documents. - Book covers and related files. - Character profiles. - Worldbuilding information. - Plot threads and continuity records. - Marketing and publishing plans. - Royalty and sales reports. - Kindle Unlimited reading data. - Financial records and analytics. This information may include unpublished or commercially sensitive material. ### Subscription and Payment Information We may collect: - Selected subscription plan. - Self-declared monthly publishing income bracket. - Subscription status. - Billing dates. - Stripe customer and subscription identifiers. - Payment and invoice references. - Cancellation records. - Refund requests and outcomes. Payments are processed through Stripe. Penfolio does not intentionally store complete payment card numbers or card security codes. ### Communications and Support When you contact us, we may collect your name, email address, inquiry type, message, case reference, correspondence history, and information necessary to respond. ### Technical Information Our systems and service providers may collect or process: - IP addresses. - Device and browser information. - Session identifiers. - Login events. - Request timestamps. - Error and performance logs. - Security and fraud-prevention information. - Bot-detection signals. Cloudflare Turnstile may process technical information to detect automated abuse. ## 3. Purposes of Processing Penfolio processes information to: - Register and authenticate customers. - Provide publishing-management features. - Store and organize customer records. - Process imported publishing reports. - Generate requested analytics and exports. - Manage subscriptions and payments. - Process cancellation and refund requests. - Respond to support inquiries. - Protect against fraud, spam, and unauthorized access. - Maintain and improve service reliability. - Provide necessary account and security communications. - Meet applicable legal obligations. ## 4. Subscription Eligibility and Publishing Income Penfolio offers income-based subscription plans. Customers are asked to self-declare their qualifying monthly publishing income bracket. This information is used to determine the selected subscription tier under the applicable pricing policy. Customers do not need to upload KDP reports solely to register. Publishing reports uploaded for analytics are processed to provide requested features. We do not intentionally send complete royalty statements, manuscript contents, or publishing financial reports to Stripe to determine subscription eligibility. Stripe receives the information necessary to manage payment transactions and subscriptions. ## 5. Manuscripts and Customer Content Customers retain ownership of their original manuscripts and other publishing materials, subject to any applicable third-party rights. Uploading content to Penfolio does not transfer copyright ownership. We process customer content only as reasonably necessary to provide authorized Service functionality, including storage, organization, display, processing, and requested exports. Penfolio does not independently publish or sell customer manuscripts. ## 6. Artificial Intelligence and Customer Data Penfolio's core hosted publishing-management product does not provide automated manuscript drafting, rewriting, or editorial AI services. We do not intentionally submit customer manuscripts or unpublished story materials to generative AI systems for model training as part of ordinary publishing management. Third-party infrastructure providers may have their own contractual data-processing terms. We do not make absolute guarantees regarding third-party AI-training practices without verifying the applicable provider agreements and configuration. If optional AI integrations are introduced in the future, relevant data-sharing practices will be disclosed. ## 7. Service Providers Penfolio uses third-party services to support its operations. These may include: **Base44:** Application infrastructure, hosting, authentication, databases, file storage, and related platform services. **Stripe:** Payment processing, recurring subscriptions, billing, invoices, cancellations, refunds, and payment-related fraud prevention. **Cloudflare Turnstile:** Protection against automated submissions and other abuse. **Email and Authentication Providers:** Account verification, password recovery, service notifications, and support communication. Information is shared with service providers as reasonably necessary to provide these functions. Their processing may also be governed by applicable contractual obligations and privacy policies. ## 8. Information Sharing We may disclose personal information: - To providers that operate or support the Service. - When a customer authorizes an export or integration. - To comply with lawful requests or legal obligations. - To investigate fraud, abuse, or security incidents. - To protect rights, safety, and service integrity. - In connection with a lawful business transaction, subject to applicable requirements. We do not sell customer manuscripts or publishing records to advertisers. Customer workspaces are not intentionally made public or accessible to unrelated customers. ## 9. Account Isolation and Security Penfolio uses access controls intended to restrict users to their authorized information. We aim to apply reasonable security measures appropriate to the nature of stored records. These may include authentication, authorization, secure connections, access restrictions, logging, and automated abuse protection. No internet-based system can guarantee complete security. Customers should use secure passwords and maintain independent backups of important files. If a security incident occurs that requires notification under applicable law, we will provide the required notice. ## 10. Cookies and Similar Technologies Penfolio and its providers may use cookies, session identifiers, or similar technologies for: - Authentication. - Account sessions. - Security. - Fraud prevention. - Remembering application preferences. - Service functionality and performance. Additional analytics or marketing technologies, if introduced, may be subject to further disclosure and consent requirements. Browser settings may permit some cookie controls, although disabling necessary technologies may affect functionality. The exact technologies used by the published Service should be reviewed periodically. ## 11. Marketing and Service Emails Penfolio may send necessary communications related to: - Account verification. - Password recovery. - Security. - Billing. - Subscription changes. - Cancellations. - Refunds. - Important service notices. Optional marketing communications are separate from necessary service messages. Where required, marketing emails will be sent only with appropriate consent. Customers may unsubscribe from optional marketing messages through the available controls. ## 12. International Processing Penfolio is operated from Washington State, United States. Our service providers may process or store information in other locations, depending on their infrastructure. Where required, applicable legal safeguards will be used for international data transfers. Specific hosting locations and transfer arrangements are subject to the actual services and provider terms in effect. ## 13. Data Retention We retain information for as long as reasonably necessary to provide services, maintain accounts, process payments and refunds, protect security, comply with legal requirements, and resolve disputes. Different types of information may have different retention periods. Our current application configuration specifies **30 days for post-deletion data retention**, but this does not mean all third-party backups, legally required financial records, or provider-controlled information are necessarily deleted within exactly 30 days. Information removed from active systems may remain temporarily in backup or retention systems where necessary or permitted. We will follow applicable deletion requirements and disclose relevant limitations. ## 14. Customer Privacy Rights Depending on applicable law, customers may have rights to: - Access personal information. - Correct inaccurate information. - Request deletion. - Obtain available information in portable form. - Withdraw applicable consent. - Object to or restrict certain processing. - Appeal certain decisions where required by law. To submit a privacy request, contact: **azebagaming@gmail.com** We may request reasonable identity verification before providing access to sensitive information or processing deletion. We will respond according to applicable legal requirements. Certain information may be retained where necessary for legal, tax, security, billing, or dispute-resolution purposes. ## 15. Data Exports and Backups Penfolio provides certain data export and backup capabilities. Metadata exports may include book, series, pen-name, financial, and other structured workspace records. These exports may not contain the actual bytes of uploaded manuscript files, covers, or documents. Customers are encouraged to maintain independent copies of important publishing materials. Metadata-only backups should not be treated as guaranteed complete recovery packages. ## 16. Account Deletion Customers may request account closure or deletion through supported account tools or contact channels. Subscription cancellation does not itself delete an account. Before requesting deletion, customers should obtain available exports they wish to retain. Eligible records will be processed according to applicable law, technical capabilities, and retention requirements. Some records may remain in backups or be retained for legitimate legal obligations. ## 17. Billing and Refund Records When a subscription is canceled or a refund is requested, we may retain relevant transaction references, invoice identifiers, cancellation dates, refund amounts, case records, and communications. These records help us process refunds, prevent duplicate transactions, investigate billing errors, and meet legal obligations. Stripe may retain payment information according to its own legal and regulatory requirements. ## 18. Optional Integrations and MCP Penfolio may offer optional connections to third-party applications or authorized tools, including Model Context Protocol (MCP) integrations. Information available through an authorized integration depends on the permissions granted and the capabilities of that integration. Customers should review requested permissions before granting access. Revoking an authorization is intended to stop further authorized access through that connection, subject to actual integration capabilities. Data already exported to another provider may remain subject to that provider's terms and privacy practices. ## 19. Children's Privacy Penfolio is intended for adults managing publishing activities. Accounts are not intended for individuals under 18. We do not knowingly solicit registrations from children. If you believe a minor has provided personal information contrary to our eligibility requirements, please contact us. ## 20. Changes to This Policy We may update this Privacy Policy to reflect changes in functionality, service providers, legal obligations, or business operations. We will update the revision date and provide additional notice when required. Where renewed consent is required, we will request it before applying the relevant processing activity. ## 21. Contact Information **Penfolio Studio** **Operator:** Rhiannon Barney **Business Structure:** Individual Sole Proprietorship **Mailing Address:** 419 Plum Street, Bremerton, WA 98310, United States **Email:** azebagaming@gmail.com **Website:** https://penfoliostudio.com **Jurisdiction:** Washington State, United States For privacy requests, account concerns, or questions about this policy, please contact us through the website or at the email address above.