INTRODUCTION
Welcome to Personal Assistant: Pocket PA, provided by Hyperlink Infosystem Inc., registered in New York, New York, USA ("we," "us," or "our"). This Privacy Policy describes how we collect, use, share, process, and protect your information when you use the Personal Assistant: Pocket PA application (“Application,” “App,” or “Platform”).
By using the Application, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of the Application.
This Privacy Policy applies solely to data processed through the Application. It does not apply to third-party services accessed through or linked from the Application.
DATA WE COLLECT
The Application is designed with a strong focus on privacy. We do not intentionally collect personal information.
The Application does not collect, store, transmit, or process personal information on Company servers, including but not limited to:
- Name
- Email address
- Phone number
- Location data
- Contacts
- Email content or account data
All goals, reminders, notification settings, and other content created or managed within the Application remain stored exclusively on the User's device and are processed locally.
- Device type
- Operating system version
- App usage information
- Anonymous device identifiers
All permissions are optional and may be revoked at any time through your device settings. Revoking a permission will disable the associated feature but will not affect other Application functionality. All processing of device data occurs locally. The Company does not access, upload, or store this data.
DEVICE PERMISSIONS
To enable its features, the Application may request access to certain device functionalities:
- Notifications: To deliver reminders, goal-related alerts, and other notifications configured by the User. Processing occurs entirely on-device.
- Alarms and Scheduling: To trigger time-based reminders at the time set by the User, including exact alarm scheduling where applicable on Android devices.
All permissions are optional and can be revoked at any time through device settings. All processing of such data occurs locally on the device. The Company does not access or store this data.
PURPOSE OF DATA COLLECTION
The limited technical information we collect is used to:
- Facilitate and maintain the core functionality of the Application.
- Diagnose and resolve technical issues, crashes, or performance problems.
- Analyze anonymous usage patterns to improve user experience.
- Comply with legal obligations and safeguard against fraud or security threats.
PROCESSING OF THE INFORMATION
Where limited technical data is processed, it is used for the following purposes:
- Service delivery and support: To respond to technical inquiries, provide troubleshooting assistance, and address Application errors.
- Security and fraud prevention: To detect, prevent, and investigate security threats, misuse, or abuse of the Application.
- Legal compliance: To meet applicable legal obligations and enforce our Terms of Use.
- Application improvement: To understand aggregate usage patterns and improve Application features and stability.
PURPOSE AND LEGAL BASIS FOR PROCESSING
- Performance of contract: Providing the Application and its features, managing in-app purchases, and supporting User-requested functionality.
- Legitimate interests: Ensuring Application security, improving performance, and maintaining platform integrity through anonymized analytics.
- Legal obligations: Retaining records as required by applicable tax, accounting, and regulatory laws.
- Consent: Where required for optional analytics or region-specific rights. Consent may be withdrawn at any time as described below.
SHARING OF INFORMATION AND THIRD PARTY SERVICES
1. No Sale of Personal Data - We do not sell, trade, or transfer personal information to unrelated third parties for marketing or advertising purposes.
2. While the Application itself does not collect personal information, certain third-party platforms may collect limited technical data when you download or purchase the Application. These may include:
- Apple App Store
- Google Play Store
Such services operate under their own privacy policies, and the Company does not control their data practices.
3. We May Share Information With:
- Service providers: In limited circumstances, we may engage trusted third-party service providers to support specific Application features, such as payment processing for in-app subscriptions. These providers process data only as necessary to provide the requested functionality and are contractually obligated to protect user information.
- Affiliate Companies: In connection with mergers, acquisitions, restructurings, or asset transfers, subject to the protections described in this Policy.
- Legal compliance and safety: Where required by law, court order, or to protect the rights, property, safety, or security of the Company, Users, or the public.
4. International Data Transfers and Storage:
- EEA/UK transfers: Where any data is transferred outside the EEA or UK, appropriate safeguards such as Standard Contractual Clauses or adequacy decisions are implemented. If storage locations materially change, this Policy will be updated accordingly.
GOALS, REMINDER, AND NOTIFICATION DATA
All goals, reminders, notification settings, and other content created or managed within the Application are stored exclusively on the User's local device.
The Company:
- Does not upload, transmit, or copy such content to any server
- Does not provide cloud storage for such content
- Does not host such content on remote infrastructure
- Does not access, read, or analyze such content
Users are solely responsible for managing, backing up, and securing all content stored on their device. The Company accepts no responsibility for loss, corruption, or unauthorized access to locally stored data.
COOKIES AND ANALYTICS
- Cookies are used to operate the Application, improve user experience, analyze traffic, and enhance security. The Application and its underlying services may use cookies or similar technologies, including mobile device identifiers and local storage, to maintain your usage session and improve app performance.
- Google Analytics may be used to understand service usage patterns on the Application or related pages. Users can opt out via Google’s tools. Additional information about Google’s processing is available in Google’s publicly available materials.
DATA STORAGE
All user data, including goals, reminders, and notification settings, remains stored locally on the User's device.
DATA RETENTION
All User-generated content, including documents, PDF files, images, and annotations, is stored locally on the User's device. The Company does not maintain remote databases containing User file content.
Retention of any limited technical or operational data collected by the Company is limited to the duration necessary for the purposes described in this Policy. Upon a verified deletion request, associated personal data will be deleted within seven (7) days, subject to any retention required by legal obligations (e.g., payment and invoice records retained for applicable regulatory periods).
DATA SECURITY
We implement appropriate technical and organizational measures to protect your data against:
- Unauthorized access
- Alteration
- Disclosure
- Destruction
We have designed the Application to minimize data collection and maximize user privacy.
Because the Application does not collect or store user data on company servers, the risk of data exposure from our systems is significantly reduced.
Users are responsible for securing their own devices and managing their locally stored content.
While we strive to use commercially acceptable means to protect your data, no method of electronic storage or transmission is 100% secure.
IN-APP PURCHASES
Payments are processed by third-party providers; payment credentials entered with those providers are not accessed by us. By making an in-app purchase through our App, you acknowledge and agree that all sales are final. We do not offer refunds or cancellations after purchase, except as required by applicable consumer protection laws.
All subscription plans and pricing are presented clearly within the App prior to purchase. Please review the plan details carefully before confirming your purchase.
For any concerns or support related to your purchase, you may contact us at legal.hyperlinkinfosystem@gmail.com, but please note that refunds will only be issued if mandated by law.
Before you complete a purchase, we clearly display price, recurring periods, billing intervals.
YOUR RIGHTS
Depending on jurisdiction, the following rights may apply:
- Access, rectification, and erasure: Request copies, corrections, or deletion of personal information.
- Restriction and objection: Request processing restrictions or object to certain processing, including where based on legitimate interests.
- Data portability: Request portable copies in a machine‑readable format where applicable.
- Consent withdrawal: Where processing is based on consent (e.g., certain cookies/analytics), consent may be withdrawn at any time via settings or by contacting us; this does not affect the lawfulness of prior processing.
- Marketing opt‑out: Unsubscribe from marketing communications at any time. Service and transactional messages may still be sent.
GDPR‑SPECIFIC DISCLOSURES (EEA/UK)
- Controller: We the entity managing the Services acts as the controller for personal data processed as described.
- Lawful bases: Performance of contract, legitimate interests, legal obligations, and consent (as detailed above).
- EEA/UK transfers: Adequacy decisions or Standard Contractual Clauses apply for transfers to non‑EEA/UK countries, including the United States.
- Rights and timelines: Access, rectification, erasure, restriction, objection, and portability requests will be addressed within thirty (30) calendar days. A nominal fee may be charged where permitted by law for excessive or manifestly unfounded requests.
- Complaints: Individuals may lodge a complaint with a competent supervisory authority in the EEA/UK in addition to contacting us.
California “Shine the Light”
California residents may request information about disclosures of certain categories of personal information to third parties for their direct marketing, if any, once per year free of charge.
CHILDREN’S PRIVACY
The Services are not intended for individuals under the age of thirteen (13). If it is learned that data has been collected from someone under 13 years of age, access will be terminated and the data will be deleted.
If you believe a child under 13 years of age has provided us with identifiable personal data, please contact us at legal.hyperlinkinfosystem@gmail.com and we will take steps to remove such information.
CHANGES TO THIS POLICY
This Policy may be updated from time to time. The “Last Updated” date will reflect changes. For material changes, reasonable efforts will be made to notify via in‑app notice or email if available. Continued use of the Services after changes indicates acceptance.
CONTACT US
For questions or concerns related to this Privacy Policy, please contact us via email at legal.hyperlinkinfosystem@gmail.com with the subject line “Privacy Policy of Personal Assistant: Pocket PA Application”.