PENA

Privacy Policy - PENA

This Privacy Policy explains how PENA (“we”, “the application”, or “the service”) collects, uses, and protects information related to the use of the PENA (Secure Messenger) application, as well as its websites, features, and supporting services (collectively referred to as the “Platform”).

PENA is designed to provide a secure, private, and fully encrypted communication experience, ensuring that your conversations remain entirely your own.

By installing or using PENA, you are deemed to have read and agreed to this Policy.

1. Our Commitment to Your Privacy

Privacy is not just a feature for PENA. Privacy is a fundamental right of every individual and is the fundamental foundation of the entire system we build.

PENA is built on the core principle of privacy. PENA also does not collect user data in any form. The entire system is designed with the highest level of security standards and next-generation encryption technology, including protection against threats that do not exist today

We cannot view, store, or access your messages, and do not have the ability to read or record any communications that occur within PENA. All data and activities are completely under the control of the user.

All messages, communications, and data can only be viewed and stored by you. PENA does not own, does not store, and does not control any information from user activities within this application.

From the beginning, PENA was designed to ensure that full control of communications was in the hands of users, not in the hands of any company, server, or third party.

Privacy From the First Moment

PENA can be used without:

We believe that secure communication should not depend on identity. Therefore, PENA never asks for data that is not needed.

We Do Not Collect Personal Data

We are committed to:

We don't know who you are, who you're talking to, or what you're talking about — and we don't want to know.

Communication Without a Central Server

PENA uses a peer-to-peer (P2P) architecture, which means:

With this approach, the risk of mass surveillance and data leakage can be significantly minimized.

Uncompromised Encryption

All communications in PENA are protected by:

Only the sender and receiver can read the content of the message. Even we as developers don't have access.

Zero-Knowledge by Design

The PENA system is built on the principle of zero-knowledge:

If we don't have your data, then it can't be misused.

Your Data Stays on Your Device

When you delete something, the data is permanently lost, without any copies.

Additional File Security & Protection

To protect your device:

Privacy must not come at the expense of freedom.

Freedom Comes With Responsibility

We give you complete freedom of communication.
However, we also believe that true freedom always comes with personal responsibility.

PENA does not monitor conversations, but users remain responsible for their actions in accordance with applicable law.

Long-Term Commitment

Privacy is not a momentary trend. We are committed to:

Transparency & Trust

We strive to always be transparent about:

Trust is not demanded. Trust is built.

2. Information We Collect

PENA is designed with the principle of data minimization, which is to process only information that is really technically necessary, without compromising user privacy.

Basic Principles of Information Collection

PENA is designed with the principle of data minimization, which is to process only information that is really technically necessary, without compromising user privacy.

In general:

Information We Do NOT Collect

PENA does not collect, store or process the following information:

Content of Communication

All messages and files are end-to-end encrypted.

Content of communication:

Due to the peer-to-peer architecture, data moves directly between the user's devices.

Non-Identifying Technical Information

To ensure that the application can function properly, PENA may process limited technical information, which is non-identifiable, including:

This information:

Payment Information (Premium Service)

For Premium services, payments are processed by third-party providers.

PENA:

Payment information is fully subject to the privacy policy of the relevant payment provider.

Anti-Malware & File Security

User-accepted files can be scanned by anti-malware systems.

The scan is performed to:

This process:

Information Storage

All communication data is stored locally on the user's device.

PENA does not provide:

Deletion of Information

Users can delete data at any time.

Once removed:

PENA does not have a copy of the data to restore.

Legal Obligations

Because PENA does not collect or store the content of communications, PENA cannot provide user communication data to any party.

Legal compliance is carried out without compromising the principles of privacy and anonymity.

Changes to Information Collection Policy

In the event of a change in the type of technical information processed, PENA will:

Changes are effective from the date they are announced.

3. Messages and Calls

Core Principle

Messages and calls in PENA are built on one simple principle: only the sender and receiver can know the contents.

PENA does not act as an intermediary that can read, store, or control user communications.

Message Encryption

All text messages, voice messages, and files:

Each communication session:

PENA:

Voice Calls & Secure Calls

Voice calls in PENA are carried out:

All calls are:

PENA does not store:

Peer-to-Peer (P2P) Architecture

Messages and calls are delivered directly from the sender’s device to the recipient’s device.

No server:

The risk of mass-scale data exposure is minimized because:

Post-Quantum Security

PENA is designed to withstand future computational threats.

The encryption system considers:

Communication keys:

Metadata & Privacy

PENA does not:

Temporary technical information is only used to:

This information is temporary and not stored.

Message Deletion

Messages may be deleted manually or automatically.

Once deleted:

The Auto-Delete feature ensures messages do not leave a digital trace.

Technical Limitations

The quality of messages and calls may be affected by:

PENA does not guarantee that:

However, security remains the top priority.

User Responsibility

Users are responsible for the content of their messages and calls.

PENA does not moderate, record, or intervene in user communications.

4. How We Use Data

Principle of Data Usage

PENA uses data for one primary purpose: to ensure the application operates safely, stably, and functionally — without compromising user privacy.

We do not use data for:

Technically Used Data

PENA only uses non-identifying technical data necessary to:

This data is:

Use of Communication Data

The content of messages, calls, and files:

End-to-end encryption ensures:

All communications occur directly between user devices.

Security & Anti-Malware

PENA uses an anti-malware system to:

This process:

Scan results are used locally only to protect the user’s device.

Service Improvement

Anonymous technical data may be used to:

Such use is performed without:

Legal Compliance

Because PENA does not store communication content or user identity, our ability to provide user data is extremely limited.

Legal compliance is carried out only to the extent possible without violating privacy and anonymity principles.

Premium Services

Data related to Premium subscriptions is used only to:

Payment information is handled by third-party providers and is not used by PENA for any other purpose.

No Ads & No Tracking

PENA:

Our business is not built on your data.

Control in the Hands of Users

Users have full control over:

Once deleted, data:

5. Control Over Data

Principle of Data Ownership

In PENA, data fully belongs to the user.

PENA does not claim ownership of:

We only provide the technology — we do not control the data.

Full Control on the User’s Device

All communication data is stored locally on the user’s device.

There is no:

Users are free to:

Right to Delete Data

Users may delete:

Once deleted:

Deletion is instant and final.

Auto-Delete & Time Control

PENA provides an Auto-Delete feature.

Users may determine:

This feature helps to:

No Remote Access

PENA does not have:

Even under certain conditions:

Control Over Files & Media

Every received file:

The anti-malware feature:

Control Over Identity

PENA does not use:

There is no centralized account that must be closed.

Deleting the application means:

Right of Access & Portability

Because PENA does not store user data, requests for:

are technically unavailable.

All control remains in the hands of the user.

Technical Limitations of Data Control

Losing a device may result in:

Users are advised to:

Affirmation Statement

We do not hold your data.
We do not control your data.
You are fully in control.

Account Recovery (Recovery Phrase)

PENA uses a recovery phrase as an account recovery mechanism if a user forgets or loses their password.

The recovery phrase:

PENA does not have technical access to view, store, or recover a user’s recovery phrase. Therefore, PENA cannot assist with account recovery if the recovery phrase is lost or inaccessible.

The user is fully responsible for maintaining the security and confidentiality of their recovery phrase.

Account Registration and Use of CAPTCHA

During the initial registration process, PENA uses CAPTCHA as a system security measure.

CAPTCHA is used to:

CAPTCHA is not used to identify users and is not intended to collect personal data. PENA does not store identity information generated by the CAPTCHA process.

6. Children’s Privacy

Child Protection Principle

PENA is committed to protecting the privacy and safety of children in the digital environment. We strictly limit the use of our services to ensure compliance with applicable child protection laws.

Age Restrictions

PENA is not intended for children under the age of 13, unless legally permitted under applicable laws in the user’s region.

By using PENA, users acknowledge and confirm that:

No Collection of Children’s Data

PENA does not knowingly collect personal data from children, including but not limited to:

Because PENA:

PENA has no technical mechanism to individually identify a user’s age.

Content & Communication

PENA does not monitor or moderate user communications because:

Responsibility over a child’s use of the application lies with:

Actions in Case of Violation

If PENA becomes aware of service use by a child in violation of applicable laws:

Due to PENA’s architecture which does not store data, any actions taken are technical and limited in scope.

Role of Parents & Guardians

Parents or guardians are responsible for:

PENA recommends the use of:

Compliance With Child Protection Laws

PENA strives to comply with generally recognized child protection principles under applicable laws and regulations, including but not limited to:

However, compliance is implemented without compromising user anonymity and encryption principles.

Affirmation Statement

PENA is not designed to collect children’s data.
We do not build profiles of anyone — including children.
Safety and privacy begin with restriction, not surveillance.

7. Prohibited Use

PENA is a Super App built on privacy and high-level security that gives users full control over their communications and transactions. With this freedom, users are required to use PENA responsibly and in accordance with applicable laws.

Users are prohibited from using PENA — including PENA Chat and PENA Wallet — for unlawful purposes, including but not limited to:

Communication activities that contain illegal elements, such as:

Using PENA Wallet for:

8. Law Enforcement Requests

General Principle

PENA respects applicable laws. However, PENA is designed from the beginning with a privacy-by-design approach, which means our technical ability to access or disclose user data is extremely limited.

We cannot provide data that we do not have.

Limitations of Data Access

PENA does not store:

All communications:

Technically, PENA cannot read, access, or decrypt user communications — even upon request from any party.

Types of Requests We May Accept

PENA will only respond to law enforcement requests that:

However, our response remains limited by:

Information That May Be Provided

In limited situations, and only where technically available, PENA may provide:

Information We Cannot Provide

PENA cannot and will not provide:

No Backdoor Access

PENA does not provide:

Providing such access would conflict with:

Transparency

Where legally permitted, PENA reserves the right to:

PENA will not modify the application’s technical design to enable data access.

Jurisdiction & Compliance

Each request is evaluated based on:

Compliance is carried out without:

Affirmation Statement

We respect the law.
But we do not store what should not be stored.
User privacy cannot be handed over — because we do not possess it.

9. Disclaimer

Nature of Service

PENA is provided “as is” and “as available”.

We do not guarantee that the service will:

No Guarantee of Communication Success

PENA does not guarantee that:

Service performance may be affected by:

Security & User Risk

PENA implements advanced security technology, including:

However, no system is entirely risk-free.

Users understand and accept that:

Data Loss

Because PENA does not store data on servers:

may result in permanent loss of data.

PENA is not responsible for:

Responsibility for Content

All communication content is the responsibility of the user.

PENA:

PENA is not responsible for:

Anti-Malware & Files

The anti-malware feature is provided as an additional protection layer.

PENA does not guarantee that:

Users remain responsible for:

Third-Party Services

PENA may rely on:

PENA is not responsible for:

Limitation of Liability

To the extent permitted by law, PENA is not liable for:

No Legal or Professional Advice

PENA does not provide:

Use of the service is entirely the responsibility of the user.

Closing Statement

We build secure technology.
But how it is used is entirely up to you.
Use it wisely.

10. Intellectual Property Rights

Ownership of Rights

All intellectual property rights contained in or associated with the PENA application, including but not limited to:

Are owned by or legally licensed to PENA and are protected by copyright law, trademark law, and applicable regulations.

License to Users

PENA grants users a limited, non-exclusive, non-transferable, and revocable license to:

This license is granted solely for lawful personal use, in accordance with these Terms.

Usage Restrictions

Users are prohibited from:

User Content

All user-generated communication content (messages, files, media) remains the property of the user.

PENA:

No license to user content is granted to PENA, because PENA does not technically store such content.

Feedback & Suggestions

If users provide feedback, suggestions, or ideas to PENA:

Feedback is not treated as confidential information unless otherwise stated in writing.

Intellectual Property Violations

PENA reserves the right to take action against:

Such actions may include:

Rights Not Granted

All rights not expressly granted to the user remain the property of PENA.

Affirmation Statement

This technology is built with great care.
Use it respectfully.
Copyright exists not to restrict — but to protect.

11. Jurisdiction

Governing Law

The Terms of Use, Privacy Policy, and all legal relationships between the user and PENA are governed by and interpreted in accordance with the laws of the Republic of Indonesia, without regard to conflict-of-law principles.

Scope of Jurisdiction

This jurisdiction applies to:

These provisions apply regardless of the physical location of the user when accessing the service.

Dispute Resolution

Any dispute, conflict, or claim arising from the use of PENA shall first be settled through deliberation or amicable resolution.

If no amicable settlement is reached, the dispute shall be resolved through a legally authorized forum within the Republic of Indonesia, in accordance with applicable laws and regulations.

Limitation of Foreign Jurisdiction

Users understand and agree that:

Technical Limitations Related to Jurisdiction

Because PENA:

The execution of certain jurisdictional actions may be technically limited.

Users acknowledge that these limitations are a direct result of PENA’s privacy and security design.

No Waiver of User Rights

The application of this jurisdiction does not waive or limit users’ rights that are protected under applicable law, as long as they do not conflict with these Terms.

Affirmation Statement

The law remains respected.
But privacy is not compromised.
Jurisdiction operates in harmony with user protection principles.

12. Official Contact

For privacy inquiries, data requests, or other official matters, please contact:

📧 [email protected]