
Pete the Pigeon
All Ohio’s Data, All the Time.
Security Questionnaire
Pre-filled — part of Pete the Pigeon’s Trust page, Fugio Consulting, LLC
Security and privacy questionnaire — pre-filled
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.
1. Company
| # | 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. |
2. Hosting and data location
| # | Question | Answer | Detail |
| 2.1 | Is the hosting provider named? | Yes | Railway (railway.com) hosts the Service’s servers, databases, and application logs. |
| 2.2 | Is the current data region disclosed, and kept current? | Yes | Published at petethepigeon.com/trust rather than fixed in this questionnaire, because the region is actively changing: as of the most recent check (2026-09-09) the service still ran in Railway’s Southeast Asia region, with a staged move to US East pending. Check the live page for the current answer rather than this document. |
| 2.3 | Does the hosting provider hold independent security certifications and publish a DPA? | Yes | Railway is SOC 2 Type II and SOC 3 certified, and offers a self-service DPA (DocuSign PowerForm, referenced at railway.com/legal/dpa). |
3. Encryption
| # | Question | Answer | Detail |
| 3.1 | Is data encrypted in transit? | Yes | All traffic is served over TLS, observed as TLS 1.3, terminated at Railway’s edge. No plain-HTTP path exists to the application. |
| 3.2 | Is data encrypted at rest? | [VERIFY WITH CHRIS] | Railway’s own compliance documentation does not make a blanket at-rest encryption claim for customer application databases — it addresses encryption only in the context of HIPAA add-on guidance ("will make its best effort to advise your company on setting up encryption for your data"). No stronger claim could be verified from the code or Railway’s published docs as of this writing. |
4. Access control
| # | 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 (Railway, 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. |
5. User authentication
| # | 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. |
6. Logging and monitoring
| # | Question | Answer | Detail |
| 6.1 | Are hosting/application logs retention-limited rather than kept forever? | Yes | 30 days, on Railway’s Pro-plan logging window. |
| 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. |
7. Retention and deletion
| # | 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). |
8. Subprocessors
| # | 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 |
| Railway Corporation | Hosting, databases, logs | SOC 2 Type II, SOC 3 |
| 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 |
9. AI specifics
| # | 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. |
10. Backups and continuity
| # | 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 Railway service/region at a time; no failover region is configured in the reviewed deployment. |
| 10.3 | Is data on a deleted storage volume destroyed within a bounded time? | Yes | Railway destroys a deleted volume within 48 hours. |
11. Vulnerability management
| # | 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. |
12. Penetration testing
| # | Question | Answer | Detail |
| 12.1 | Has the Service undergone an independent penetration test? | No | None to date. |
13. Independent audits
| # | 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. |
14. Incident response
| # | 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. |
15. Insurance
| # | Question | Answer | Detail |
| 15.1 | Does Fugio carry cyber liability / errors & omissions insurance? | [VERIFY WITH CHRIS] | Not stated in any reviewed file. |
16. Personnel
| # | 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. |
17. Compliance
| # | 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. |
Summary
| 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.