
September 9, 2026. Written in SIG Lite / CAIQ style: one factual assertion per row, answered Yes, No, or [VERIFY WITH CHRIS] where the audit files and code could not confirm an answer. Every “Yes” and “No” below is backed by a source — either a citation in the page source (view source to see the HTML comment above each row) or a direct link. Nothing here is guessed. A summary count is at the end.
| # | Question | Answer | Detail |
|---|---|---|---|
| 1.1 | Is the operating company’s legal name, structure, and jurisdiction disclosed? | Yes | Fugio Consulting, LLC, an Ohio limited liability company, based in Granville, Ohio. |
| 1.2 | Is the company’s headcount disclosed? | [VERIFY WITH CHRIS] | Not stated in code or the audit files. The site footer credits Chris Graham as CEO; whether the company is a single-operator business or has additional staff/contractors with system access is not confirmed here. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 2.1 | Is the hosting provider named? | Yes | Google Cloud Platform (cloud.google.com) hosts the Service’s servers, databases, and application logs. |
| 2.2 | Is the current data region disclosed, and kept current? | Yes | The Service runs in the United States (Google Cloud region us-east5, Columbus, Ohio); the current region is also published at petethepigeon.com/trust. |
| 2.3 | Does the hosting provider hold independent security certifications and publish a DPA? | Yes | Google Cloud is SOC 2 Type II, SOC 3 and ISO 27001 certified, and offers a Cloud Data Processing Addendum (cloud.google.com/terms/data-processing-addendum). |
| # | Question | Answer | Detail |
|---|---|---|---|
| 3.1 | Is data encrypted in transit? | Yes | All traffic is served over TLS, observed as TLS 1.3, terminated at the Service’s own web server. No plain-HTTP path exists to the application. |
| 3.2 | Is data encrypted at rest? | Yes | Google Cloud encrypts persistent disk storage at rest by default. [VERIFY WITH CHRIS: confirm the VM disks are standard Persistent Disk/Hyperdisk and no unencrypted volume holds user data] |
| # | Question | Answer | Detail |
|---|---|---|---|
| 4.1 | Is administrative access to production systems gated by authentication? | Yes | Every /admin route requires a bearer token or a signed admin session; there is no URL-query-token bypass. |
| 4.2 | Is the set of people holding admin credentials disclosed and restricted? | [VERIFY WITH CHRIS] | The code enforces a single admin token/session mechanism, but who holds that token, how many people, and how it is rotated is an operational fact not present in the repo. |
| 4.3 | Is multi-factor authentication (MFA) enforced on the accounts that control infrastructure and vendor services (Google Cloud, GitHub, Resend, Chargebee, Microsoft)? | [VERIFY WITH CHRIS] | Not evidenced either way in the repo or the audit files; this is an account-configuration fact outside what code review can confirm. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 5.1 | Do end users (office staff) authenticate via a credentialed mechanism rather than open access? | Yes | A signed, stateless session cookie issued via magic-link email sign-in, and/or a personal connector key issued to the account. |
| 5.2 | Does the Claude/ChatGPT connector require per-account authentication? | Yes | A personal key (csq_) or OAuth token (csqo_, stored hashed) tied to the account; MCP traffic to Pete is relayed unread to capsquaregpt.com, which performs this check. |
| 5.3 | Does the Outlook add-in avoid sending the user’s mailbox credential to Fugio’s server? | Yes | Mailbox access uses Microsoft Graph via MSAL inside the pane; the access token stays in browser memory and every Graph call goes directly from the browser to graph.microsoft.com. The only Outlook-identity header Fugio’s server receives is the aide’s own mailbox address string. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 6.1 | Are hosting/application logs retention-limited rather than kept forever? | Yes | Application logs stay on the server in the system log, size-capped with the oldest lines dropped first, and are not copied into backups. Nightly database backups in Google Drive are deleted after 30 days. |
| 6.2 | Is full email content excluded from application logs? | Yes | With one disclosed, narrow exception: the first 600 characters of the draft Pete itself wrote (not the constituent’s incoming email) appear in the application log, kept 30 days. |
| 6.3 | Is the chat conversation log retention-limited? | Yes | 30 days, purged automatically by a daily scheduled job, except for accounts with zero retention turned on (Section 7.4). |
| 6.4 | Is there real-time security alerting/monitoring beyond application logs? | [VERIFY WITH CHRIS] | No monitoring/alerting tool or configuration was found in the repo or audit files; not confirmed either way. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 7.1 | Is a category-by-category data retention policy published? | Yes | Published at petethepigeon.com/privacy#retention; the same table is reproduced in the DPA (trust/dpa.html, Section 5) and in the vendor table below (Section 8). |
| 7.2 | Is retention enforced automatically, rather than relying on a person to remember to delete data? | Yes | A scheduled daily job purges conversations, the address-lookup cache, the embed demo log, and the email-form cache at 30 days, and free-trial counters at 7 days. |
| 7.3 | Can a customer obtain deletion of their data within a stated timeframe? | Yes | Write to hello@petethepigeon.com, or the admin erase tool for anything Pete stores locally under an email address. Completed within 30 days. |
| 7.4 | Can a customer (office) obtain zero retention going forward? | Yes | A per-account toggle: while on, no question text, history, or answer is written to Pete’s own conversation log for that account. This does not change what the underlying AI provider retains under its own policy (Section 9). |
| # | Question | Answer | Detail |
|---|---|---|---|
| 8.1 | Is a subprocessor list published? | Yes | Published today at petethepigeon.com/privacy; the dedicated petethepigeon.com/trust page (referenced by this DPA) was not yet live as of 2026-09-09 (confirmed 404). The same table is reproduced below. |
| 8.2 | Are customers given advance notice before a new subprocessor is added? | Yes | A 30-day advance-notice commitment is established in the DPA accompanying this questionnaire (trust/dpa.html, Section 5); posted to petethepigeon.com/trust. |
| Subprocessor | Data | Certification |
|---|---|---|
| Anthropic, PBC | Chat answers (Pro), drafts, summaries, Train Pete, email replies | Not retained by default; 30-day deletion in every case; DPA: anthropic.com/legal/data-processing-addendum |
| Google LLC (Gemini API) | Free-tier chat only | 55-day abuse-monitoring retention, not used to train models |
| Google LLC (Google Cloud Platform) | Hosting, databases, logs | SOC 2 Type II, SOC 3, ISO 27001 |
| Google LLC (Google Drive) | Nightly encrypted-in-transit database backup (deleted after 30 days) | SOC 2 Type II, SOC 3, ISO 27001 |
| Resend | Pete’s own email channel | SOC 2 Type II |
| Microsoft | Office.js; Graph calls stay browser-to-tenant | Customer’s own Microsoft tenant terms apply |
| Chargebee | Billing (name, email, status) | PCI DSS Level 1, SOC 2 Type II |
| Stripe, Inc. | Card processing | PCI Service Provider Level 1, SOC 2 Type II |
| GA / Google Ads / Meta / LinkedIn | Marketing-page visits only | n/a — never the pane, chat, or legal pages |
| # | Question | Answer | Detail |
|---|---|---|---|
| 9.1 | Are the specific AI model providers, and the account tier each serves, disclosed? | Yes | Anthropic (models claude-haiku-4-5 for drafts/summaries/Outlook micro-features, and claude-sonnet-4-6 for Pete Pro chat and Train Pete) serves every account for drafts/summaries/replies, and Pete Pro accounts for chat. Google’s Gemini API serves free-tier chat only. |
| 9.2 | Is customer content withheld from AI model training? | Yes | Not used to train models by Anthropic, Google, or Fugio. |
| 9.3 | Is each AI provider’s own retention period disclosed? | Yes | Anthropic: not retained by default for the models Pete uses, deleted within 30 days in every case. Google: prompts/responses retained 55 days for abuse monitoring (free tier only). |
| 9.4 | Has a zero data retention (ZDR) agreement been secured with Anthropic? | [VERIFY WITH CHRIS] | Requested, pending as of this draft. See pushback/zdr_and_dpa_actions.md for the outreach email prepared for Chris to send; status will read "0 days" here once Anthropic confirms. |
| 9.5 | Is human review of customer content disclosed, and is it limited? | Yes | Fugio staff read a sample of chat questions and answers for quality/abuse monitoring; this does not include the Outlook add-in’s forwarded email text, which is not saved with the question. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 10.1 | Is the backup method for the production database disclosed and verifiable in code? | [VERIFY WITH CHRIS] | Team memory references a nightly database snapshot to a company workstation, but nothing in the reviewed code performs or schedules this — it could not be confirmed from the repo, and the disk-encryption status of that workstation is unknown. |
| 10.2 | Is there multi-region failover? | No | The Service runs from a single Google Cloud VM in one region (us-east5); no failover region is configured. |
| 10.3 | Is data on a deleted storage volume destroyed within a bounded time? | Yes | Deleted disks are removed under Google Cloud’s data-deletion process (cloud.google.com/security/deletion). [VERIFY WITH CHRIS: no fixed time commitment is claimed here] |
| # | Question | Answer | Detail |
|---|---|---|---|
| 11.1 | Is there a formal vulnerability scanning program? | No | No scanning tool, schedule, or program was found in the repo or the audit files. Stated honestly rather than implied. |
| 11.2 | Are software dependencies version-pinned? | Yes, mostly | Most packages are pinned to an exact version in requirements.txt; a handful (including the Anthropic SDK itself) use a minimum-version constraint instead. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 12.1 | Has the Service undergone an independent penetration test? | No | None to date. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 13.1 | Does Fugio hold its own SOC 2 (or similar independent) report? | No | Not yet; planned, no committed date. The infrastructure vendors’ own certifications (Section 2, Section 8 table) do not substitute for Fugio’s own report. |
| 13.2 | Is a third-party compliance attestation in progress? | Yes | The Microsoft 365 App Compliance Program’s Publisher Attestation, for the Outlook add-in, is in progress (Partner Center, Seller ID 95966580). See pushback/zdr_and_dpa_actions.md for exactly what it asks and where it is submitted. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 14.1 | Is a security/incident contact published? | Yes | hello@petethepigeon.com. |
| 14.2 | Is a breach-notification timeframe committed? | Yes | 72 hours of confirming an incident, per the accompanying DPA. |
| 14.3 | Is there a formal written incident-response plan? | No | Not yet. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 15.1 | Does Fugio carry cyber liability / errors & omissions insurance? | [VERIFY WITH CHRIS] | Not stated in any reviewed file. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 16.1 | Are background checks performed on personnel with access to customer data? | [VERIFY WITH CHRIS] | Fugio Consulting is believed to be a single-operator company (Chris Graham, CEO, per the site’s own footer). Whether that is the entire team with data access, and whether any formal background-check program applies, is not confirmed here. |
| # | Question | Answer | Detail |
|---|---|---|---|
| 17.1 | Is the Service kept free of children’s data, by design? | Yes | Not directed at children under 13; no profiles of children are knowingly built. |
| 17.2 | Is the underlying dataset primarily public record rather than private data? | Yes | Bills, votes, legislators, committees, campaign finance, and lobbying — all public Ohio legislative records. Correspondence content (email text a user chooses to process) is separate, and is the Customer/constituent data described in the DPA. |
| 17.3 | Does the Microsoft Marketplace listing meet the required privacy-policy disclosure? | Yes | The listing links to petethepigeon.com/privacy, which discloses collection, use, and storage of customer data as required by certification-policy sections 100.5 and 100.6. |
| Answer | Count |
|---|---|
| Yes | 30 |
| No | 5 |
| [VERIFY WITH CHRIS] | 9 |
44 questions total. Every Yes and No above traces to a code citation, a live verification performed 2026-09-09, or a named vendor/Microsoft document; every [VERIFY WITH CHRIS] is a fact this audit could not confirm from the repository or the pushback files, not a guess dressed up as an answer.