Draft. This notice is not in effect yet and is still being reviewed.
Privacy notice
Last updated [EFFECTIVE DATE]
The short version
- We use what you give us to deliver your cards and keep them in your album. That is all.
- Anyone with a card's link can open it, so share the link only with the person it is for.
- Link previews in chat apps show your name, your city and the photo. They never show what you wrote on the back.
- We never sell your information, and we do not use advertising trackers.
- Pocard will never ask you for money, one-time PINs or bank details.
- You can ask to see, correct or delete your information at any time.
Who we are
Pocard is run by [REGISTERED BUSINESS NAME], [BUSINESS ADDRESS], Philippines ("we"). We decide how your personal information is used, which makes us its personal information controller under the Data Privacy Act of 2012 (Republic Act No. 10173).
Our Data Protection Officer is [DPO NAME], reachable at [DPO EMAIL].
What we collect, and why
When you sign in to the app
Your email address and name, from Sign in with Apple, from Google, or from the email address you sign up with. If you use Apple's "Hide My Email", we only get Apple's relay address. We also get an account number that identifies you inside Pocard.
We use these so you can send cards, keep the cards people send you, and get replies. If you sign in with email, Amazon Cognito keeps your password in a form nobody can read back, including us.
When you send a card
- the name and city you put on the envelope
- the name of the person it is for
- the photo, and a small preview image made from the front of the photo
- what you write or draw on the back, the handwriting style, the stamps and where you placed them
- a voice note, if you record one
- the date
We use these to make the card, show it to whoever opens its link, and keep it in your Sent album.
When you keep a card
Which card you kept and when, so it stays in your Received album.
When you open a card in a browser
We do not ask for anything and we do not set cookies. Like every website, your browser sends your IP address to our servers when it loads the page. The page's fonts come from Google Fonts, so your browser also contacts Google.
When you join the Android waitlist
Your email address, which page you signed up on, and when. We use it only to tell you when Pocard for Android is out.
When you report a card
The reason you choose, anything you write, and a short code derived from your IP address (not the address itself) so we can stop people flooding us with reports.
To keep Pocard running and secure
Our servers log requests, including IP addresses, for 30 days to fix problems and stop abuse. To limit how often one address can use the waitlist or the report form, we count requests against a scrambled form of the IP address; those counters are deleted within two hours.
Who can see your cards
- The link is the key. Every card has its own link with 12 random characters, which nobody can guess. Anyone who has the link can open the card and read the back. If the person you sent it to forwards the link, whoever gets it can read it too.
- Link previews. When a link is pasted into Messenger, WhatsApp, Viber and similar apps, they show a preview with your name, your city and the preview image. The back of the card is never part of a preview, the page title or the link.
- Albums. You see your sent cards in your album. The person you sent a card to can keep it in theirs.
- Us. We do not look at your cards, except when a card is reported, when our automatic check flags it, or when the law requires it.
How we keep cards safe
Every image on a card is checked automatically by Amazon Rekognition for explicit, violent or hateful content before the card can be opened. A card that is flagged, or reported as a risk to a child, is hidden straight away. People can report a card from its page, and we review reports. We report child sexual abuse material to the authorities as the law requires, and we keep what the law requires us to keep as evidence.
Where your information is kept, and who helps us
- Amazon Web Services stores your cards, photos, account and album in its Singapore region, runs sign-in (Amazon Cognito) and the automatic image check (Amazon Rekognition). Its CloudFront network delivers photos and pages from servers near whoever opens them, and keeps short-lived copies there.
- Apple or Google, if you choose to sign in with them. Their own privacy policies cover what they collect.
- Google Fonts serves the fonts of the card page.
This means your information leaves the Philippines and is kept in Singapore. We use these providers under their data processing terms, which require them to protect it and to use it only to provide their service to us. We never sell or rent your information to anyone.
How long we keep it
- Cards: for as long as Pocard runs, so the cards in your album do not disappear. You can ask us to delete yours earlier.
- Cards that never finished sending: never shown to anyone. Their details are deleted after 7 days; a photo that was already uploaded for one stays in storage with the other photos.
- Cards hidden for breaking our rules: kept for as long as the law requires them as evidence, and never shown again.
- Your account: until you ask us to delete it.
- Waitlist emails: until we have told you Pocard for Android is out, or until you ask us to remove yours.
- Reports: for as long as the card they are about.
- Server logs: 30 days. Rate limit counters: two hours.
- Backups: deleted information can stay in our backups for up to 35 days before it is gone for good.
Your rights
Under the Data Privacy Act you have the right to be informed, to access your information, to have it corrected, to object, to have it erased or blocked, to get a copy you can take elsewhere, and to be paid damages if it is misused. You can also complain to the National Privacy Commission at privacy.gov.ph.
To use any of these rights, email [SUPPORT EMAIL]. We may ask you to confirm it is you, and we aim to answer within [15] days.
Deleting your account: email us and we will delete your account and your album. [DECISION: say what happens to cards you already sent. Either they stay in their recipients' albums with your name on them, or they are deleted everywhere.]
Children
You must be at least [13] to use Pocard. If you believe a child younger than that has given us information, email us and we will delete it.
Security
Everything travels over encrypted connections. Photos and data are kept in private storage that only Pocard's systems can read, and card links cannot be guessed. No system is perfect: if a breach puts your information at risk, we will tell you and the National Privacy Commission as the law requires.
Changes to this notice
When we change this notice we update the date at the top. If a change matters to how your information is used, we will also tell you in the app before it takes effect.
Contact
[REGISTERED BUSINESS NAME]
[BUSINESS ADDRESS], Philippines
[SUPPORT EMAIL]