diff --git a/src/app/app-privacy-policy/page.tsx b/src/app/app-privacy-policy/page.tsx index 725e0209f..806116607 100644 --- a/src/app/app-privacy-policy/page.tsx +++ b/src/app/app-privacy-policy/page.tsx @@ -59,288 +59,259 @@ const TitleTypography = styled(Typography)(() => ({ marginBottom: "4rem", })) +// Tommy Thomas, Slack 2026-09-14 (C0BRZ8G1V50): the Compass privacy policy replaces the +// PocketPal one that stood here. Copy is his Google Doc, verbatim; numbered sections are +// h2 and their sub-headings h3, his bold runs are . The doc says "Last updated: +// [publish date]" — filled in with the day this went up. const AppPrivacyPolicy = () => { return ( - PocketPal Privacy Policy -

Last updated: June 30, 2026

+ Compass Privacy Policy +

Last updated: September 15, 2026

- PocketPal is a travel assistant app for digital nomads and travelers. This Privacy Policy explains what information PocketPal collects, how we - use it, when we share it, and what choices you have. + Compass is an AI assistant app for iPhone. This policy explains what information Compass collects, how we use it, who we share it with, and + the choices you have.

-

This policy applies to the PocketPal iOS app and related services operated by Up Labs Limited (“PocketPal,” “we,” “us,” or “our”).

-

1. Information We Collect

-

Account information

-

When you create or use an account, we may collect:

+

It applies to the Compass iOS app and its supporting services, operated by Up Labs Limited ("Compass", "we", "us", or "our").

+ +

1. Information we collect

+

Account information

+

+ You can use Compass without creating an account. When you start, we create an anonymous guest account so the app can work, identified only by + an internal user ID. No email or name is attached to it. +

+

If you create an account, we also collect:

+ +

Profile

+

If you choose to fill them in, we store:

+ +

Your name and About you note are used to personalise answers. They are sent to the AI provider only when you use cloud AI (see below).

+ +

Chat and AI providers

+

Compass answers with either a cloud model or an on-device model.

- We use this information to create and secure your account, sync your profile, personalize travel answers, and provide account recovery or - support. -

-

- Your passport country may be used to give more relevant travel, visa, entry, and local-context answers. Because this may reveal - nationality-related information, you should only provide it if you are comfortable doing so. + Cloud models. Cloud AI is off until you turn it on. When it's on and you send a message, Compass sends the following to our + backend on Supabase, which forwards it to OpenRouter:

-

Chat and third-party AI providers

-

When you chat with PocketPal, we process your messages and the assistant’s responses to provide the AI travel assistant experience.

-

PocketPal supports both cloud AI and local AI:

- PocketPal asks for your permission before sending chat content or travel context to third-party AI providers. If you do not allow cloud AI, - you can use local AI where available and your chat content is not sent to OpenRouter or Anthropic's Claude. + OpenRouter routes the request to the provider of the model that answers — for example Anthropic (Claude), OpenAI (GPT), Google (Gemini), xAI + (Grok), DeepSeek, Meta (Llama), or Alibaba (Qwen). If you pick a model yourself, it goes to that model's provider. If you use Auto, Compass + chooses the model. Each reply shows which model answered.

- PocketPal stores chat history locally on your device so your conversation can continue between app sessions. Chat history is not designed to - be synced as part of your cloud account. However, recent chat messages may be sent to the cloud AI service when you use cloud AI mode after - giving permission. + We do not store your chat messages on our servers. They pass through our backend to reach the AI provider and are not saved there. AI + providers process them under their own terms and privacy policies.

-

You should avoid entering highly sensitive information into chat unless it is necessary for your use of the app.

-

Voice input and speech recognition

-

If you use voice mode, PocketPal may access your microphone so you can speak to the travel assistant.

- Your speech is converted into text using Apple speech recognition technology. When local recognition is not available, Apple may process the - audio on its servers. The resulting transcript is then handled like a normal chat message. + On-device models. If you download an on-device model, messages answered by it are processed entirely on your iPhone and are + not sent to us or to any AI provider. You can use Compass with on-device models only, with cloud AI turned off.

-

PocketPal does not intentionally store raw voice recordings.

-

Location and country information

-

PocketPal may use location-related information to provide travel features, including:

- -

Depending on the feature, PocketPal may process:

+

+ Chat history is stored only on your device. It is not synced to your account. +

+

Please avoid sharing highly sensitive information in chat unless you need to.

+ +

Usage and allowance

+

Cloud AI use is metered so we can apply each plan's allowance. For your account we store:

+

We do not store message content as part of this.

+ +

Purchases and subscriptions

- Some map, search, location, and routing features may send location, route, or search information to service providers such as Apple Maps, - Supabase, or other map/routing infrastructure used by the app. + Subscriptions (Compass Plus, Compass Premium) and top-ups are bought through Apple. Apple handles payment; we never receive your card details. + We receive and store the product you bought, its status and renewal dates, and Apple's transaction identifiers, so we can give you what you + paid for.

+ +

VPN (Premium)

- PocketPal does not intentionally build a persistent location history. If you save a place, the saved place may include its name, category, - coordinates, notes, phone number, website, or other details you choose to save. + If you use the built-in VPN, we create a VPN account for you with our VPN infrastructure provider and store the account identifier and + connection configuration needed to connect you. We do not log the websites you visit or the traffic that passes through the VPN.

-

You can control location access at any time in iOS Settings.

-

Saved places and lists

-

If you use saved places or travel lists, we may collect and store:

- -

Saved places may be stored locally on your device and synced to your PocketPal account so they are available across sessions.

-

User content

+ +

eSIM (Premium)

- Content you create in PocketPal, such as saved place lists, notes, feedback messages, and chat messages, may contain personal information - depending on what you choose to enter. Saved places and lists may sync to your PocketPal account through Supabase. Chat messages are stored - locally, except when sent for cloud AI after permission. + If you claim the eSIM included with Premium, we order it from our eSIM provider and store the order details needed to deliver and support it, + such as the plan, order status, and the identifiers needed to install and check your data balance.

-

Feedback and support

-

If you submit feedback, we may collect:

- -

We use feedback to respond to you, debug issues, improve the app, and prioritize product improvements.

-

Analytics and diagnostics

-

PocketPal may collect product analytics and diagnostic information to understand how the app is used and to improve reliability.

-

This may include:

- + +

Voice

- PocketPal does not intentionally send chat message content, email address, exact location, raw search text, saved place names, phone numbers, - or saved place URLs to analytics. + If you use voice mode, Compass uses your microphone, and Apple's speech recognition turns what you say into text. When on-device recognition + isn't available, Apple may process the audio on its servers. The transcript is then handled like a typed message. Compass does not store voice + recordings.

+ +

Location and country

+

Compass uses your country to make answers more relevant to where you are.

- Analytics may be associated with an internal user ID so we can understand app usage and reliability without using your email address or chat - content. + By default, your country comes from your iPhone's region setting, which doesn't require location permission. You can change it in Settings. If + you allow location access, Compass may use your approximate location, at country-level accuracy, to update your country when you travel. We + don't collect your precise location or build a location history.

-

You can turn off analytics in the app settings by disabling Share product analytics.

-

eSIM purchase links

-

PocketPal may show eSIM plans and purchase links for third-party eSIM providers.

+

Your country is sent to the AI provider with cloud AI messages, as described above.

+ +

Feedback

- If you choose to buy an eSIM, you may be taken to a third-party website, such as Breeze or another eSIM provider. That provider is responsible - for collecting and processing information needed for the transaction, such as payment details, account details, order information, and - customer support information. + If you send feedback, we collect the category, your message, your email address if you provide one, your user ID, and your app and iOS + versions.

-

PocketPal does not collect or store your payment card details for third-party eSIM purchases.

+ +

Analytics

- Some links may include an affiliate or referral identifier. This may allow the third-party provider to attribute a purchase or visit to - PocketPal. + To understand how Compass is used and to fix problems, we collect product analytics through PostHog. This includes app launches, which + features are used, sign-in events, message and conversation length, the models and plans involved, voice and on-device model events, purchase + events, and error details, along with your app version and device's operating system. Analytics are linked to your internal user ID, not your + email address.

-

Local model and offline map downloads

-

PocketPal may let you download optional on-device AI models or offline map files.

-

When you download these files, the app may process:

- -

Downloaded models and offline map files are stored on your device.

-

2. How We Use Information

+

We do not send chat message content, your email address, or your location to analytics.

+

You can turn analytics off in Settings under "Share product analytics".

+ +

On-device model downloads

+

+ On-device models are downloaded from Hugging Face. The download request goes directly from your iPhone to Hugging Face, which sees your IP + address as part of it. Downloaded models are stored on your device. +

+ +

2. How we use information

We use information to:

-

3. How We Share Information

+ +

3. How we share information

We do not sell your personal information.

-

We may share information with service providers only as needed to operate PocketPal, including:

+

We share information only with providers that help run Compass:

- These providers may process information according to their own privacy policies and contractual obligations. We use service providers to help - deliver app functionality and require them to protect information in a manner consistent with this Privacy Policy and applicable privacy and - security obligations. + We may also disclose information if the law requires it, or to protect the rights and safety of our users or others, or to investigate fraud, + abuse, or security issues.

+ +

4. Information stored on your device

- We may also disclose information if required to comply with law, enforce our terms, protect the rights and safety of users or others, or - investigate fraud, abuse, or security issues. + The following stays on your device: chat history, downloaded on-device models, your model choice, and app settings. It's removed when you + clear chat history, delete your data or account, or uninstall the app.

-

4. Data Stored Locally on Your Device

-

Some PocketPal data is stored locally on your device, including:

+ +

5. How long we keep information

- Local data may be removed if you clear it in the app, sign out, delete your account, uninstall the app, or delete app data from your device. -

-

5. Data Retention

-

- We keep information only as long as needed for the purposes described in this policy, unless a longer retention period is required or - permitted by law. + When you delete your account, or delete your data as a guest, we delete the associated data from our active systems, except where we must keep + something for legal, security, fraud-prevention, or dispute reasons.

-

In general:

+ +

6. Your choices

- When you delete your account, PocketPal will delete your account and associated account data from our active systems, subject to limited - exceptions such as legal obligations, security, fraud prevention, dispute resolution, or backup retention. -

-

6. Your Choices and Controls

-

You can control your information in several ways:

- -

- You may also contact us to request access, correction, deletion, export, or restriction of your personal information, depending on your - location and applicable law. + Depending on where you live, you may also have the right to access, correct, export, or delete your personal information, or to object to how + it's used. Contact us to make a request.

+

7. Security

- We use reasonable technical and organizational measures to protect information, including secure transport, authentication, access controls, - and service-level protections. + We use reasonable technical and organisational measures to protect information, including encrypted connections and access controls. No method + of transmission or storage is completely secure, so we can't guarantee absolute security.

-

However, no method of transmission or storage is completely secure. We cannot guarantee that information will always remain secure.

-

8. Children’s Privacy

-

- PocketPal is not intended for children under 13, or the minimum age required in your jurisdiction. We do not knowingly collect personal - information from children. If you believe a child has provided personal information to us, please contact us so we can take appropriate - action. -

-

9. International Processing

-

- PocketPal and its service providers may process information in countries other than where you live. These countries may have privacy laws that - differ from those in your jurisdiction. -

-

By using PocketPal, you understand that your information may be processed and transferred internationally as needed to provide the app.

-

10. Third-Party Links and Services

-

- PocketPal may contain links to third-party websites or services, including eSIM purchase pages. We are not responsible for the privacy - practices of third-party websites or services. You should review their privacy policies before providing information to them. -

-

11. Changes to This Policy

+ +

8. Children

- We may update this Privacy Policy from time to time. If we make material changes, we will update the “Last updated” date and provide - additional notice if required by law. + Compass is not intended for children under 13, or under the minimum age in your country. We don't knowingly collect personal information from + children. If you believe a child has given us personal information, contact us and we'll take appropriate action.

-

12. Contact Us

-

For privacy questions, requests, or concerns, contact us at:

+ +

9. International processing

+

Compass and its providers may process information in countries other than yours, where privacy laws may differ.

+ +

10. Changes to this policy

+

We may update this policy. If we make material changes, we'll update the date above and give additional notice where the law requires it.

+ +

11. Contact us

+

For privacy questions or requests, contact:

+

Up Labs Limited

tommy@scroll.io

-

Tommy Thomas, Up Labs Limited

 ) }