Privacy Policy

Cpenio Inc. built the cPen app as an Ad Supported app. This SERVICE is provided by Cpenio Inc. at no cost and is intended for use as is.

This page is used to inform visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decided to use our Service.

If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which are accessible at cPen unless otherwise defined in this Privacy Policy.

Information Collection and Use

For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to advertising ID, IP address, location . The information that we request will be retained by us and used as described in this privacy policy.

Log Data

We want to inform you that whenever you use our Service, we collect data and information (directly and through third-party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics. We collect Log Data when an error occurs in the app and during normal use of the Service, including for security, fraud prevention, and abuse detection purposes.

Cookies

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.

This Service does not use these “cookies” explicitly. However, the app may use third-party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

Service Providers

We may employ third-party companies and individuals due to the following reasons:

• To facilitate our Service;
• To provide the Service on our behalf;
• To perform Service-related services; or
• To assist us in analyzing how our Service is used.

We want to inform users of this Service that these third parties have access to their Personal Information. Service providers that process information solely on our behalf, such as our hosting, storage, email, and content moderation providers, are contractually restricted to performing the tasks we assign to them and may not use the information for their own purposes.

This restriction does not apply to our advertising partners. As described in “Advertising and Ad Partners” below, ad partners and the advertisers bidding through them receive information about your device and use it for their own purposes under their own privacy policies.

Advertising and Ad Partners

cPen is an ad-supported app. To show you an ad, our app and our ad mediation partners send a request for each ad opportunity to advertising exchanges, where advertisers bid in real time for the chance to serve that ad. The information included in these ad requests may consist of:

• Your advertising identifier (Google Advertising ID or IDFA)
• Your device Internet Protocol (“IP”) address, which may be shared in full rather than truncated
• Approximate location derived from your IP address, and precise location only where you have granted the app location permission
• Device and app information (device model, operating system version, app version, language, and connection type)
• Ad interaction data (ads requested, shown, viewed, clicked, and completed)

Ad partners and the advertisers bidding through them use this information for their own purposes, including ad targeting and personalization, frequency capping, invalid traffic and fraud detection, and measurement and reporting. They act as independent controllers of that information and are governed by their own privacy policies rather than by this one. Depending on the exchange, an ad request may also be passed on to downstream demand partners and resellers that we do not individually control. The sellers and resellers we authorize are listed publicly in our app-ads.txt file.

You can limit ad tracking or reset your advertising identifier at any time in your device settings. Where applicable law requires your consent for personalized advertising, we present a consent request in the app, and your response is recorded on your device and made available to our advertising partners. Declining personalized advertising does not remove ads from the Service, but the ads you see will be less relevant.

Because ad requests are transmitted to and processed by third parties in real time, we cannot retrieve or delete information that ad partners have already received. Requests to access or delete that information must be directed to those partners under their own privacy policies.

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children’s Privacy

EU and EEA Users

Our services are primarily directed to users outside the European Economic Area (EEA). While our app supports multiple languages including some European languages, this is to serve our global user base and does not constitute targeting of EU residents. We do not specifically market to or tailor services for individuals in the EU.

Some EU users may access our app incidentally. In such cases, we process personal data only as necessary to provide the service as described in this privacy policy. We have not appointed an EU Representative under Article 27 GDPR as our processing activities are not directed at the EU market and are occasional in nature.

Please note that cryptocurrency mining and related services may be subject to additional regulations in your jurisdiction.

California and Other U.S. State Privacy Rights

If you are a resident of California or of another U.S. state with a comprehensive consumer privacy law, this section describes additional rights you may have.

In the twelve months preceding the effective date of this policy, we have collected the following categories of personal information: identifiers (such as your email address, account identifier, advertising identifier, and IP address); commercial information (such as your transaction, burn, and reward history); internet or other network activity (such as your interactions with the app and with ads); approximate location inferred from your IP address; and, where you submit it for identity verification, biometric information. The sources, purposes, and recipients for each are described elsewhere in this policy.

We do not sell your personal information for money. However, as described in “Advertising and Ad Partners” above, we disclose identifiers, network activity, and IP-derived approximate location to advertising partners that use it for their own advertising purposes. Under California law this is treated as “sharing” for cross-context behavioral advertising, and under some U.S. state laws it may also be treated as a “sale.” We do not knowingly share the personal information of consumers we know to be under 16 years of age for these purposes.

Subject to verification and to the exceptions in applicable law, you have the right to know what personal information we have collected about you and how it is used and disclosed; to request correction or deletion of your personal information; to opt out of the sharing described above; to limit the use of sensitive personal information; and not to receive discriminatory treatment for exercising any of these rights.

To exercise these rights, you can delete your account from within the app, or contact us at [email protected] and state which right you wish to exercise. We will verify your request against the account details we hold before acting on it. You may also limit ad tracking or reset your advertising identifier at any time in your device settings, which reduces the information available to our advertising partners. An authorized agent may submit a request on your behalf with proof of authorization.

Burnchase Program Data

When you participate in the Burnchase Program, we collect and store:

• Token burn transaction records (token type, amount, timestamp, blockchain transaction hash)
• Wallet addresses used for burn transactions
• Dan credit balance and transaction history
• Price quotes and conversion rate history

Data retention periods for Burnchase:

• Completed burn transactions: Retained indefinitely for financial audit purposes
• Failed or cancelled transactions: 90 days
• Price quotes: 30 days after expiration

Wall (Community Board) Data

When you use the Wall feature, we collect and store:

• Post content including text, images, and any location data you provide
• Post duration, pricing, and payment records
• View counts and engagement metrics
• Moderation scores and review history
• User reports and moderation outcomes

Wall posts are public and visible to all platform users. Data retention periods for Wall:

• Active posts: Retained while active
• Expired posts: 90 days after expiration
• Deleted posts: 90 days after deletion
• Post view records: 30 days
• Resolved user reports: 180 days after resolution

Community Ambassador Program Data

When you participate in the Community Ambassador Program, we collect and store:

• Referral relationships between users
• Referral reward amounts and transaction history
• Ambassador status, badge level, and application history
• Performance metrics (referral counts, earnings)

This data is retained indefinitely for program administration and audit purposes.

Chasepot Program Data

When you participate in Chasepot, we collect and store:

• Entry data: selected numbers, wallet addresses, entry timestamps, on-chain sync status
• Draw results: winning numbers, match counts, prize tier assignments
• Prize and payout data: prize amounts, payout wallet addresses, blockchain transaction hashes, payout status
• Ambassador bonus data: bonus amounts, ambassador-referral relationships, bonus payout transaction hashes
• Date of birth (for age verification, immutable after initial submission)

Chasepot entry and prize data is retained indefinitely for audit, blockchain verification, and regulatory compliance purposes. On-chain records (entries, draws, payouts) are permanently stored on the blockchain and cannot be deleted.

AI-Powered Content Analysis

We use artificial intelligence and automated systems to analyze content on the platform:

• Wall posts are analyzed by Azure Content Moderator for text content
• Images are analyzed by AWS Rekognition for content safety
• Automated decisions may be made regarding content visibility and moderation

These systems help us maintain platform safety but may result in automated content removal without human review in some cases.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page.

This policy is effective as of 2026-08-24

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at [email protected].

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