User blog comment:HazelQuill7445/Awesome fan art/@comment-25936766-20170802031605/@comment-26397825-20170802043640

That's what I'm saying. Penguins feel too prim and proper to merely be used on a drunkard and a military aristocrat. They should be reserved for a snobby noble type aristocrat instead. Someone who wears top hats and tail coats and white collar formalwear.

Basically Winter, while proper, isn't prim and proper enough to warrent the Penguin tag because her properness is more based in military rather than being a snob or princess.