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Privacy Policy

Your privacy is important to us

Last updated: December 31, 2025

This Privacy Notice for NaBo Systems ("we", "us" or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • Download and use our mobile application (PenPro), or any other application of ours that links to this Privacy Notice
  • Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. Contact us at support@penproapp.com

Summary of Key Points

What personal information do we process?

We may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we collect any information from third parties?

We do not collect any information from third parties.

How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

Table of Contents
1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You

  • Names
  • Email addresses
  • Usernames
  • Passwords
  • Job status / student status
  • Jersey number

Payment Data

We process transaction data required for subscriptions and payments. In-app purchases and mobile subscriptions are processed securely via Apple App Store, Google Play Store, Adapty, and Stripe. We do not store complete credit card or banking details on our servers.

Application Data

Geolocation Information

We may request access to track location-based information from your mobile device.

Mobile Device Access

We may request access to camera, storage, notifications, and other features.

Mobile Device Data

Device information, OS, version, IP address, browser type, and more.

Push Notifications

We may request to send you push notifications regarding your account.

Information automatically collected

In Short: Some information is collected automatically when you visit our Services.

  • Log and Usage Data: Service-related, diagnostic, usage, and performance information including IP address, device info, browser type, and activity data.
  • Device Data: Information about your device including IP address, location, browser type, hardware model, and operating system.
  • Location Data: Information about your device's location, which can be either precise or imprecise.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

  • Account Management: To facilitate account creation and authentication
  • Service Delivery: To deliver and facilitate delivery of services to the user
  • Administrative Information: To send you details about our products, services, and policy changes
  • Request Feedback: To request feedback and contact you about your use of our Services
  • Marketing Communications: To send you marketing and promotional communications (with your consent)
  • Targeted Advertising: To develop and display personalized content and advertising
  • Service Protection: To keep our Services safe and secure, including fraud monitoring
  • Usage Trends: To better understand how our Services are being used
  • Marketing Effectiveness: To understand how to provide relevant marketing campaigns
  • Vital Interests: To save or protect an individual's vital interest
3. What Legal Bases Do We Rely On?

In Short: We only process your personal information when we have a valid legal reason to do so.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information.

Consent

We may process your information if you have given us permission for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract

We may process your information to fulfill our contractual obligations to you, including providing our Services.

Legitimate Interests

We may process your information when reasonably necessary to achieve our legitimate business interests.

Legal Obligations

We may process your information for compliance with our legal obligations.

Vital Interests

We may process your information to protect your vital interests or those of a third party.

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations and with specific categories of third parties.

Categories of third parties:

Data Analytics Services (Google Analytics / Firebase)
Cloud Database & Auth (Supabase - Frankfurt, Germany / EU-Central-1)
Web Server Hosting (Hostinger VPS - Frankfurt, Germany / EU)
Payment Processors
Performance Monitoring
Authentication Services

Business Transfers

We may share or transfer your information in connection with any merger, sale of company assets, financing, or acquisition.

Offer Wall

Our application(s) may display a third-party hosted "offer wall" where third-party advertisers offer virtual currency, gifts, or other items.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out, visit Google Analytics Opt-out

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services.

If you become aware of any data we may have collected from children under age 18, please contact us at support@penproapp.com

8. What Are Your Privacy Rights?

In Short: In some regions, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws:

Request access and obtain a copy of your personal information
Request rectification or erasure
Restrict the processing of your personal information
Data portability (if applicable)
Object to processing of your personal information
Not be subject to automated decision-making

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us.

Account Information

If you would like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account, or contact us using the contact information provided.

9. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

10. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

11. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at:

12. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please fill out and submit a data subject access request.