Privacy
Policy.

This Privacy Policy ("Policy") explains what types of information we collect and how Peng Data strives to collect, use, and disclose information in a manner consistent with the laws of the countries in which we operate. This Policy applies to our data platform ("Platform") and related gaming services ("Services"), as well as our website at https://www.mypgsolutions.com ("Website").

Privacy Protection Measures

Personally Identifiable Information

Peng Data collects personally identifiable information from its website when you choose to provide it to us. PII refers to any information that can be used to identify or locate a specific individual or entity. This includes, but is not limited to: name, mailing address, phone number, or email address. For example, you may choose to send us your PII via email or by filling out a form on our website. Peng Data uses this information solely to contact you in response to your inquiries.

Updating and Deleting Your Information

As required by applicable law, Peng Data will, upon your request, provide you with information about whether we hold any of your data. If you wish to update, correct, delete, transfer, or deactivate any data you have provided to us through the Website or other business operations, please send your request to [email protected], and Peng Data will process your request. We will respond to your access request within a reasonable time frame—for data subjects located in the European Economic Area (EEA), this period is 30 days, and Peng Data will honor such requests with respect to personal data.

If your personal information has been processed through our gaming features on behalf of our customers, please direct your access, correction, deletion, or objection requests directly to the relevant customer, who is your data controller. We will assist our customers in fulfilling such requests as described in our Data Processing Addendum.

California Data Subjects

The California Consumer Privacy Act ("CCPA") provides additional privacy protections to California data subjects and users, including: (a) the right to review data we hold about you, your computer, or your device (i.e., the right to know); (b) the right to delete data we hold about you, your computer, or your device (i.e., the right to deletion); and (c) the right to opt out of the sale of data about you, your computer, or your device to certain third parties (i.e., the right to opt out of the sale of your information). We will not discriminate against you if you exercise any of the above rights. Additionally, we may be unable to fulfill such rights if doing so would violate applicable law.

Regarding personal information processed through our gaming features: We do not sell or share personal information processed through our gaming Services. We do not use personal information received from one customer to train gaming models that serve other customers. Our gaming features process personal information solely to provide Services to the specific customer on whose behalf it was collected, consistent with our role as a service provider under the CCPA.

If you wish to review or delete any data we may have collected through our Website or internal business operations, you may exercise your relevant rights with Peng Data by sending an email to [email protected].

As a California data subject, if you make a request to access your personal information under this Policy, you have the right to review and request deletion of the personal information we hold about you. We will confirm your request within 10 days and will make reasonable efforts to fulfill your request within 45 days.

Individuals in the EEA, Switzerland, and the UK

Under the General Data Protection Regulation ("GDPR"), individuals located in the European Economic Area ("EEA") have additional privacy rights. For example, individuals in the EEA, UK, or Switzerland who wish to access, correct, modify, transfer, and/or delete inaccurate data, or who wish to restrict the use and disclosure of their personal information, should send us an email.

If you are a customer or partner and have questions about reviewing data used to log into our systems, please contact your company's business relationship lead directly. If you are a consumer and wish to review data we hold on behalf of a customer, please contact that customer directly. Peng Data is contractually prohibited from processing such requests without the express written instruction of the relevant customer.

If you wish to review or delete any data we may have collected through our Website or internal business operations, you may send an email to [email protected] to exercise your relevant rights with Peng Data and its affiliates.

Peng Data operates our various platforms and provides Services as a "data processor" under the GDPR framework. This means Peng Data processes data through the Platform and Services only in accordance with customer instructions and does not use it for any other purpose. We also process certain personal data provided by customers and partners as contractually required.

Regarding personal data processed through our gaming features: Peng Data operates the gaming Services as a "data processor" under the GDPR. We process personal data related to gaming solely in accordance with the instructions of our customers (the data controllers) and do not use it for any other purposes. We do not use personal data processed through the gaming Services for one customer to train gaming models that serve other customers. Where our gaming features involve automated decision-making as defined in Article 22 of the GDPR, our customers (as data controllers) are responsible for ensuring legality, providing appropriate safeguards, and informing data subjects. We provide our customers with information regarding our gaming processing to support their transparency obligations. Subprocessors used for the gaming Services (including large language model providers) are disclosed on our subprocessors page and are contractually prohibited from using customer personal data for their own purposes.

Before sharing your data with third parties other than our agents, or using it for purposes other than those for which it was originally collected or subsequently authorized, we will provide a separate opt-out option or, for sensitive data, an opt-in option. To restrict the use and disclosure of your personal information, please send a written request to [email protected].

Data Retention

The data we store on the Platform and use to provide Services is non-sensitive personal data and is not subject to industry-specific data retention requirements. We retain data on the Platform in accordance with customer instructions and strongly recommend that customers retain data only for as long as reasonably necessary.

Message-related data is retained only for as long as necessary to provide the Services, fulfill legal obligations, resolve disputes, and enforce agreements. Message content (including multimedia files) is generally retained only for transmission and delivery purposes, unless a longer retention period is required for troubleshooting, compliance, or at the customer's written request.

Gaming-related data retention will follow customer instructions and our standard retention policies. Gaming agent configurations, workflow intelligence, and customer-specific model tuning data will be retained for the duration of the customer's subscription. Upon termination of the subscription, customers may request export of their gaming configurations in a machine-readable format, and we will delete customer-specific gaming data from active systems within ninety (90) days after receiving a written request. Data processed by gaming subprocessors is retained only for the time necessary to process each individual request.

Changes to This Privacy Policy

This Policy may be revised from time to time. When we do, we will update the "Last Updated" date at the top. We encourage you to review this Privacy Policy periodically to stay informed about how we protect the information we collect.

Privacy Questions and Complaints

Our Ambassador is committed to resolving any complaints you may have regarding privacy and our collection or use of your personal information. If you have any questions or complaints about this Privacy Policy, please send an email to [email protected] with "Privacy Office" in the subject line.

You may contact our Data Protection Officer at [email protected].