PENA — Terms & Conditions of Use (User Agreement)

Last Updated: January 2026

Welcome to PENA. These Terms & Conditions ("Terms") govern your access to and use of the PENA application, software, website, and all related features ("Services").

By installing, accessing, or using PENA, you represent that you have read, understood, and agree to these Terms in full.

If you do not agree to these Terms, please stop using the Service immediately.

1. Definition

In all legal documents, policies, terms, and conditions relating to the PENA application, the following terms have the following meanings:

PENA
is a super high privacy and security-based Super Apps that provide digital communication services and a Bitcoin-only wallet (BTC only), equipped with VPN features, built on Real Peer-to-Peer (P2P) architecture, using 3.20 F (Post-Quantum) and 3.20 W (Post-Quantum Cryptography) encryption, and applying the principles of end-to-end encryption, self-custody, and zero-access, so that all control of Bitcoin's data, communications, and assets is fully in the hands of users.

Applications
Are PENA software in the form of Super Apps that provide a variety of integrated services in one platform, and can be accessed through electronic devices, including but not limited to mobile phones, tablets, or other compatible devices.

User
Is any individual or party who downloads, installs, accesses, or uses the PENA application, either directly or indirectly.

The Service
is all features and functions provided by PENA, including but not limited to text messaging, file delivery, 3.20 F (Post-Quantum) Encryption, Real P2P network, anti-malware features, auto-delete, recovery phrase, PENA Wallet with 3.20 W (Post-Quantum Cryptography) Encryption, as well as Basic and Premium services.

Real Peer-to-Peer (P2P)
is a method of direct communication between a user's devices without going through a central server or third-party intermediary.

End-to-End Encryption
is a method of securing communications in which messages and files are encrypted on the sender's device and can only be decrypted on the receiving device.

3.20 F (Post-Quantum) Encryption
Is an advanced symmetric encryption system used by PENA, where encryption keys and patterns are dynamic and variable for each communication session, in order to increase resistance to cryptographic analysis and attacks.

3.20 W (Post-Quantum Cryptography) Encryption
It is an advanced encryption system designed to protect digital assets and cryptographic keys from future computing threats, including Quantum Computing.

In PENA Wallet, 3.20 W (Post-Quantum Cryptography) is used to protect the wallet's private keys, secure transactions, and ensure that only the wallet owner has full access.

Post-Quantum
is a cryptographic security mechanism designed to remain secure against potential attacks from quantum computers in the future.

Anti-Malware
Is a security system within PENA that automatically scans received files to detect and prevent files that are malicious, dangerous, or potentially damaging to the user's device.

Auto-Delete
Is a feature that allows messages or files to be deleted automatically after a certain period of time.

Recovery Phrase
PENA uses recovery phrase as an account recovery mechanism if the user forgets or loses the password.

Data
Is all messages, files, local metadata, or other information that is generated, sent, received, or stored locally by a user through the PENA application.

Personal Data
is information that can identify a person directly or indirectly. PENA does not collect, store, or process users' personal data.

Device
Is the user-owned hardware used to access and run the PENA application.

Basic Plan
Is a version of PENA service that is available to users with standard security features, including anti-malware, as well as access to the core features of PENA in accordance with applicable terms.

Premium Plan
Is a paid version of the PENA service that provides Ultra Secure Mode with advanced security and privacy features, including but not limited to VPN features and other additional features in accordance with applicable regulations.

PENA Wallet (BTC Only)
PENA Wallet is a Bitcoin wallet (BTC only) designed for maximum security and full user control, using 3.20 W (Post-Quantum Cryptography) Encryption, and applying the principles of self-custody and zero-access, and can only be used to receive, send, and store Bitcoin.

Third Party
Means any party other than PENA and users, including but not limited to individuals, legal entities, or other entities.

Terms
are all terms, policies, agreements, and rules that govern the use of the PENA application, including their changes and updates.

2. Scope of Service

General Description of Service

PENA is a digital communication application that provides instant messaging and file exchange services with a primary focus on user security, privacy, and anonymity. All PENA services are designed using a real peer-to-peer (P2P) architecture, with no central servers, no cloud storage, and no collection of personal identities.

Communication Services

PENA provides communication services in the form of:

• Sending and receiving text messages between users.
• Direct communication between devices without third-party intermediaries.
• End-to-end encrypted communication systems use 3.20 F (Post-Quantum) Encryption.
• Creation of a unique encryption key for each communication session.

File Exchange Services

Within the scope of the PENA service, users can:

• Send and receive digital files, including but not limited to documents, images, and other media.
• Perform direct file exchange between devices (P2P).
• Use the automatic Anti-Malware scanning feature against the received files.

The terms of anti-malware service include:

• Basic plan with a limited number of scans.
• Premium plan with unlimited scanning.

Security & Privacy Services

PENA provides security and privacy services that include:

• End-to-end encryption on all messages and files.
• The use of 3.20 F (Post-Quantum) Encryption to increase resistance to cryptographic analysis and attacks.
• PENA Wallet uses 3.20 (Post-Quantum Cryptography) Encryption to protect digital assets and cryptographic keys from future computing threats.
• Application of post-quantum security mechanisms for long-term protection.
• No data storage on a central server or cloud.
• No collection, storage or processing of users' personal data.

Local Data Management Services

Within the scope of this service, the user has full control over the data residing on his device, including:

• Manual deletion of messages and files.
• Auto-deletion via Auto-Delete feature.
• Delete all data through the Wipe Code feature.

All data deletions are permanent and cannot be recovered.

Additional Features Services

PENA provides additional features as part of the scope of services, including:

• Advanced security settings for high-risk communication needs.
• Feature management based on Basic and Premium service plans.

Limitations on the Scope of Services

The scope of PENA services does not include:

• Storage or backup of data on a server or cloud.
• Management, monitoring, or moderation of the content of user communications.
• User identity provision, identity verification, or account recovery.
• Recovery of data that has been deleted by the user or system.

Changes in the Scope of Services

PENA reserves the right to:

• Change, add, or reduce the scope of the service.
• Make feature adjustments to improve the security, stability, and performance of the app.
• Adjust the service based on technological developments, operational needs, or applicable legal requirements.

Changes in the scope of the service will take effect from the moment they are published in the application or official platform of PENA.

User Responsibility

In using the PENA service, the user is solely responsible for:

• All communication activities and file exchange.
• The security of the device being used.
• Local data management and protection on their devices.

3. User Eligibility

General Requirements

Users are declared eligible to use the PENA application if they meet the following conditions:

• An individual who is legally capable of using digital services in accordance with applicable laws and regulations.
• Use the PENA application of your own volition and with full awareness of the nature of the anonymous and decentralized service.
• Agree to all Terms of Service, Privacy Policy, and other related regulations applicable to the PENA application.

Age Restrictions

• The User must be at least 13 (thirteen) years old or have been considered an adult according to the applicable laws in the user's jurisdiction.
• Users under this age are not allowed to use PENA services without the supervision and approval of the authorities in accordance with local law.
• PENA does not have an age verification mechanism because it does not collect user identity data.

Legal Capacity

By using PENA, users represent and warrant that:

• Have the full legal capacity to bind themselves to this agreement.
• Not being in a legal condition that restricts or prohibits the use of digital communication services.
• Do not use PENA on behalf of other parties without valid authority.

Device Eligibility

To be able to use PENA optimally, users must:

• Using a device that is compatible with the PENA application system.
• Keeping devices safe from unauthorized access, malware, or system vulnerabilities.
• Be responsible for all activities that occur through such devices.

Compliance with the Law

The user is declared eligible to use PENA during:

• Do not use the service for unlawful purposes.
• Do not use the application for activities prohibited by applicable laws and regulations.
• Do not use PENA to harm other parties legally or non-legally.

Anonymity & Personal Responsibility

• PENA provides anonymity freedom to users.
• Anonymity does not mean being free from legal liability.
• All legal consequences for the use of the application are entirely the responsibility of the user.

Eligibility Denial

PENA reserves the right to:

• Restrict or terminate access to the service if a violation of these terms is found.
• Refuse to use the service if it is proven to be used for activities that are contrary to applicable law.
• Take such actions as are deemed necessary to keep the system and other users safe.

No Identity Verification

• PENA does not verify the identity of users.
• User eligibility is based on the user's statement and good faith.
• Any risk resulting from the incorrectness of the user's statement is the sole responsibility of the user.

Eligibility Requirements

User eligibility occurs during:

• The user complies with all terms of service.
• Not to commit any violations of the law or abuse of the service.
• It does not pose a risk to the security, stability, or reputation of PENA.

4. Account & Security

No Conventional Account

• PENA does not use an account system based on:

Phone number
Email address
Original name
Other official identities

• The use of the application does not require the registration of a conventional account.
• The user's identity is local and stored only on the user's device.

User's Local Identity

• Each user has a local identity that is automatically generated by the system.
• These local identities are used solely to:

Connection requirements between users
Communication encryption
P2P session management

Local identity:

• Not sent to the central server
• Cannot be associated with the user's real-world identity

Application Access Security

Users can secure access to the PENA application through:

• Application security code (PIN/passcode).
• Device security features, such as biometrics (if available).
• Additional security settings at the user's discretion.

User Safety Responsibilities

The User is solely responsible for:

• The security of the device being used.
• The confidentiality of the security code or local authentication method.
• All activities are carried out through the PENA application on their devices.

PENA is not responsible for:

• Unauthorized access due to user negligence.
• Data loss due to damage or loss of device.

Encryption and Data Protection

All communications are protected by End-to-End Encryption.

PENA uses 320 F (Post-Quantum) Encryption to improve data security from future computing threats.

PENA Wallet uses 3.20 W (Post-Quantum Cryptography) Encryption to protect private keys and transactions from future computing threats, including Quantum Computing.

Encryption key:

• Uniquely crafted for each communication session
• Not stored on a central server

PENA applies the principle of Zero-Knowledge, where the system does not have access to the content of the user's communication.

Peer-to-Peer Real Network Security

• Connections between users are made directly (P2P).
• There is no central server that stores or forwards the content of the message.
• The risk of mass eavesdropping is minimized due to the absence of a central point.

Additional Security Features

PENA provides advanced security features, including but not limited to:

• Auto-Delete for automatic message deletion.
• Wipe Code to erase all data instantly.
• App locking to prevent unauthorized access.

Anti-Malware & File Protection

• Every file that the user receives will be scanned automatically.
• Anti-malware systems are designed to detect malicious threats.
• The limitations of the anti-malware feature are adjusted by service plan (Basic or Premium).
• PENA does not guarantee absolute protection against all types of malware, but it strives to provide the best protection according to technological capabilities.

Loss of Access & Recovery

PENA does not provide an account recovery feature.

If the device is lost, damaged, or data is deleted:

• Access to data cannot be restored
• No backups on servers or clouds

Users fully understand and agree to these risks.

Limitation of Security Liability

PENA is not responsible for:

• Data loss due to user error.
• Security breaches caused by the user's device.
• Losses due to the use of the application outside of the specified specifications or conditions.

Security Updates

• PENA may perform security system updates periodically.
• The update aims to:

Increase protection
Closing security gaps
Adapting to technological developments

Users are advised to always use the latest version of the app.

5. Intellectual Property Rights & Licenses

Ownership of Intellectual Property Rights

• All intellectual property rights related to the PENA application, including but not limited to:

Software
Source code
Security algorithm
Interface design (UI/UX)
Logos, icons, and visual identities
Documentation and supporting materials are the legal property of PENA and/or the party that granted the license to PENA.

• Nothing in this agreement transfers ownership rights to the user.

License to Use to Users

• PENA grants the licensee user:

Non-exclusive
Non-transferable
Cannot be sublicensed
Can be revoked at any time

This license is granted solely for:

Download
Install
Using the PENA application in accordance with the applicable Terms of Service.

License Restrictions

In using the PENA application, users are prohibited from:

• Copy, modify, or distribute the app without written permission.
• Reverse engineering, decompilation, or code disassembly.
• Exploiting security, encryption, or P2P networks.
• Use the app for commercial purposes without the express written consent of PENA.
• Remove or alter any copyright or intellectual property rights notice.

User Content & Data

• The rights to the content of messages and files remain entirely with the user.
• PENA does not claim ownership of the content of user communications.
• Because the PENA system is characterized by:

End-to-end encrypted
No central server

Therefore, PENA does not have access to the content of user communications.

Limited License to Technical Content

• For operational purposes, the user grants limited permission to PENA to:

Processing non-identifying technical data
Running the app's functions normally

This license does not include access to the content of messages or files.

Trademarks

• The name "PENA", logo, icon, and all related brand elements are legally protected trademarks.
• The use of the PENA trademark without written permission is prohibited.
• Users are not allowed to use the PENA brand for purposes that mislead or harm the reputation of PENA.

Third Party Rights

• The PENA application may use legally licensed third-party components.
• The rights to these components remain the property of their respective third parties.
• Use of such components is subject to applicable licenses.

Intellectual Property Rights Infringement

• PENA has the right to take action in the event of infringement of intellectual property rights.
• Actions can be:

Access restrictions
Termination of service
Legal steps in accordance with applicable provisions

The user is responsible for any violations he commits.

License Termination

• The license to use will automatically expire if:

The user violates these terms
The user stops using the app

After the license expires, the user is obliged to stop all use of the PENA application.

Legal Protection

• All intellectual property rights are protected by applicable law.
• These terms remain in effect even if the user agreement ends.

The content you submit remains entirely yours.

6. Privacy & Encryption

Privacy Policy Principles

• PENA is built on the principles of privacy-by-design and security-by-default.
• User privacy is not an additional feature, but rather the main foundation of the service.
• PENA does not require users to provide:

Original name
Phone number
Email address
Other identity information

No Collection of Personal Data

• PENA does not collect, store, or process users' personal data.
• No system:

Centralized user profiles
Identity database
User behavior tracking

All communication data is located and processed locally on the user's device.

Real Peer-to-Peer (P2P) Architecture

• PENA uses a peer-to-peer real architecture, where:

The user's devices are directly connected to each other
There is no central server that stores messages

Messages and files don't pass through intermediary servers.

This model eliminates the risk:

• Mass surveillance
• Centralized data leaks
• Misuse of data by third parties

End-to-End Encryption

• All PENA communications are protected by End-To-End Encryption (E2EE).
• Only the sender and receiver can read the content of the message.
• PENA does not have technical access to:

Read messages
Save messages
Decrypt user files

AES-320 F (Post-Quantum) Encryption

• PENA uses AES-320 F (Post-Quantum) Encryption, which is:

A strengthened version of the symmetric encryption standard
Generates a different encryption pattern each session

Each communication:

• Using a unique encryption key
• Not reusable

The AES-320 F (Post-Quantum) Encryption approach increases resilience against:

• Pattern analysis
• Repeated cryptographic attacks
• Unauthorized data reading attempts

Post-Quantum Protection

• PENA is designed with a post-quantum readiness approach.
• Communication systems consider future cryptographic threats.
• The key and data exchange mechanism is set up for:

Reduces the risk of quantum computing attacks
Maintain long-term confidentiality

Zero-Knowledge System

• PENA applies the principle of Zero-Knowledge, where:

The system does not know the content of the communication
Doesn't store encryption keys

Even under certain technical conditions, PENA cannot provide the content of the message to any party.

Local & Cloudless Data Storage

• Entire messages and files:

Stored only on the user's device
Not backed up to the cloud

PENA does not provide:

• Online backup
• Server-based cross-device synchronization

Permanent Data Deletion

• Users can delete messages and files at any time.
• Deletion is of the following nature:

Permanent
Irreversible

The Auto-Delete feature allows automatic deletion as per the user's settings.

File Security & Anti-Malware

• Every file received will be scanned by the Anti-Malware system.
• The scan aims to detect:

Malware
Malicious files
Other security threats

Anti-malware system:

• Not reading the contents of encrypted communications
• Operates only on accepted file objects

Privacy Protection Limitations

• Although PENA implements high security standards, no system is completely immune to risk.
• Security also depends on:

The condition of the user's device
Operating system
Usage behavior

User Responsibility

The User is responsible for:

• Keep your device secure.
• Not sharing app access with others.
• Use the application in accordance with applicable law.

Compliance with the Law

• PENA respects applicable laws without compromising user privacy.
• Because it does not have access to communication data, PENA cannot hand over the content of user messages to any party.

Privacy & Encryption System Changes

• PENA may update its privacy and encryption systems to improve security.
• Changes will take effect from the moment they are published in the app or official platform.

Full details are available in PENA's Privacy Policy.

7. User Behavior

General Principles of Behavior

• Users are required to use the PENA application in good faith, responsibly, and in accordance with applicable law.
• The freedom, anonymity, and privacy provided by PENA do not eliminate the personal legal responsibility of the user.
• All in-app activities are entirely the responsibility of the user.

Individual Responsibilities

The User is responsible for:

• The content of the message
• Files sent or received
• The impact of communication

PENA does not monitor, store, or control the content of user communications because the system is in nature:

• End-to-End Encrypted
• Real Peer-to-Peer
• No central server

General Prohibitions of Use

Users are prohibited from using PENA to:

• Perform acts that violate laws, regulations, or public order.
• Spreading content that violates the rights of others, including copyright and privacy.
• Commit fraud, manipulation, or impersonation with the intent to harm another party.
• Transmitting malware, malicious code, or files that have the potential to damage the system.
• Intimidating, threatening, or harassing other parties.

Abuse of the Service

• Users are not allowed to use PENA to:

System exploit activity
Permissionless security testing
Hacking attempts or technical glitches

Any attempt to bypass or damage the security system is considered a serious violation.

Content & Communication

• PENA does not do:

Content censorship
Message moderation
Communication surveillance

Users understand that freedom of communication also means:

• Risk of receiving unwanted content
• Full responsibility for interactions

Digital Ethics

Users are expected to:

• Respect the privacy and security of other users.
• Do not abuse anonymity to harm others.
• Maintain reasonable communication and do not cause legal conflicts.

Interaction Between Users

• Each interaction occurs with the consent of each party.
• PENA is not responsible for:

Disputes between users
Disadvantages due to direct communication

Users are encouraged to stop communications that they feel are unsafe.

Reporting & Actions

• Due to the decentralized nature of the PENA system, reporting capabilities are limited.
• PENA was unable to access or verify the content of the reported messages.
• Users are advised to:

Secure your device
Stop communication
Take personal legal steps when necessary

Consequences of Violations

• PENA reserves the right to take action in the event of a breach of these provisions, including:

Feature restrictions
Termination of service

The action is carried out as far as technically possible without violating the principle of privacy.

No Responsibility for Content

• PENA is not responsible for:

The content of the message
File
Impact of user communication

All risk of using the service is borne solely by the user.

Legal Compliance

• Users are required to ensure that the use of PENA is in accordance with the laws in their respective regions.
• PENA does not provide protection against illegal actions even though the service is anonymous.

8. Service Reliability

Reliability Principle

• PENA is designed to provide stable, safe, and reliable communication services according to available technological capabilities.
• The reliability of the service depends on the combination between:

User device infrastructure
Each party's network connection
Technical conditions of the application system

Decentralized Architecture

• PENA uses a real peer-to-peer (P2P) architecture without a central server.
• The absence of a central server means:

There is no single point of failure
The risk of mass disruption can be minimized

However, the quality of service is greatly affected by:

• Availability of both users' connections
• The state of the internet network of each device

Service Availability

• PENA strives to keep the service accessible at all times.
• However, PENA does not guarantee that the service will:

Always available without interruption
Free from delays or connection failures

Disorders can occur as a result of:

• System maintenance
• App updates
• Third-party network disruption

Communication Quality

The quality of message and file delivery is affected by:

• Network speed
• P2P connection stability
• The condition of the user's device

Delays, delivery failures, or disconnections may occur and are beyond PENA's control.

Security as a Reliability Priority

• PENA prioritizes security and privacy over speed or convenience.
• Encryption, anti-malware scanning, and other security protections can affect:

Delivery time
Data reception process

Users understand that additional security measures are part of long-term reliability.

Updates & Maintenance

• PENA can do:

System updates
Technical maintenance
Feature customization

The update aims to:

• Improves stability
• Fix bugs
• Strengthen security

During the update, the service may experience temporary limitations.

Reliance on Third Parties

• Some aspects of the service depend on:

Device operating system
Internet network
Application distribution services

Interference with third parties is beyond PENA's responsibility.

Limitations of Service Guarantee

• PENA is provided on an "as is" and "as available" basis.
• PENA makes no express or implied warranties regarding:

Uninterrupted availability
Fit for a specific purpose
Absolute reliability of the system

User Responsibility

The User is responsible for:

• Provide a decent and safe device.
• Maintain a stable network connection.
• Using the latest version of the app.

Limitation of Liability

• PENA is not responsible for:

Service interruptions due to external factors
Data loss due to device or network failure
Indirect losses due to service limitations

The User agrees that the use of the service is at his own risk.

Service Reliability Changes

• PENA reserves the right to change, adjust, or discontinue part or all of the services.
• Changes are made to:

Quality improvement
Security
Legal compliance

Changes take effect from the date of announcement on the official PENA application or platform.

9. Paid Services (Premium)

General Description of Premium Services

• PENA provides paid services ("Premium") as an upgrade to basic services ("Basic").
• The Premium Service is intended for users who need:

Advanced security protection
Greater usage capacity
Additional privacy features

Premium Services are optional and not mandatory to use PENA.

Premium Service Features

With a Premium subscription, users can gain access to additional features, including but not limited to:

• Unlimited Anti-Malware
  Unlimited number of incoming file scans.
• Unlimited File Transfer
  Sending and receiving files without any specific quota restrictions.
• Additional Security Features
  Advanced privacy settings
  Additional access protection
  Quick wipe removal mechanism

PENA Wallet

PENA Wallet is a Bitcoin (BTC Only) wallet designed for maximum security and full user control.

Payment Mechanism

• Payment for Premium services is made through:

Official app distribution platform
Third-party provided payment methods

PENA does not store user payment data.

All financial transactions are processed by third-party payment service providers.

Validity Period & Extension

• Premium Services are valid for the subscription period of the user's choice.
• Renewals can be done automatically or manually, according to the user's settings.
• If the subscription period ends, Premium access will:

Disabled
Return to the Basic service without deleting the user's local data

Cancellation Policy

• Users can cancel their Premium subscription at any time.
• Cancellation will take effect at the end of the current subscription period.
• PENA does not provide refunds for:

Subscription period that has been running
Features that have been used

Pricing Changes & Features

• PENA reserves the right to change:

Premium service pricing
Package structure
List of features

Changes will be notified via:

• Application
• PENA official platform

Changes are effective from the specified date.

Limitations of Premium Services

• Despite being Premium, the service:

Does not guarantee absolute protection
Doesn't eliminate all technical risks

Security and performance remain dependent on:

• User device
• Network conditions
• User compliance with conditions

No Special Warranties

• Premium Services are provided "as is".
• There are no implied or express warranties regarding:

Uninterrupted availability
Suitability for specific needs

Termination of Premium Services

• PENA reserves the right to suspend or terminate access to Premium if:

Violation of the provisions
Required for system security

Termination does not delete the user's local data.

Legal & Tax Compliance

• Premium service prices may include taxes as per the legal requirements.
• The User is responsible for any tax liability that may arise.

Premium Service Updates

• PENA can add or subtract Premium features.
• The update aims to improve:

Security
Quality of service

Updates are effective from the time they are announced.

10. Suspension / Termination

General Principles

• PENA reserves the right to suspend or terminate services in order to:

Keeping the system secure
Protect other users
Comply with applicable legal provisions

Suspension or termination is carried out as far as technically feasible without violating the principles of privacy and anonymity.

Service Suspension

Basis of Deferment

PENA may suspend part or all of service access if:

• The User violates the Terms of Service, Privacy Policy, or other related regulations.
• There are indications of misuse of services or activities that are high risk to system security.
• Precautions are required to protect the integrity of the P2P network.
• There is a technical, maintenance, or system update fault.

Form of Suspension

Suspension can be done in the form of:

• Certain feature restrictions.
• Temporary disabling of service access.
• Premium access suspension without deleting the user's local data.

Service Termination

Termination by PENA

PENA reserves the right to permanently terminate the service if:

• There is a serious or repeated violation of the terms of service.
• The use of the application is proven to be in violation of applicable law.
• The user poses a threat to the security, stability, or reputation of PENA.
• It is required under a legal obligation or a lawful authority order.

Termination by Users

Users can stop using the app at any time.

Termination can be done by:

• Delete an app
• Delete all local data

Termination by the user is final and irreversible.

Impact of Suspension & Termination

• After suspension or termination:

Service access will be restricted or terminated
Local data remains on the user's device until it is deleted

PENA has no obligation to:

• Storing data
• Recover a message or file
• Provide a copy of the communication

No Account Recovery

• Since PENA does not use a centralized account system:

No account recovery available
No access rollback available

Users fully understand and agree to these risks.

Termination of Premium Services

• Termination of Premium services may occur when:

Subscription period ends
Violation of the provisions

Premium termination does not delete the user's local data.

There are no refunds for the remaining unused subscription period, unless required by law.

Notice

• PENA may provide notice of suspension or termination through:

Application
Official platform

Under certain circumstances, advance notice may not be possible for security or legal reasons.

Limitation of Liability

• PENA is not responsible for:

Losses due to suspension or termination of services
Data loss due to deletion by users

Users use the service at their own risk.

Applicability of Terms

• These terms remain in effect even if the service is discontinued.
• Related Parts:

Privacy
Intellectual Property Rights
The limitation of liability remains binding on the user.

11. Disclaimer of Liability

General Terms

• The PENA application is provided on an "as is" and "as available" basis.
• Use of the app is entirely at the user's own risk.
• PENA makes no express or implied warranties relating to:

Service availability
Absolute reliability
Fit for a specific purpose

Disclaimer of the Content of Communication

• PENA is not responsible for:

The content of the message
File
Information exchanged between users

Because the system uses:

• End-to-End Encryption
• Real Peer-to-Peer

Without a central server, PENA does not have technical access to the content of user communications.

Disclaimer of User Actions

• All user actions in the application are the user's personal responsibility.
• PENA is not responsible for:

Violations of the law committed by the user
Losses arising from interactions between users

Anonymity does not eliminate the legal responsibility of individuals.

Disclaimer of Technical Glitches

• PENA is not responsible for service interruptions caused by:

Internet network failure
Third-party system disruptions
The condition of the user's device

Delays, data loss, or delivery failures may occur beyond PENA's control.

Data Loss Disclaimer

• PENA is not responsible for:

Loss of messages or files
User-generated data deletion
Device damage

There is no recovery system or data backup.

Disclaimer of Absolute Security

Although PENA implements:

• Advanced encryption
• Anti-malware
• Post-quantum security

No system is completely risk-free.

PENA does not guarantee absolute protection against:

• Cyberattacks
• Advanced malware
• User device vulnerabilities

Disclaimer of Premium Services

• Premium features don't guarantee:

Absolute security
Uninterrupted availability

PENA is not responsible for:

• Mismatch of user expectations
• Losses due to the use of Premium services

Limitation of Legal Liability

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

Direct or indirect losses
Loss of profits
Intangible losses

PENA's total liability, if any, is limited to the amount permitted by applicable law.

Force Majeure

PENA is not responsible for service failures or delays due to circumstances beyond its control, including but not limited to:

• Nateral disasters
• Global network disruption
• Regulatory changes
• Government action
• National emergency

12. Changes in Terms

These terms are subject to renewal at any time.
Important changes will be announced through the app or official website.

General Terms of Change

PENA reserves the right, fully and at any time, to change, add, delete, or update all or part of the terms and conditions of use of the application, including but not limited to:

• Terms of Service
• Privacy Policy
• User Agreement
• Security, encryption, anti-malware, and P2P networking provisions

Changes to the conditions are made to adapt to:

• Developments in security and encryption technology
• Improved app features
• Changes in applicable regulations or laws
• Operational needs and user protection

The User understands and agrees that PENA is an application with an architecture without a central server, without identity, and without data storage, so the change in terms is not related to the management of the user's personal data.

Mechanism for Implementing Changes

Any changes to the terms will take effect from:

• Published in the PENA application, or
• Published through the official PENA channel

PENA is under no obligation to provide individual notices to each user, remembering:

• Absence of user identity data
• No email, phone number, or centralized account

By continuing to use the PENA application after the changes take effect, users are considered:

• Have read
• Understanding
• Agree to all changes to the terms

User's Right to Change of Terms

If the user does not agree to part or all of the changes to the terms, the user has the right to:

• Stop using apps
• Remove an app from your device
• Permanently delete all data

Because PENA does not store data on servers and does not have a data recovery mechanism, users understand that:

• Data deletion is final and irreversible
• There is no obligation of PENA to store or return any data

Feature & Security Changes

PENA may make changes or updates related to:

• Encryption system, including AES-320 Polymorphic Encryption
• Post-quantum security mechanisms
• Anti-malware and file scanning system
• P2P network architecture

These changes may include:

• Added security features
• Restriction or removal of certain features
• Changes to the Basic and Premium service schemes

Users understand that security changes are made to enhance protection, and not to weaken user privacy or anonymity.

Limitation of Liability for Change

PENA is not responsible for:

• Discomfort due to feature changes
• Loss of access to certain features
• Changes in the application usage mechanism

PENA cannot be held liable for direct or indirect losses arising from changes in conditions, as long as such changes are made reasonably and in the interests of security, law, or operation.

Applicability of Terms

If one or more provisions in the Amendment section of these Terms are held to be invalid by law, the remaining provisions shall remain valid and binding.

This section is an integral part of the Terms of Service and other PENA legal documents.

Continued use means that you agree to the updated Terms.

13. Applicable Law & Dispute Resolution

Disputes will be resolved in accordance with the legal jurisdiction chosen by the PENA manager. If an informal settlement fails, arbitration or legal proceedings may be conducted in accordance with the applicable rules.

Governing Law

These Applicable Legal Terms & Dispute Resolution govern the entire legal relationship between users and the PENA application, including but not limited to the use of the service, security features, encryption systems, real peer-to-peer (P2P) networks, anti-malware, and all policies and agreements attached to the application.

By using the PENA application, the user consciously and voluntarily agrees that the legal relationship that arises is governed and interpreted based on the applicable law in the jurisdiction where the developer of the PENA application is registered, regardless of the conflict of laws.

The user understands that PENA is an application:

• No central server
• No cloud storage
• No collection of personal identity
• Based on direct connections between users (P2P)

Therefore, PENA does not play the role of a content organizer, communication intermediary, or party that stores user data.

All legal responsibility for the content of communications, messages, files, or other activities carried out through the application rests solely with the user. PENA does not have the technical capability or access to:

• Read the content of the message
• Change the content of a communication
• Store or restore user data

Users acknowledge that PENA's security system uses AES-320 F (Post-Quantum) Encryption, end-to-end encryption, as well as other advanced security mechanisms.

However, no digital system can guarantee absolute security, so PENA cannot be held liable for losses incurred as a result of:

• Misuse of the user's device
• User negligence in maintaining device access
• Third-party attacks beyond PENA's reasonable control

Limitation of Legal Liability

PENA is provided on an "as is" and "as available" basis without warranties of any kind, either express or implied.

PENA is not responsible for:

• Data loss due to manual or automatic deletion
• Data loss due to wipe code or auto-delete feature
• Direct or indirect losses arising from the use of the application

Since PENA does not store data and does not have a central server, users hereby agree that there is no data recovery mechanism under any circumstances.

Dispute Resolution

Deliberation & Peaceful Settlement
Any disputes, differences of opinion, or disputes arising from the use of the PENA application will be sought first to be resolved through deliberation and good faith between the parties.

No Class Action
The User hereby agrees that each dispute is resolved individually, and the User waives the right to file a class action.

Limitations of PENA's Role
Considering the nature of PENA as a P2P communication platform without a central server:

• PENA cannot be asked to hand over communication data
• PENA cannot be a witness to the content of the conversation
• PENA does not have the technical authority to intervene in user communications

Legal Forum
If a peaceful settlement is not reached, the dispute will be resolved through the competent legal forum in accordance with applicable law, taking into account the limitations of PENA's liability as stipulated in this provision.

Release of Additional Liability
The User hereby releases PENA from all legal claims arising out of:

• Abuse of the app by other users
• Illegal content sent between users
• Losses due to the user's own fault

Applicability & Changes to Terms

PENA reserves the right to change, update, or adjust the provisions of this Applicable Law & Dispute Resolution at any time.

Changes will take effect from the moment they are published in the application or official PENA platform.

By continuing to use the application after the changes are made, the user is considered to have agreed to all the updated terms.

14. Official Contact

For legal questions or violation reports:

📩[email protected]

Final Statement

PENA was created so that privacy does not depend on promises, but on systems that are technically impossible to access your data.

Your privacy remains completely in your hands. Forever.