Privacy Policy

Last updated April 6, 2026

This Privacy Policy explains how A440 VENTURES PTE. LTD ("Pocket," "we," "us," or "our") collects, uses, stores, and discloses personal data when you use the Pocket mobile application and related services.

Pocket is currently available through our mobile application only.

If you have questions about this Privacy Policy or our handling of personal data, contact:

• Email: nick@a440.vc
• Phone: +6580430973
• Post: A440 VENTURES PTE. LTD, Data Protection Officer, 160 Robinson Rd, #14-04, Singapore 068914, Singapore

1. Scope

This Privacy Policy applies to Pocket users worldwide, including users in Singapore, the United States, the European Economic Area, the United Kingdom, and Switzerland.

2. Personal Data We Collect

We collect only the personal data needed to provide Pocket and operate the app.

Data you provide directly

We may collect:

• account details
• email address
• conversation history within Pocket
• finance-related data that you choose to use in Pocket
• LinkedIn posts published through Pocket
• support or other communications you send to us

Data we access from connected services

When you connect third-party services and ask Pocket to perform a task, we may access data from those services to complete your request.

This may include:

• Gmail content that you ask Pocket to retrieve or act on
• Outlook data that you ask Pocket to access or act on
• calendar events that you ask Pocket to retrieve or act on

We do not store Gmail content, Outlook data, or calendar event data on our servers as part of normal product operation based on the current version of Pocket.

Technical and operational data

We may collect:

• device and app usage information needed to operate the app
• crash reports and app error logs
• basic account and subscription status information from Apple or Google needed to manage access to paid features

We currently store crash reporting and app error information using Amazon CloudWatch.

3. Data We Do Not Currently Use for These Purposes

Pocket does not currently:

• sell personal data
• share personal data for targeted advertising
• run targeted advertising programs
• offer social login
• collect precise geolocation data
• run SMS marketing programs

We may send email marketing communications. Users can opt out of marketing emails.

4. How We Use Personal Data

We use personal data to:

• create and manage user accounts
• provide Pocket features, including finance, project tracking, AI assistant, and connected-service workflows
• respond to user requests involving Gmail, Outlook, calendar, and LinkedIn integrations
• store conversation history and user-created records needed for the service
• process and maintain records related to app subscriptions
• secure, monitor, troubleshoot, and improve the app
• comply with legal and regulatory obligations
• send service messages and, where permitted, marketing emails with opt-out controls

5. AI Features

Pocket includes AI-powered features. When you use them, your prompts, instructions, and related data may be processed by third-party AI service providers that help us deliver the service.

Our current AI-related providers include:

• Google Gemini
• OpenRouter and model providers accessed through OpenRouter

These providers process data under their own terms and privacy practices, in addition to ours.

6. When We Disclose Personal Data

We may disclose personal data to service providers and partners that help us operate Pocket, including providers that support:

• hosting and infrastructure
• AI processing
• crash reporting and operational monitoring
• app store subscription management
• connected-service integrations requested by users

We may also disclose personal data:

• where required by law, regulation, court order, or lawful request
• to protect our rights, users, systems, or services
• in connection with a merger, acquisition, financing, or sale of all or part of our business

We do not sell personal data and do not share personal data for targeted advertising.

7. International Transfers

Pocket is operated by a Singapore company, and our servers are located in Singapore.

Some of our service providers may process personal data outside Singapore, including providers involved in AI processing, app distribution, and related technical services. Where we transfer personal data across borders, we take steps intended to ensure an appropriate standard of protection under applicable law, including the Singapore Personal Data Protection Act 2012 ("PDPA") and, where applicable, European data protection law.

8. Retention

We keep personal data only for as long as reasonably needed for the purposes described in this Privacy Policy, subject to legal, operational, security, and dispute-resolution requirements.

As a general rule:

• we aim not to retain personal data longer than 5 years
• if you request deletion, we may retain relevant data for up to 90 days before final deletion where needed for legal, security, fraud-prevention, backup, or dispute-handling purposes

9. Security

We use reasonable technical and organisational measures to protect personal data. However, no system can be guaranteed to be completely secure, and we cannot promise absolute security.

10. Children

Pocket is intended only for users aged 18 and above. We do not knowingly provide Pocket to users under 18.

11. Your Rights

Depending on where you live, you may have rights under applicable privacy laws, including rights to request access, correction, deletion, restriction, objection, withdrawal of consent where consent is used, or data portability.

To exercise any applicable rights, contact us at nick@a440.vc.

Singapore

If you are in Singapore, you may contact us to:

• request access to personal data we hold about you, subject to applicable exceptions
• request correction of inaccurate or incomplete personal data
• withdraw consent where our processing is based on consent, subject to legal and contractual limits

EEA, UK, and Switzerland

If you are in the EEA, UK, or Switzerland, we process personal data under one or more of these legal bases, depending on the context:

• performance of a contract with you
• our legitimate interests in operating, securing, and improving Pocket
• compliance with legal obligations
• your consent, where applicable

Subject to applicable law, you may have the right to:

• access your personal data
• request correction or deletion
• object to certain processing
• request restriction of processing
• request data portability
• withdraw consent where processing is based on consent
• lodge a complaint with your local supervisory authority

United States

If you are a resident of a US state with an applicable privacy law, you may have rights to request access, correction, deletion, or a copy of certain personal data, subject to applicable exceptions.

Pocket does not currently:

• sell personal data
• share personal data for targeted advertising

12. Account Deletion Requests

If you ask us to delete your account or personal data, we will process the request subject to applicable law and our retention requirements.

This may include deletion of:

• account details
• conversation history
• stored LinkedIn post records created through Pocket

Some data may be retained for up to 90 days before final deletion as described above.

13. Marketing Communications

We may send marketing emails. You can opt out at any time using the unsubscribe link in the email or by contacting us at nick@a440.vc.

We may still send non-marketing service communications that are necessary for your account or use of Pocket.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date above. If a change is material, we may also provide additional notice inside the app or by other appropriate means.

15. Contact Us

If you have questions, requests, or complaints about this Privacy Policy or our handling of personal data, contact:

A440 VENTURES PTE. LTD
Data Protection Officer
160 Robinson Rd, #14-04, Singapore 068914
Singapore
nick@a440.vc
+6580430973