Terms of Service

Version 3.1 · Unpublished draft · No effective date has been set.

NOT READY FOR PUBLICATION. Every field marked ACTION REQUIRED must be completed by the owner and the complete set reviewed by Dutch/EU counsel before release. Version 2.2 has not been changed or replaced.

1. About Pennny and these Terms

These Terms of Service govern your use of the Pennny web application at app.pennny.ai (and the site at pennny.ai) and the services made available through it. They form a contract between you and Pennny B.V., registered with the Dutch Chamber of Commerce under number 42159747, with registered office at Sydneystraat 6, 1175 RN Lijnden, the Netherlands ("Pennny", "we", "us" or "our"). VAT number: [ACTION REQUIRED: VAT number].

Pennny is an AI-assisted money advocate. It can help you discover possible refunds, compensation, waived charges and other financial recovery opportunities; organise evidence; prepare communications; and monitor the progress of a case. It also helps with spending, bills, reminders, price comparison and travel. Pennny does not guarantee that an opportunity is legally valid or that any recovery will occur.

By creating an account, starting your free week, sending a claim or otherwise using the service, you agree to these Terms. If you do not agree, do not use Pennny.

2. Who may use Pennny

You may use Pennny only if:

• you are at least 18 years old;
• you are legally able to enter into a contract;
• you live in the Netherlands;
• you use Pennny for your own consumer matters, unless Pennny expressly agrees otherwise;
• the information and evidence you provide are accurate to the best of your knowledge; and
• your use is lawful.

Pennny is available to residents of the Netherlands only. Being able to reach the site from another country does not mean that Pennny supports that country's laws, claims or remedies.

3. Important definitions

Term	Meaning
Account	Your personal Pennny account.
Opportunity	A specific potential refund, compensation, reimbursement, waived charge or other recoverable value identified by Pennny.
Sent Claim	A claim that Pennny prepared and that you approved to be sent, including a claim sent during your free week.
Connected Source	A data source that you choose to connect: Gmail, Outlook or a bank (through Tink).
Sending Date	The date on which a Sent Claim is sent.
Qualifying Recovery	Money, a voucher, account credit or another measurable financial benefit that a company actually pays or gives you because of a Sent Claim.
Qualifying Waiver	A charge that has already been levied and that is demonstrably cancelled, reversed or refunded because of a Sent Claim. A charge you would have paid in future but will now not be charged — for example a subscription Pennny cancels for you — is not a Qualifying Waiver and carries no fee.
Success Fee	30% of the amount of a Qualifying Recovery or Qualifying Waiver that you actually receive, plus 21% VAT on the fee (36.3% in total).

4. Forming the contract

The contract is formed when you accept these Terms through the application or complete the set-up flow that refers to them. The set-up page shows the total consumer price, including VAT, before you are bound.

Separate permissions are needed for each connected inbox, for bank access, for payments, for health details in an insurance claim and for any other connected service. Accepting these Terms is not the same as giving those permissions.

5. The free week, the price and renewal

5.1 The free week

You get 7 days free, with everything unlocked. We collect your payment details when you start; the first charge is on day 8 unless you cancel before then. There is no separate free tier: after the free week, Premium is what keeps starting new claims and Ask available.

5.2 Premium

Plan	Price excluding VAT	Total you pay (21% VAT)	Renewal
Premium monthly	EUR 9.95	EUR 12.04 per month	Renews monthly until cancelled

There is one price and no annual plan. All totals shown to consumers include VAT. Pennny charges Dutch VAT at a fixed 21% on the subscription and the success fee. Pennny is available to residents of the Netherlands only. The set-up page is authoritative for the total charged at the time of purchase.

5.3 Cancelling, and what happens if you stop paying

You can cancel (opzeggen) at any time in your account settings. Cancelling stops the next renewal and your access runs to the end of the period you have paid for. It is separate from withdrawing from the contract (section 13).

If you cancel your free week, or your subscription is unpaid, claims Pennny already sent keep going and fees stay owed. Starting new claims, and Ask, are locked until payment. Your data is kept under the normal retention rules in the Privacy Policy.

5.4 Price changes

Pennny notifies any rise in the subscription price at least 30 days before it takes effect, by email and in the app. You may cancel free of charge before the effective date. Pennny does not raise the price within the first 3 months of your contract. A price change does not alter the Success Fee percentage for a Sent Claim.

6. What Pennny provides

Depending on the supported claim category, Pennny may:

• scan information you choose to provide or connect;
• identify and explain possible Opportunities;
• organise documents, messages and transactions as evidence;
• estimate possible value and deadlines;
• draft letters, forms or responses;
• send material only where you have clearly approved the exact text;
• track replies, deadlines, offers and outcomes; and
• provide status updates, reminders and support.

Pennny uses AI and automated analysis. Outputs may be incomplete or wrong. You must review important facts, dates, recipients, amounts and documents before approving a consequential action. Pennny will not accept a settlement, waive a right, make a binding statement, sign a legal document or send a consequential communication without the approval required in the relevant flow.

Pennny is not a law firm, financial adviser, insurer, bank or public authority. General information and AI-generated material are not a substitute for professional advice where your situation requires it.

7. Success Fee

7.1 Amount and trigger

For a Sent Claim, the Success Fee is 30% of what the company pays you, plus 21% VAT (36.3% in total), calculated on the amount you actually receive. If you receive only part of what was claimed, the fee is calculated on the part you receive. On a recovery of EUR 400 the fee is EUR 120.00 plus EUR 25.20 VAT at 21%, so EUR 145.20 is charged and you keep EUR 254.80.

No Success Fee is due merely because Pennny identifies an Opportunity, prepares a draft or predicts a result. A fee becomes due only when a Qualifying Recovery or Qualifying Waiver has actually occurred. If nothing comes back, you pay nothing.

Cancellations and avoided charges are included in Premium. Where Pennny cancels a subscription or contract for you so that you will not be charged in future, or a fine is cancelled before you paid it, no Success Fee arises.

7.2 The company pays you, not Pennny

The company pays you directly. Pennny never holds your money and never receives your recovery. The payout is established by a matching credit on your connected bank account or by an email from the company confirming that it paid you. The fee is owed on Sent Claims during your free week too.

7.3 Twelve-month period

The Success Fee is owed if the payout is established within the 12-month period that starts on the Sending Date, including after you cancel your subscription. A payout established later carries no fee.

Self-submitted cases: a claim you file yourself that Pennny did not find starts the 12-month period only when you send it through Pennny.

At your request, including after cancellation, Pennny will provide a retrievable record of the Sending Date, the claim reference, the fee disclosure and the evidence on which a fee is based.

7.4 No double collection

Pennny will never collect a Success Fee twice for the same Sent Claim or the same realised value. If different claims overlap, Pennny will explain the calculation and remove any duplicate value.

7.5 Calculating value

For money paid to you, value is the amount you received for that claim. For a charge you have already paid that is subsequently cancelled, reversed or refunded, value is the amount returned to you. Vouchers, account credit and comparable non-cash benefits are included at the face value the provider confirms, and only where Pennny showed you that value before you were charged.

7.6 Telling Pennny about an outcome, and how Pennny learns of one

You must tell Pennny within 14 days after you become aware of a Qualifying Recovery or Qualifying Waiver for a Sent Claim, and provide reasonable evidence of the amount. This duty remains during the 12-month period after cancellation.

Pennny may also learn of an outcome itself, from a matching credit on a connected bank account, from the replies to claims it sent for you, or from a message in a connected inbox. If the amount does not match what was expected, it stops for review instead of becoming an invoice. If a company says it paid you but the money never arrived, tell Pennny: the fee is cancelled and any planned debit is paused while it is checked.

You can object to Pennny using your mailbox this way. See the Privacy Policy — objecting stops Pennny recording payments from your mail, and changes nothing else about your account or your claims.

7.7 Notice before collection, and disputing a Success Fee

Once a payout is established, Pennny collects the fee by SEPA direct debit under the mandate you gave at set-up, and sends you a notice at least 2 days before the debit, stating the amount, the date, the Creditor Identifier and the mandate reference. The notice has a "This is wrong" button that pauses the debit while the matter is checked. You may also dispute the amount or eligibility using [ACTION REQUIRED: billing mailbox]. Pennny pauses a disputed collection while it investigates, unless immediate action is required by law or to correct fraud.

8. Your role as claimant

You remain the claimant and owner of your claim. Pennny may act only within the permission you grant for a specific step. You authorise Pennny to process and organise the information needed for the service and, where you explicitly approve it, to send a communication in your name. Pennny may not settle, abandon, transfer or materially change a claim without your express approval.

9. Your responsibilities

You agree to:

• provide complete and accurate information;
• keep originals where they may be required;
• review drafts and recipient details before approval;
• avoid misleading, fabricated, altered or unlawfully obtained evidence;
• respond to reasonable verification requests;
• protect your login credentials and device; and
• notify Pennny promptly of a recovery, reversal, settlement or chargeback for a Sent Claim.

Pennny may suspend a case if the information appears unreliable, unlawful or abusive.

10. Connected sources

10.1 Gmail and Outlook

Connecting an inbox is optional and uses a separate consent and OAuth flow. On the first connection Pennny looks back up to 36 months, then reads only new mail. You can disconnect at any time. Disconnecting stops new access; findings and claims already made stay, and data already synced is deleted after 30 days unless it is evidence on an open claim. Reconnecting inside those 30 days resumes where you left off.

10a. Your bank, through Tink

Connecting a bank is optional. Pennny reads your accounts and transactions through Tink, read-only, for up to 180 days per consent, after which your bank asks you again. On the first connection Pennny asks for up to 36 months of transactions; some banks give less. Pennny uses your transactions to show your spending, to warn you before money leaves, and to find claims such as a double charge, a charge after you cancelled, or a refund that never arrived. Transactions that point to health, a trade union, religion or politics are sorted by fixed rules only and are never sent to an AI service. You can disconnect at any time; data already synced is deleted after 30 days unless it is evidence on an open claim.

10b. Price comparison and travel

Telecom. Pennny compares public prices for telecom plans, ranks them, and can email providers on your behalf to ask for a quote or a better price, with your approval.

Insurance. For insurance, Pennny only links to licensed comparison sites, such as Independer and Pricewise. Pennny does not compare, rank, recommend or request quotes for insurance, and does not advise on insurance.

Travel. Pennny shows flight, train and hotel options from partners and sends you to the partner to book. Pennny does not book travel or sell insurance or telecom contracts.

How results are ranked, and commission. Pennny shows how a list is ranked next to every list: for comparison, "Similar quality first, then price."; for travel, "Results are ranked by price.". Separately, where a link is an affiliate link: for comparison, "Pennny may earn a commission if you switch through these links. It never changes the order."; for travel, "Pennny earns a commission if you book through these links."; for insurance links, "Pennny may earn a commission if you take out a policy through these links." Prices are estimates from public prices collected on the date shown; check on the provider's site.

11. How subscription and Success Fee payments are collected

11.1 Payment provider

Pennny uses Stripe as its payment service provider. Stripe may process payment details, mandates, transaction status and fraud-prevention information under its own terms and privacy notice, and is a controller for some of its own purposes (see the Privacy Policy).

11.2 Your subscription

At set-up you give payment details through Stripe: a SEPA mandate on your IBAN, plus a card if you prefer. The subscription is charged from day 8 to the payment method you gave. A card pays only the subscription; Pennny's fee is collected by SEPA direct debit from your IBAN.

11.3 Success Fee collection

Where a company pays you directly — the only case — no recovery money passes through Pennny. Once the payout is established, Pennny sends you an invoice and the notice in section 7.7, and collects the fee by SEPA direct debit after that notice.

11.4 If a payment fails

Membership. Pennny retries a failed membership payment itself, on days 3, 7 and 14 counted from the first failure, each time with an email and a payment link. Your membership is marked past due from the first failure. After a 3-day grace period, starting new claims and Ask are locked (section 5.3). After the failed payment on day 14, the subscription is cancelled. Claims already sent continue.

Fees. If a fee debit fails, Pennny sends a notice and a card payment link, and tries once more after 7 days by SEPA with a fresh 2-day notice. If the invoice is still unpaid 14 days after the due date, Pennny sends a 14-day letter (veertiendagenbrief); statutory collection costs are charged only after that letter, and only the statutory amount. Pennny does not hand collection to an agency. If the invoice is still unpaid 30 days after the due date, starting new claims and Ask are locked. After that your existing claims, documents and account data remain accessible; your account is not blocked and claims already under way continue. A dispute or chargeback pauses these steps.

12. SEPA direct debit

If you give a recurring SEPA Core mandate, you authorise the identified creditor and your bank to collect your subscription and the Success Fee. Pennny sends the notice described in section 7.7 at least 2 days before each fee debit. The mandate, notice and collection use the Creditor Identifier [ACTION REQUIRED: SEPA Creditor Identifier] and a Unique Mandate Reference.

You can ask your bank to refund an authorised SEPA Core debit within 8 weeks of the debit date, no questions asked, and an unauthorised debit for up to 13 months. A refund right does not by itself decide whether the underlying invoice was owed; if the amount remains valid Pennny may seek payment by a lawful method, but it will not obstruct your statutory refund rights.

13. Withdrawal from the contract

13.1 Fourteen-day right

When you sign up online as a consumer, you have 14 days to withdraw from the contract without giving a reason, subject to statutory exceptions.

13.2 Withdraw from contract, online

Pennny provides an online function, Withdraw from contract, at Settings → Membership. It is labelled for withdrawal, separate from cancelling, and includes a confirmation step. When you confirm, you get an immediate confirmation on screen and by email. Withdrawing stops all future subscription payments at once.

13.3 Starting during the withdrawal period

When you start your free week you ask Pennny to start the service immediately, and you acknowledge that you lose your right of withdrawal once the service has been fully performed. Any amount you have already paid is refunded within 14 days of your withdrawal, pro rata for the days after the free week when you asked the service to start immediately. Verify in counsel review.

13.4 What withdrawal does not do

Withdrawal does not cancel the Success Fee on claims Pennny already sent for you. Verify in counsel review.

13.5 Other ways to withdraw

You can also send an unambiguous statement to [ACTION REQUIRED: withdrawal mailbox], or use the model withdrawal form (Directive 2011/83/EU, Annex I(B)). Verify in counsel review.

To Pennny B.V., Sydneystraat 6, 1175 RN Lijnden, the Netherlands, [ACTION REQUIRED: withdrawal mailbox]: I hereby give notice that I withdraw from my contract for the provision of the following service: Pennny Premium. Ordered on: ... Name of consumer: ... Address of consumer: ... Signature of consumer (only if this form is notified on paper): ... Date: ...

14. Refunds, reversals and corrected outcomes

Refunds are governed by the Pennny Refund Policy and mandatory consumer law. If a provider reverses a recovery or reinstates a charge, Pennny will recalculate the Success Fee on the final retained value. Any overpaid amount will be refunded or credited without undue delay after verification.

Fraud, chargeback abuse or false evidence may result in suspension while Pennny investigates.

15. Signing in and account security

You sign in with a password or with Google. You are responsible for keeping your login methods secure. Tell Pennny immediately if you suspect unauthorised access.

16. Acceptable use

You must not use Pennny to:

• make a claim you know is false;
• fabricate, manipulate or unlawfully obtain evidence;
• impersonate another person;
• harass, threaten or deceive a recipient;
• bypass security, access controls or rate limits;
• introduce malware or hostile prompts;
• reverse engineer the service except where law expressly allows it; or
• violate another person's privacy or intellectual-property rights.

17. Intellectual property

Pennny and its licensors own the application, software, designs, models, workflows and branding. Subject to these Terms, Pennny gives you a limited, personal, revocable and non-transferable right to use the service.

You retain ownership of materials you provide. You give Pennny the limited rights needed to host, process, analyse and use them to provide, secure and improve the service as explained in the Privacy Policy. Pennny will not use Google user data to train general-purpose AI models.

18. Third-party services

Pennny depends on third parties including Google, Microsoft, Tink, Stripe, hosting, communications and AI providers. Their own terms may apply to their services. The Privacy Policy lists each provider and its role. Pennny remains responsible for choosing and managing processors as required by data-protection law, but it cannot control an independent third party's service availability.

19. Privacy and technologies

The Privacy Policy explains how Pennny processes personal data. The Cookie and Similar Technologies Policy explains the strictly necessary technologies Pennny uses (no analytics). Inbox and bank access have separate consent documents.

20. AI transparency and human control

Pennny uses AI to classify information, detect possible Opportunities, organise evidence, categorise spending, estimate relevance and generate drafts. You are told when you are dealing with Pennny's AI: in Ask and when Pennny drafts a letter for you. Pennny does not make decisions based solely on automated processing that produce legal or similarly significant effects for you. Where human review or intervention is required, the application provides a route to request it.

21. Availability and service changes

Pennny may update, improve, suspend or discontinue features. Pennny will give reasonable notice where a change materially reduces a paid service, unless urgent action is needed for security, law or a third-party dependency. Mandatory consumer rights remain unaffected.

22. Suspension and termination

Pennny may suspend or terminate access for serious or repeated breach, fraud, security risk or unlawful use. Where reasonable, Pennny will explain the reason and allow you to respond.

After termination, provisions that logically need to survive remain in effect, including payment duties for Sent Claims, evidence access under section 7.3, privacy obligations, dispute resolution and intellectual-property protections.

23. Liability

Nothing in these Terms excludes or limits liability where doing so is prohibited, including liability for intent or deliberate recklessness, death or personal injury caused by negligence, fraud, or mandatory consumer rights.

Pennny is responsible for direct and reasonably foreseeable loss caused by its breach of these Terms or failure to use reasonable care. Pennny is not responsible for loss caused by inaccurate information you supplied, an unauthorised instruction from your account that Pennny could not reasonably detect, or a third party outside Pennny's control, except where Pennny failed in a legal duty to select, instruct or supervise that party.

Pennny does not guarantee a successful claim, recovery amount, response time from a recipient or uninterrupted service. This does not reduce any remedy you have where the service does not conform to the contract.

24. Complaints and disputes

Send a complaint to [ACTION REQUIRED: complaints mailbox]. Pennny will acknowledge it promptly and aims to provide a substantive response within 30 days. If you are not satisfied, you may bring the matter before the competent Dutch court. Pennny is not affiliated with a dispute committee.

For general Dutch consumer-law information you may contact ACM ConsuWijzer. For privacy complaints you may contact the Autoriteit Persoonsgegevens.

These Terms are governed by Dutch law, without depriving you of mandatory protections that apply in your country of residence. Disputes may be brought before the competent Dutch court or another court that must be available to you under mandatory consumer law.

25. Changes to these Terms

Pennny may update these Terms for legal, security, operational or product reasons. Material changes will be notified in advance where required. Pennny will not retroactively enlarge the Success Fee, covered claims or the 12-month period for a claim you have already sent without your express agreement.

26. General terms

If a provision is invalid, the rest remains in effect. Pennny may transfer this contract as part of a merger, financing or sale only where your rights are not reduced and applicable law permits it. A delay in enforcing a right is not a waiver.

27. Contact

Pennny B.V. KvK: 42159747 Registered address: Sydneystraat 6, 1175 RN Lijnden, the Netherlands Support: [ACTION REQUIRED: support mailbox] Legal notices: to the registered address above.

---

Appendix A — Fee schedule

Item	Price excluding VAT	VAT treatment
Premium monthly (there is no annual plan)	EUR 9.95	21% added on top — EUR 12.04 charged
Free week	EUR 0	7 days, everything unlocked; first charge on day 8
Sent Claim	30% of what the company pays you	21% added on top of the 30% — 36.3% in total
Cancelling a subscription or contract for you	Included in Premium	No fee

Appendix B — Calculation examples

Example 1 — a company pays you. A company pays EUR 400 into your own account. The Success Fee is EUR 120.00 plus EUR 25.20 VAT, so Pennny charges EUR 145.20. You keep EUR 254.80.

Example 2 — a charge already paid, then reversed. You were charged EUR 200 in error and Pennny gets it refunded. The EUR 200 returns to you. The Success Fee is EUR 60.00 plus EUR 12.60 VAT, so Pennny charges EUR 72.60.

Example 3 — a subscription cancelled. Pennny cancels a EUR 50 per month subscription you could not cancel yourself. You will not be charged again. There is no Success Fee — cancellations are included in Premium.

Example 4 — a voucher. An airline settles with a EUR 400 voucher it confirms in writing. The Success Fee is EUR 120.00 plus EUR 25.20 VAT, so Pennny charges EUR 145.20. The voucher is yours in full.

Example 5 — partial reversal. A recovery of EUR 500 is later reduced to EUR 300. The final Success Fee is EUR 90.00 plus EUR 18.90 VAT. If Pennny previously collected EUR 181.50, it refunds or credits EUR 72.60 after verification.