PRIVCOM Consulting & Pocket Sage — Unified Privacy Policy

This Privacy Policy applies to:

  • privcom.ca

  • pocketsage.app

  • Any PRIVCOM–operated subdomains or services

  • Email communications with PRIVCOM Consulting or Pocket Sage

  • Sales Representative CV submissions

PRIVCOM Consulting is the data controller of the personal data processed through these services.

We respect your privacy, value your trust, and — most importantly — we do not collect any personal information unless you voluntarily provide it.

Pocket Sage software itself does not collect, transmit, store, or send any user data.
All AI operations occur locally on the user’s device and no usage data is ever sent to PRIVCOM.

1. Who We Are

PRIVCOM Consulting is a Canadian privacy consultancy operating pocket­sage.app as part of its software division.
We design and maintain privacy-first digital tools and consulting services.

Contact: info@privcom.ca

2. What We Do NOT Collect

Unless you voluntarily send us information (e.g., email correspondence, CV submission), we do not collect:

  • Names

  • Emails

  • Addresses

  • Payment information

  • Device identifiers tied to a person

  • AI usage logs

  • Pocket Sage activity

  • Clipboard data

  • Microphone recordings

  • Prompts, outputs, or transcripts

  • Anything processed inside the Pocket Sage application

Pocket Sage is designed specifically not to send us data. We physically cannot see what users do inside the app.

3. Automatically Collected Information (Minimal & Non-Identifying)

When you visit privcom.ca or pocketsage.app, our servers automatically process basic, non-personal technical data such as:

  • Browser type & version

  • IP address (anonymized or truncated where supported)

  • Time zone

  • Pages visited

  • Referring URLs

  • Basic device statistics

This information is automatically generated by any web server and is used:

  • To maintain site functionality

  • To detect abuse or malicious activity

  • To produce anonymous usage statistics

We do not link this information to any identifiable individual.

4. When You Provide Personal Information Voluntarily

You may choose to share personal information with us:

a) Email Correspondence

If you contact us, we retain your email for the purpose of responding.
We treat all correspondence confidentially.

b) Pocket Sage Waitlist / Purchase

If you join a waitlist, purchase Pocket Sage, or request support, we may collect:

  • Name

  • Email

  • Device type (optional)

  • Country/region (for licensing compliance)

This information is used solely to provide the requested service.

c) Sales Representative CV Submissions

Applicants submitting a CV or résumé may provide:

  • Name

  • Email

  • Phone number

  • Work history

  • Qualifications

We store this information securely and use it only to evaluate candidacy.
If the applicant withdraws or is not selected, they may request that PRIVCOM delete their submission permanently.

5. Pocket Sage Application Privacy

Pocket Sage is a local-only AI assistant.

Pocket Sage Does NOT:

  • Send prompts, conversations, or transcripts to any server

  • Log user activity to PRIVCOM

  • Use analytics

  • Collect telemetry

  • Transmit microphone data

  • Train on user inputs

  • Require accounts

Pocket Sage DOES:

  • Operate 100% offline

  • Store data only on the user’s device

  • Allow users to clear, delete, or uninstall all local data

Your device, your data, your rules.

6. Legal Basis for Processing (GDPR-Compliant)

For EU, UK, and EEA visitors, PRIVCOM processes personal data under the following legal bases:

  • Legitimate Interest:
    Basic server logs for security and site performance.

  • Consent:
    When you voluntarily provide data via forms or email.

  • Contractual Necessity:
    When processing your information is required to deliver Pocket Sage purchases or services.

  • Legal Obligation:
    When we must retain data to comply with applicable laws.

You may request access, correction, deletion, or restriction of your data at any time by emailing info@privcom.ca.

7. International Transfers

Our servers are hosted in jurisdictions compliant with modern privacy standards.
When data is transferred internationally (e.g., for support requests), we implement appropriate safeguards such as:

  • Standard Contractual Clauses (SCCs)

  • Data minimization

  • Encryption at rest and in transit

Pocket Sage application data is never transferred internationally because it never leaves the user’s device.

8. Security & Storage

We maintain appropriate administrative, physical, and technical safeguards, including:

  • Encrypted storage of CV submissions

  • Secure email retention policies

  • Firewalled server environments

  • Limited internal access

While no system is invulnerable, we take all reasonable steps to protect your information.

9. Data Retention

We retain:

  • Email communications: as long as necessary for support or legal interest

  • Waitlist sign-ups: until user unsubscribes

  • Purchase records: as required for tax and licensing

  • CV submissions: up to 12 months unless deletion is requested

Pocket Sage app data is stored only on user devices and is never retained by PRIVCOM.

10. Links to Other Websites

Our websites may contain third-party links.
We are not responsible for their content or privacy practices.
We strongly encourage users to review third-party privacy policies before interacting.

11. Legal Disclosure

We may disclose information only if legally compelled, such as:

  • Court orders

  • Government requests

  • Fraud investigations

  • Safety risks to users or others

We do not voluntarily share, sell, rent, or trade personal data.

12. Your Rights

Depending on jurisdiction, you may have the right to:

  • Access your data

  • Correct inaccuracies

  • Request deletion

  • Restrict or object to processing

  • Withdraw consent

  • Request portability

To exercise rights: info@privcom.ca

13. Updates to This Policy

We may update this Privacy Policy to reflect new products, legal requirements, or operational changes.
Updates will be posted on privcom.ca with revision dates.

14. Contact Us

For any privacy-related question:

📧 info@privcom.ca
🏢 PRIVCOM Consulting, Canada