What we collect, why, and what you can do about it.

Who we are

[Legal entity name], a [Delaware corporation] doing business as Plenary (“Plenary”, “we”, “us”), operates plenary.life and the Plenary application (together, the “Service”). Plenary is grant software for nonprofits: it maps the funding an organization can reach, scores its readiness, and drafts application materials for the organization to review and submit.

For most of what this policy describes we are the controller of your personal information. When we handle information inside an organization’s workspace on that organization’s instructions, we act as its processor — section 07 explains the difference and what it means for you.

Registered address: [Street address, City, State ZIP, Country]. Privacy questions: [privacy@plenary.life]. [If Verdex or another affiliate is a separate legal entity that processes data for the Service, name it here and describe its role.]

The short version

The summary is a guide. If it and the full policy ever disagree, the full policy applies.

Information we collect

Information you give us

• Account details. Name, work email address, password, and role. [Add any optional fields you collect, such as a phone number or photo.]
• Organization profile. Legal name, EIN or registration number, mission, programs, budget and revenue, staffing, governance, geography, and funding history — the intake behind the Mini Report and Full Report. [Adjust the list to match the intake.]
• Customer Content. Documents, past applications, letters of intent, budgets, board lists, funder correspondence, and anything else you upload, connect, or type into the Service.
• Communications. Support requests, survey answers, and feedback you send us.
• Billing details. Billing name, address, and plan. Card numbers go directly to our payment processor, [Stripe], and are not stored by us. [Confirm against your checkout integration.]

Information collected automatically

• Usage data. Pages viewed, features used, searches run, matches saved, drafts generated, and the timestamps of each.
• Device data. IP address, browser and operating system, screen size, language, and the page that referred you.
• Cookies and similar technologies. Described, with an opt-out, in our Cookies and data policy.

Information from other sources

• Public funder and grant data. [Name the public and licensed sources — for example IRS filings, foundation databases, government grant listings], used to build the funding map and your matches.
• Public information about your organization. [If the Service pre-fills or verifies profiles from public records such as Form 990 filings or state registries, describe that here and note that the user can correct it; otherwise delete this bullet.]
• Integrations you connect. [For example Google Workspace, Microsoft 365, or an accounting or CRM tool.] We receive only the data you authorize, and you can disconnect an integration at any time.
• Your team. When a colleague adds you to an organization’s workspace, they give us your name and email address.

How we use it, and our legal basis

Where the GDPR or UK GDPR applies, we need a legal basis for each use. The table shows the basis we rely on. If you are outside the EEA, UK, and Switzerland, the purposes still apply; the legal-basis column is there for completeness.

We do not use your information to make decisions with legal or similarly significant effects on you without a person involved. Readiness scores and match rankings are recommendations you can act on or ignore.

AI and your content

Plenary uses large language models to score readiness, rank matches, and draft application materials. This section says exactly what that means for your information.

• What is sent to a model. Relevant parts of your organization profile and Customer Content are sent to model providers that act as our processors: [Anthropic / OpenAI / other — list each in your subprocessors page]. They may process it only to return a result to us.
• No training on your content. Our agreements with those providers prohibit them from using your content to train or improve their models. [Confirm this against each provider’s current API or enterprise terms before publishing.]
• Not used for other customers. We do not use Customer Content to train models that serve other customers. We may use de-identified, aggregated data — never a document, never a name — to improve how Plenary scores and matches. [Confirm this is your policy. If you fine-tune on customer content, rewrite this bullet.]
• Always labelled. Anything the model produced is marked as drafted by Plenary and kept visibly separate from your own words.
• You review, you submit. Drafts can be wrong, and figures can be misread. Check every claim before it goes to a funder. Nothing leaves the Service unless you export or send it.

How we share it

We share personal information only in the ways below. We do not sell it, we have not sold it in the preceding twelve months, and we do not share it for cross-context behavioral advertising. [Confirm — an advertising pixel can count as “sharing” under CCPA.]

• Service providers. Companies that host the Service, run the models, process payments, deliver email, provide analytics, and run our support desk — for example [AWS / Vercel], [Stripe], [email provider], [analytics provider]. Each is bound by contract to use the data only to provide its service to us. The current list is at [link to subprocessors page].
• Your organization. Admins and members of your organization’s workspace can see the profile, content, and activity inside it, according to their roles in the workspace.
• Funders and other third parties, at your direction. Only when you export, download, connect, or send something. Plenary never submits an application on your behalf.
• Legal and safety. When the law requires it, to enforce our Terms, or to protect the rights, property, or safety of Plenary, our users, or others.
• Business transfers. As part of a merger, acquisition, financing, or sale of assets. We will tell you before your information becomes subject to a different privacy policy.
• With your consent. Anything else, only if you agree to it first.

Organizations and team members

Most people use Plenary through an organization’s workspace. The organization decides what goes into that workspace and who can see it, so for that information the organization is the controller and we are its processor. We handle it under our agreement with the organization and on its instructions.

In practice this means your organization’s admin can access, export, and delete workspace data, including content you created. [Confirm admins have these controls.] If you want to exercise a right over that data, ask your admin first. We will help them respond.

For information we decide how to use ourselves — account security, billing, product analytics, marketing to you — we are the controller, and everything in this policy applies directly.

Cookies and tracking

We use a small number of cookies and similar technologies. Essential ones keep you signed in and the Service secure. Optional ones remember preferences, measure how the Service is used, and, if you allow them, support our own marketing. Each category, and how to turn the optional ones off, is set out in our Cookies and data policy.

We honor the Global Privacy Control browser signal as an opt-out of sale, sharing, and targeted advertising. We do not respond to browser Do Not Track signals, which have no agreed meaning.

How long we keep it

We keep personal information only as long as we need it for the purposes above, then delete or de-identify it. The periods below are our defaults; a legal hold or a dispute can extend them.

How we protect it

We use administrative, technical, and physical safeguards designed to protect personal information, including [keep the ones that are true: encryption in transit and at rest, role-based access, multi-factor authentication for staff, access logging, vendor review]. [State your SOC 2, ISO 27001, or other audit status here, or remove this sentence.]

No system is perfectly secure. If a breach affects your personal information, we will notify you and any regulator the law requires, without undue delay. Security concerns can be reported to [security@plenary.life].

Where it is processed

Plenary is based in the United States and stores data there, in [hosting region]. If you use the Service from the EEA, the UK, or Switzerland, your information is transferred to the United States and to the countries where our service providers operate.

For those transfers we rely on the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum, and equivalent Swiss safeguards, in our agreements with each provider. [If certified under the EU–US Data Privacy Framework, say so here; otherwise delete this sentence.] You can ask us for a copy of the safeguards that apply.

Your rights

Wherever you are, you can access, correct, export, and delete your personal information, unsubscribe from marketing, and manage cookies. Some of this you can do yourself in Settings [confirm which self-service controls exist]; for anything else, email [privacy@plenary.life].

We verify requests by confirming the email on the account. We respond within 30 days, or 45 where a US state law allows it, and we will tell you if we need longer. There is no charge unless a request is plainly excessive. We never treat you differently for exercising a right. An authorized agent may make a request for you with your written permission.

If you are in the EEA, the UK, or Switzerland

Under the GDPR and UK GDPR you also have the right to restrict processing, to object to processing based on legitimate interests or used for direct marketing, to withdraw consent at any time without affecting what came before, and to lodge a complaint with your supervisory authority. We would rather hear from you first, but that is your choice.

EU representative: [Name, address, and contact of your Article 27 representative, if required]. UK representative: [Name, address, and contact, if required].

US state privacy rights

If you live in California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, or another state with a comprehensive privacy law, this section is your notice of the categories of personal information we collect and the rights you have. It should be read with sections 03, 04, 06, and 09.

* If you turn on marketing cookies, the provider behind them may receive identifiers, which some state laws treat as “sharing”. Turn them off in the preference center, or send a Global Privacy Control signal, and no sharing takes place.

We use sensitive personal information only to provide the Service and secure your account, never to infer characteristics about you. We do not sell personal information, we do not offer financial incentives in exchange for it, and we do not knowingly sell or share the personal information of anyone under 16.

Your rights under these laws

• To know what personal information we collect, use, disclose, and the sources and purposes involved.
• To access it, correct it, delete it, and receive a portable copy.
• To opt out of sale, sharing, targeted advertising, and profiling with significant effects — we do none of these by default, and the preference center and Global Privacy Control cover the rest.
• To limit the use of sensitive personal information.
• Not to be discriminated against for exercising a right.
• To appeal a decision on your request by replying to it or writing to [privacy@plenary.life]. If we still decline, we will tell you how to contact your state attorney general.

California residents may also ask, under the Shine the Light law, about disclosures of personal information to third parties for their direct marketing. We make none. Nevada residents: we do not sell covered information as that law defines it.

Children

The Service is for organizations and the people who work with them. It is not directed to anyone under 18, and we do not knowingly collect personal information from anyone under 13, or under 16 where the GDPR applies. If you believe we have, tell us and we will delete it.

Links and integrations

The Service links to funder websites and grant portals, and can connect to third-party tools you choose. Those services have their own privacy policies, and what you do there is governed by them, not by this one. Read them before you connect an account or submit an application.

Changes to this policy

We will update this policy as the Service and the law change. Every version carries its effective date at the top. For a material change we will email account owners or show a notice in the Service at least [14] days before it takes effect. Continuing to use the Service after that date means the new version applies.

Contact