Privacy Policy

This Privacy Policy explains how [Pernee legal entity name](“Pernee”, “we”, “us”, or “our”) collects, uses, shares, and protects personal information when you visit pernee.com, create an account, or use the Pernee application and related services (together, the “Services”). Pernee is a review-and-memory layer for professional-services firms (such as CPA and tax firms) that works alongside their existing tax-preparation tools.

We act as a data controllerfor the account and marketing data described below. Where your firm uses Pernee to process information about its own clients and engagements — which may include financial and tax information — we act as a data processoron the firm’s behalf, and the firm’s agreement with us (including any Data Processing Addendum) governs that processing.

1. Who we are & how to contact us

Pernee is operated by [legal entity name and registered address]. For any privacy question, or to exercise the rights described in this policy, contact us at privacy@pernee.com.

If you are in the European Economic Area (EEA) or the United Kingdom, our data protection contact is [DPO / EU-UK representative, if appointed].

2. Information we collect

We collect the following categories of personal information:

• Account & profile information — your full name, work email address, the name and size of your firm or organization, and your role within it. We require a work/organizational email to register.
• Authentication data — your password, which is stored only in salted, hashed form by our authentication provider (we never store or see the plaintext); one-time verification codes; and session tokens held in cookies.
• Technical & security logs — your IP address, browser and device information, request timestamps, and rate-limiting signals used to protect the Services from abuse.
• Audit records — a log of consequential actions taken in your account (for example sign-ins, sign-outs, role changes, and administrative changes) retained for security and compliance purposes.
• Diagnostics & error reports — when something goes wrong, technical error data (which may include your user identifier and email address) is sent to our error-monitoring provider to help us diagnose and fix issues.
• Content you provide — information, documents, and other content you or your organization choose to enter into the Services.

We do not intentionally collect special categories of data (such as health or biometric data) for our own purposes, and we ask that you do not submit such data except where the Services are expressly designed for it.

3. How we use your information

We use personal information to:

• provide, operate, secure, and maintain the Services;
• authenticate you, create and manage your workspace, and administer roles and permissions;
• protect against fraud, abuse, and unauthorized access (including rate limiting and audit logging);
• diagnose problems, monitor reliability, and improve the Services — but never by training AI models on your data, which we do not do (see section 4);
• communicate with you about your account, security, and service-related matters; and
• comply with our legal and regulatory obligations.

Legal bases (EEA/UK). Where the GDPR or UK GDPR applies, we rely on: performance of a contract (to provide the Services you request); our legitimate interests (to secure, maintain, and improve the Services), balanced against your rights; compliance with a legal obligation; and your consent where we specifically ask for it. You may withdraw consent at any time.

4. AI models & how your data is used

Pernee is an AI product used by tax and accounting professionals, so the material you put in front of it is your clients’ data. How AI models treat that data is not a setting you have to find and switch on — there is no privacy mode, no opt-in, and no plan tier that changes it. The terms below are the only way Pernee runs, for every customer, on every request.

• We do not train on your data.Neither Pernee nor the model providers we route to train, fine-tune, or otherwise improve any model on your prompts, your documents, your clients’ information, or the output produced for you.
• Zero data retention is the only option. Every request Pernee sends to a model carries two mandatory requirements: zero data retention and no prompt training. Our AI gateway routes only to providers that hold agreements covering both. If no such provider is available for a request, that request fails— it is never quietly downgraded to a provider that would retain your data.
• Enforced once, not per feature. Every model call in Pernee is built by a single server-side module that applies those requirements, and no feature is permitted to open its own connection to a model provider. Any new feature we ship inherits the guarantee automatically rather than having to remember it.
• Which providers. We currently use models from Anthropic (Claude), Google (Gemini), and OpenAI, reached through our AI gateway rather than directly. We may add or change providers as models improve, but only ones that can serve requests under the same zero-retention, no-training terms. Note that, subject to their own usage policies, providers may run automated safety or abuse classifiers on requests; where such a check flags a request, that provider may retain the data to investigate and delete it in line with its published retention policy.
• Your documents. PDFs and images you upload are sent to the model for that request only and are not retained by the provider. Spreadsheets, Word files, and other office formats are converted to text inside our own infrastructure— those files are never sent to a third-party extraction or conversion service. We do not build a searchable index or embeddings of your documents.
• What we do keep, and what ZDR does not mean. Zero data retention is a commitment about the model providers— it does not mean Pernee stores nothing. The data your firm puts into Pernee (clients, engagements, documents, conversation history, and the agent’s memory of an engagement) is deliberately stored in our database, because the product does not work without it. That data is scoped to your organization and enforced at the database level by row-level security, so no other customer can reach it; it is yours to delete, and it is retained on the terms in section 8 — not on any model provider’s terms.
• Operational metadata. We record token counts, costs, timings, and error diagnostics for each run in order to meter usage against your plan, control spend, and keep the service reliable. This is metadata about a request, not the contents of it.

5. Cookies & similar technologies

We use strictly necessary cookies to keep you signed in and to secure your session. These are required for the application to function and cannot be switched off through our Services. We do not use advertising cookies. If we introduce analytics or other non-essential cookies in the future, we will update this policy and, where required, request your consent first.

6. How we share information

We do not sell your personal information and we do not share it for cross-context behavioral advertising. We share information only with:

• Service providers (sub-processors) who process data on our behalf under contract, including our hosting and content-delivery provider, our authentication and database provider, our error-monitoring provider, and our AI gateway and the model providers it routes to on the zero-retention, no-training terms set out in section 4. A current list of sub-processors is available on request at privacy@pernee.com.
• Your own organization— administrators of your firm’s workspace can access information associated with that workspace.
• Legal & safety — where we are required to by law, or to protect the rights, safety, and security of Pernee, our users, or the public.
• Business transfers — in connection with a merger, acquisition, or sale of assets, subject to this policy.

7. International data transfers

Your information may be processed in countries other than where you live. When we transfer personal information out of the EEA or the UK, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (and the UK Addendum), or another lawful transfer mechanism.

8. How long we keep your information

We keep personal information for as long as your account is active and for a reasonable period afterwards to meet the purposes described in this policy. Security and audit logs are retained as needed for security and compliance obligations. When information is no longer needed, we delete or anonymize it.

9. How we protect your information

We apply technical and organizational measures designed to protect personal information, including encryption in transit (HTTPS/TLS), strict transport security, database-level access controls with row-level security so that each organization can access only its own data, hardened HTTP security headers, rate limiting on authentication endpoints, and least-privilege access to production systems. No method of transmission or storage is completely secure, but we work continuously to protect your information.

10. Your privacy rights

EEA / UK (GDPR). Subject to conditions, you have the right to access, correct, delete, restrict, or object to our processing of your personal information, to data portability, and to withdraw consent. You also have the right to lodge a complaint with your local data protection authority.

California (CCPA/CPRA).If you are a California resident, you have the right to know what personal information we collect and how we use and disclose it, to request access to and deletion or correction of your personal information, and to opt out of the “sale” or “sharing” of personal information. We do not sell or share personal information as those terms are defined under California law. We will not discriminate against you for exercising your rights, and you may use an authorized agent to submit a request.

To exercise any of these rights, contact us at privacy@pernee.com. We will verify your request and respond within the timeframe required by applicable law. If your data is held on behalf of your organization, we may direct your request to that organization.

11. Children’s privacy

The Services are intended for use by businesses and are not directed to children. We do not knowingly collect personal information from children under 16. If you believe a child has provided us information, contact us and we will delete it.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above and, for material changes, provide additional notice where required. Your continued use of the Services after an update means you accept the revised policy.

13. Contact us

Questions or concerns about this policy or our data practices? We are here to help:

privacy@pernee.com
[Pernee legal entity name and registered postal address]