Privacy Policy
For users in the United States, including Texas
This Privacy Policy explains how Dragon Transactions Limited (“we,” “us,” or “our”) collects, uses, shares, and protects personal data when you use Pocket Consultant (the “Service”) in the United States. It also explains the rights available to Texas residents under the Texas Data Privacy and Security Act.
In short: we do not sell personal data. We do not use your personal data, questions, documents, or answers to train AI models. You can opt out of targeted advertising at any time through Your Privacy Choices or with a Global Privacy Control signal.
1. Who We Are
Dragon Transactions Limited, Unit 617, 6/F, 131-132 Connaught Road West, Solo Workshops, Hong Kong (company registration no. 3137449), is the controller of personal data processed through the Service. Contact for privacy matters: mail@pocket-consultant.com.
2. Personal Data We Collect
| Category | Examples | Source |
|---|---|---|
| Account and contact data | Email address, phone number, password (stored as a hash), language, and region | You |
| Content you submit | Questions, chat history, uploaded documents and images, notes, custom instructions, and feedback | You |
| Payment and subscription data | Plan, price, billing period, payment status, renewals, cancellations, and refunds. Card details are collected by our payment processor and are not stored by us | You and Dodo Payments |
| Device and usage data | IP address, browser and device information, pages visited, cookie identifiers, and advertising click identifiers | Collected automatically |
| Communications | Support requests, emails, and your communication preferences | You |
| Sensitive data | Only if you choose to include it in a question or document (see Section 5) | You |
3. How We Use Personal Data
- To create and manage your account and authenticate you.
- To provide the Service: answer your questions, analyze documents, and prepare drafts you request.
- To process payments, subscriptions, renewals, cancellations, and refunds.
- To provide support and send service messages about your account, security, and billing.
- To send marketing emails if you agreed to receive them. You can unsubscribe at any time.
- To measure and improve the Service and our advertising, subject to your privacy choices (Section 7).
- To keep the Service secure, prevent fraud and abuse, and comply with legal, tax, and accounting obligations.
4. Categories of Recipients
We share personal data only with the categories of recipients below and only as needed for the purposes described in this Policy.
| Recipient | Data shared | Purpose |
|---|---|---|
| Hosting and infrastructure providers | All categories listed in Section 2 | Servers, databases, file storage, and backups needed to run the Service |
| AI model providers | The text of your question, relevant chat context, and the content of documents and images you upload | Generating answers, analyzing documents, and recognizing text in images. Depending on the task, these may include providers of OpenAI, Google, and Perplexity models, accessed directly or through the OpenRouter routing service |
| Legal research and search services | Search queries based on your question | Finding statutes, regulations, and court decisions, for example through CourtListener and web search services |
| Email delivery providers | Email address and message content | Sending account, billing, support, and, with your consent, marketing emails |
| Payment processor | Email address, country, plan, amount, and payment status | Dodo Payments acts as merchant of record: it processes payments, calculates and collects sales tax, and handles chargebacks |
| Analytics and advertising providers | Device and usage data, cookie identifiers, advertising click identifiers, IP address, hashed email address, and events such as sign-up or purchase | Measuring site usage and advertising campaigns (Google, Meta) and diagnosing errors (Sentry), subject to your privacy choices |
| Professional advisers and authorities | Data relevant to the matter | Legal, tax, and accounting advice, and responses to lawful requests |
| Successors in a corporate transaction | Data related to the Service | A merger, acquisition, or sale of assets, subject to this Policy |
5. Sensitive Data
Under Texas law, sensitive data includes data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, or citizenship or immigration status; genetic or biometric data processed to identify a person; precise geolocation; and personal data of a known child.
We do not require sensitive data to use the Service, and we do not use it for advertising or profiling. We process sensitive data only with your consent: if you choose to include it in a question or document, we use it only to provide the answer or document you requested. You can withdraw consent at any time by deleting the conversation or document, or by contacting us. Please do not include sensitive data about other people unless you are allowed to share it.
6. AI Processing
- Answers are generated automatically by AI models. They can be incomplete or inaccurate and are not legal advice.
- We send content to AI model providers only to process your request.
- We do not use your personal data, questions, documents, or answers to train AI models.
- We do not use AI processing to make decisions about you that produce legal or similarly significant effects.
7. Sale of Personal Data, Targeted Advertising, and Your Choices
We do not sell personal data, including sensitive data.
We may use cookies, pixels, and server-side conversion measurement from Google and Meta to show and measure ads. This can be considered processing for targeted advertising. You can opt out at any time:
- use Your Privacy Choices or Cookie preferences at the bottom of our pages and turn off advertising;
- enable Global Privacy Control (GPC) in your browser: we treat a GPC signal as a valid request to opt out of targeted advertising and of any sale of personal data, and we apply it to your account when you are signed in;
- email mail@pocket-consultant.com with the subject Opt Out.
Details about the cookies and similar technologies we use are in our Cookie Policy.
8. How Long We Keep Personal Data
- Uploaded documents are deleted 30 days after upload, unless you save them to your favorites. Saved documents are kept until you remove them or your account is deleted.
- Documents generated by the Service are kept for 30 days.
- Chat history is kept while your account is active, until you delete the conversation or ask us to delete your account.
- Payment, tax, and consent records are kept for as long as required by law or needed to resolve disputes.
When data is no longer needed, we delete or anonymize it, unless the law requires us to keep it longer.
9. Your Texas Privacy Rights
Subject to the Texas Data Privacy and Security Act and its exceptions, Texas residents have the right to:
- confirm whether we process their personal data and access it;
- correct inaccuracies in their personal data;
- delete personal data provided by or obtained about them;
- obtain a copy of personal data they provided to us in a portable format;
- opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects.
We will not discriminate against you for exercising these rights.
10. How to Submit a Request or Appeal
Email mail@pocket-consultant.com with the subject Privacy Request and describe the right you want to exercise. We may ask for information needed to verify your identity, usually by confirming access to the email address on your account. You may use an authorized agent to submit an opt-out request on your behalf.
We will respond within 45 days. If reasonably necessary, we may extend this period once by an additional 45 days and will tell you the reason. Requests are free of charge up to twice in any 12-month period.
If we decline your request, you may appeal by emailing the same address with the subject Privacy Appeal. We will respond to an appeal in writing within 60 days after we receive it. If the appeal is denied, you may contact the Texas Attorney General.
11. Age Requirement
The Service is intended only for people who are 18 or older. We do not knowingly collect personal data from children. If we learn that we have collected personal data from a child, we will delete it.
12. Security
We use reasonable administrative, technical, and physical safeguards appropriate to the nature of the data, including encryption in transit and access controls. No method of transmission or storage is completely secure.
13. Where Data Is Processed
We are based in Hong Kong. Our servers and service providers may be located outside the United States, and personal data may be processed in those locations under contractual and security safeguards.
14. Changes to This Policy
We may update this Policy to reflect changes to the Service, our practices, or the law. The current version and its date are always available on this page.
15. Contact
Privacy questions and requests: mail@pocket-consultant.com.