PRIVACY POLICY — Penni App Effective Date: May 11, 2026

Easily Group LLC ("we", "us", or "our") operates the Penni mobile application ("Penni" or the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this policy carefully. If you disagree with its terms, please discontinue use of the App.

Penni is a GLP-1 companion application designed to help users manage nausea and side effects associated with GLP-1 medications including Ozempic, Wegovy, Mounjaro, Zepbound, Rybelsus, Saxenda, and Victoza. Penni is not a medical device and does not provide medical advice.

1. INFORMATION WE COLLECT

a) Information You Provide

Account information: name, email address, and password when you register

Health information: GLP-1 medication type, dosage schedule, injection day, and dose escalation stage

Meal photos: images of food you scan using the App

Symptom logs: nausea scores, side effect reports, and personal trigger notes

b) Information Collected Automatically

Device information: device type, operating system, and unique device identifiers

Usage data: features used, scan frequency, session duration, and in-app behaviour

Log data: IP address, browser type, pages visited, and crash reports

2. HOW WE USE YOUR INFORMATION

We use the information we collect to:

Provide, operate, and maintain the Penni App and its nausea risk scoring features

Personalise your nausea risk scores based on your medication cycle and individual trigger history

Analyse meal photos to assess nausea risk factors including fat content, portion size, and spice level

Send you notifications, reminders, and weekly insight reports

Improve and develop new features of the App

Respond to your support requests and communications

Comply with legal obligations

3. HEALTH INFORMATION AND SENSITIVE DATA

Penni collects health-related information including GLP-1 medication details, nausea symptoms, and meal data. We treat this information as sensitive and apply additional protections:

We do not sell your health information to third parties

Meal photos are processed to generate nausea risk scores and are not shared with third parties for advertising purposes

We do not use your health data to make decisions that affect your insurance, employment, or access to credit

Penni is not a HIPAA-covered entity; however, we apply reasonable security standards to your health data

4. SHARING YOUR INFORMATION

We do not sell your personal information. We may share your information only in the following circumstances:

Service providers: trusted third parties who assist us in operating the App (e.g. cloud hosting, AI image analysis, analytics), bound by confidentiality obligations

Legal requirements: when required by law, subpoena, court order, or to protect the rights and safety of our users or the public

Business transfers: in the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred as part of that transaction

With your consent: we may share information with third parties when you have given us explicit consent to do so

5. DATA RETENTION

We retain your personal information for as long as your account is active or as needed to provide you with the App. You may delete your account at any time by contacting us at [email protected]. Upon account deletion, we will delete or anonymise your personal data within 30 days, except where retention is required by law.

6. DATA SECURITY

We implement industry-standard security measures to protect your information, including encryption in transit and at rest, access controls, and regular security reviews. However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

7. YOUR RIGHTS

Depending on your location, you may have the following rights regarding your personal data:

Access: request a copy of the personal data we hold about you

Correction: request correction of inaccurate or incomplete data

Deletion: request deletion of your personal data

Portability: request a copy of your data in a structured, machine-readable format

Objection: object to our processing of your data for certain purposes

Withdrawal of consent: withdraw consent at any time where processing is based on consent

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

8. CHILDREN'S PRIVACY

Penni is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal data, we will take steps to delete such information. If you believe a child has provided us with their information, please contact us at [email protected].

9. THIRD-PARTY SERVICES

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party services you access through the App.

10. INTERNATIONAL DATA TRANSFERS

Easily Group LLC is incorporated in Wyoming, United States. If you are accessing Penni from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries. By using the App, you consent to the transfer of your information to countries that may have different data protection laws than your country of residence.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy within the App and updating the effective date at the top of this page. Your continued use of the App after such changes constitutes your acceptance of the updated policy.

12. MEDICAL DISCLAIMER

Penni is a wellness tool and is not a medical device. The nausea risk scores and information provided by Penni are for general informational purposes only and do not constitute medical advice, diagnosis, or treatment. Always consult your healthcare provider or prescribing physician regarding your GLP-1 medication, side effects, and dietary choices.

13. CONTACT US

If you have any questions about this Privacy Policy or our data practices, please contact us:

Easily Group LLC Email: [email protected] Registered in Wyoming, United States