Penholder ← Back to site
Draft. This policy is a working template pending review by legal counsel before launch — not final terms.

Privacy Policy

Last updated: 27 July 2026 · Draft

Penholder is a governance layer between your AI agents and your data. We hold as little of your data as possible, we never sell it, and we never use it to train models.

1. Who we are

Penholder ("Penholder", "we", "us") operates a hosted service that gates AI-agent writes to spreadsheets and databases behind human approval. This policy explains what we collect when you visit this site or request access, and how we handle the data you connect to the service. For privacy questions, contact privacy@penholder.ai.

2. Information we collect

3. How we use it

We rely on your consent (for access requests) and our legitimate interest in running and securing the service. We do not sell personal data, and we do not use your connected data to train machine-learning models.

4. Your connected data

When you connect a spreadsheet or database, that content is processed under your control:

5. Sharing & subprocessors

We share personal data only with service providers that help us operate (for example, cloud hosting and email), under contract and only as needed. We do not sell your data. We may disclose data if required by law. A current list of subprocessors is available on request.

6. Data retention

We keep access-request data for as long as needed to evaluate and follow up, and site logs for a limited period. Connected data is retained only while your account is active and deleted on request or termination.

7. Your rights

Depending on where you live (including under GDPR and CCPA), you may have the right to access, correct, delete, or port your personal data, and to object to or restrict certain processing. To exercise any right, email privacy@penholder.ai. You can also opt out of our emails at any time.

8. Security

We use encryption in transit and at rest, account isolation, least-privilege access, and a tamper-evident audit log. See the Security section of our site for the product-level posture. No system is perfectly secure, but we design so that agents never hold your keys and no protected write publishes without approval.

9. Cookies

We use only essential and basic analytics cookies. We do not use advertising cookies. You can control cookies through your browser settings.

10. International transfers

We may process data in countries other than yours. Where required, we use appropriate safeguards (such as standard contractual clauses) for cross-border transfers.

11. Changes

We may update this policy as the product evolves. Material changes will be posted here with a new "last updated" date.

12. Contact

Questions or requests: privacy@penholder.ai.