Privacy Policy

Effective: January 1, 2026
Operator: FrenzyPenguin Media (contact@frenzypenguin.media)
Jurisdiction: Belgium / European Union (GDPR-aligned)

1. Overview

This Privacy Policy describes how FrenzyPenguin Media (“we”, “us”, “the Operator”) processes personal data, communications, and digital artifacts through the neohiro infrastructure (collectively “the System”). The System includes Brain, Heart, Mouth, Voicemail, userdata, and all associated tools.

The System is operated exclusively by FrenzyPenguin Media. There is no third-party data broker relationship.

2. The data we process

2.1 Conversation and message data (only when you interact)

When you send a message, voice note, or document to the assistant:

No message content is ever sold or shared with third parties.

2.2 Authorisation and identity

When you authenticate (GitHub OAuth, voice PIN, etc.):

• GitHub username — stored hashed (sha256 truncated), used to identify your account
• Email address — optional, stored only if you provide it
• IP address — hashed immediately (sha256), never stored raw
• GeoIP country — derived from IP, used only for anomaly detection
• Authentication history — for security audit, kept for 12 months

2.3 Ghost and stranger visitor data

Visitors who have not authenticated are treated as ghosts or strangers:

• Ghosts — never contacted, hashed identifiers, observations are TTL’d (90 days)
• Strangers — GeoIP-only, may receive automated triage response, hashed identifiers
• Raw IPs are never persisted in ghost or stranger records
• Observations are public-data only (mentions, third-party handles)

2.4 Hearsay and relations

The hearsay cache stores derived attributes about entities that have a double-confirmed relation with you. Only low-bandwidth data is included:

• role, last_seen_bucket, social_boost_band, activity_bucket, presence, mutual_count, tag_set, public_credit_count

No PII is stored in the hearsay cache — no emails, IPs, addresses, or full names.

2.5 Cloud memory and preference profiles

When you opt in to cloud memory, we store:

• Conversation summaries — to maintain context across sessions
• Preference profiles — dietary, scheduling, project, contact preferences
• Encrypted vault entries — credentials, payment cards, API keys (AES-256-GCM)
• Contact relations — your family, friends, co-admins, teams (with their consent)

All vault entries are stored encrypted with age. You may delete any item at any time via the vault management interface.

3. Legal basis for processing

We process your personal data on the following legal bases under GDPR:

• Contract — when you sign up and use the service
• Consent — when you opt in to cloud memory or specific features
• Legitimate interest — fraud prevention, security monitoring
• Legal obligation — when required by law

4. Cryptographic security

4.1 Encryption at rest

Unique IVs — every encryption uses a fresh 96-bit random IV. Authentication tags — every encrypted blob is verified before decryption.

4.2 Encryption in transit

• TLS 1.3 — for all LLM API and database traffic
• Forward secrecy — X25519 ephemeral keys
• HSTS — for all public endpoints

5. Administrative access and oversight

[!IMPORTANT] Owner oversight notice: The Primary Administrator (God Admin / Owner) retains full administrative access to all underlying databases, conversation transcripts, error logs, and automated triage reports. This access is for system security, operational integrity, fraud prevention, and quality improvement.

Day-to-day user data is cryptographically and logically isolated between individual user accounts. However, complete privacy from the system operator is not guaranteed or implied by the use of this service.

6. Stranger contact and triage

Incoming messages from unrecognized numbers or identifiers undergo automated triage:

1. Automated reception — the assistant delivers a standard professional auto-reply
2. OSINT verification — best-effort, open-source intelligence on the contact
3. Admin escalation — a structured triage summary is sent to the God Admin

Unrecognized contacts are never granted administrative access, memory inspection, or repository tools.

7. Data retention

8. Right to erasure

You have the right to delete your data at any time:

• Self-service — use the vault management interface to delete entries
• Request — email contact@frenzypenguin.media with your account ID
• Response time — within 30 days, typically 7 days
• Scope — we delete all data linked to your account, except:
  • Aggregated, non-identifying analytics
  • Legal compliance records (where required)

9. Data sharing

We do not sell your data. We do not share your data with third parties for marketing.

Limited sharing only occurs:

• With your explicit consent (e.g., integration with third-party tools you configure)
• To comply with legal obligations (court orders, lawful requests)
• To protect the System (abuse prevention, fraud detection)
• With service providers (LLM inference, cloud hosting) who are contractually bound

10. International transfers

The neohiro infrastructure is operated in the European Union. If data is transferred outside the EU, we use:

• Standard Contractual Clauses (SCC) approved by the European Commission
• Adequacy decisions — only to countries with equivalent data protection
• Encryption — all data is encrypted in transit and at rest

11. Children’s privacy

The System is not intended for users under 16 years of age. We do not knowingly collect data from children. If we learn we have collected data from a child, we will delete it promptly.

12. Your rights (GDPR)

If you are in the EU, you have the right to:

• Access — request a copy of your data
• Rectification — correct inaccurate data
• Erasure — request deletion
• Restrict processing — limit how we use your data
• Data portability — receive your data in a machine-readable format
• Object — to certain types of processing
• Withdraw consent — at any time, without affecting prior processing

To exercise any of these rights, contact contact@frenzypenguin.media.

13. Organ-failure diagnostics

We use medical analogies throughout the System. This is for readability and alert fatigue reduction, not because we are insensitive to medical issues. When a component fails, we describe it as organ failure. The recovery process is regeneration. The abuse filter is the immune system. The doctor is paramedic services. The GH Actions fallback is the sepsis protocol.

This is a deliberate UX choice so engineers and operators can quickly diagnose system state without jargon fatigue.

14. Changes to this policy

We may update this Privacy Policy to reflect changes in our infrastructure, legal requirements, or business practices. Changes will be posted on this page with an updated effective date. We will notify you via the assistant when material changes occur.

15. Contact

For questions about this Privacy Policy or your data:

• Email: contact@frenzypenguin.media
• GitHub: https://github.com/neohiro
• Mailing address: FrenzyPenguin Media, Belgium

Last reviewed: 2026-01-01