PRIVACY POLICY for PocketCoach

D Jungle People Sdn Bhd (“we,” “our,” or “us”)
Last Updated: September 18, 2025

1. INTRODUCTION

This Privacy Policy describes how D Jungle People Sdn Bhd collects, uses, and protects your personal information when you use the PocketCoach mobile application (“App”). PocketCoach is an AI-powered coaching platform that provides professional development and leadership guidance.

Our Commitment: We are committed to protecting your privacy and complying with the Malaysian Personal Data Protection Act 2010 (PDPA), applicable international data protection laws, and app store requirements.

Contact Information:

·       Company: D Jungle People Sdn Bhd

·       Registration: 200001000253 (502858-A) 

·       Address: No. 15, Jln SS 1/39, Kampung Tunku, 47300 Petaling Jaya, Selangor

·       Email: [email protected]

·       Phone: +603-7877 8008

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide

When you register and use PocketCoach, we collect:

·       Name – for personalization and account identification

·       Email address – for account management and communications

·       Company name – to understand your professional context

2.2 Coaching Session Data

·       Text conversations – stored for service improvement and trend analysis (anonymized)

·       Voice recordings – temporarily processed for speech-to-text conversion, then immediately deleted

·       Session transcripts – generated from voice interactions, stored for your access and our service improvement

2.3 Usage and Technical Data

·       App usage patterns – session duration, feature usage, navigation paths

·       Device information – device type, operating system, app version

·       Performance data – crash reports, error logs (anonymized)

2.4 Data We Do NOT Collect

We do not collect:

·       Biometric data

·       Device identifiers for tracking

·       Contact lists or calendar information

·       Financial or payment information (handled by third-party processors)

3. HOW WE USE YOUR INFORMATION

3.1 Primary Purposes

·       Providing coaching services – personalized AI coaching and mentoring

·       Account management – maintaining your profile and preferences

·       Communication – updates, support responses, service notifications

·       Service improvement – analyzing usage patterns to enhance features

·       Security – preventing misuse and protecting user data

3.2 AI Model Enhancement

We use aggregated, de-identified coaching conversation data to:

·       Improve AI response quality and relevance

·       Identify industry trends and common challenges

·       Enhance coaching methodologies

·       Note: Personal identifiers are removed before analysis

3.3 Marketing and Communications

·       Service updates and new feature announcements

·       Industry insights and coaching tips

·       Customer support and technical assistance

·       You can opt-out of marketing communications at any time

4. DATA SHARING AND DISCLOSURE

4.1 Third-Party Service Providers

We share data with these essential service providers:

Cloud Infrastructure:

·       Amazon Web Services (AWS)

·       Purpose: Secure data storage and app infrastructure

·       Safeguards: AWS provides SOC, ISO 27001, and GDPR compliance

AI Processing:

·       OpenAI – GPT-4o for coaching conversations, Whisper for speech-to-text

·       ElevenLabs – Text-to-speech conversion

·       Purpose: Core AI coaching functionality

·       Safeguards: Data processing agreements with privacy protections

4.2 Business Partners

·       B2B Resellers – Only aggregated, non-identifiable trend data

·       Enterprise Clients – Custom implementations maintain data separation

·       Learning and Coaching Professionals – No personal data shared, only anonymized insights

4.3 Legal Requirements

We may disclose information when required by:

·       Malaysian law enforcement or regulatory authorities

·       Court orders or legal processes

·       Emergency situations to prevent harm

4.4 Business Transfers

In case of merger, acquisition, or sale, your data may be transferred with appropriate privacy protections maintained.

5. DATA STORAGE AND SECURITY

5.1 Storage Location

·       Primary storage: AWS (London) data centers

·       Jurisdiction: Data subject to UK and EU privacy laws

·       Cross-border transfers comply with Malaysian PDPA cross-border transfer guidelines

5.2 Security Measures

·       Encryption – Data encrypted in transit and at rest

·       Access controls – Role-based access with multi-factor authentication

·       Regular audits – Security assessments and vulnerability testing

·       Data minimization – We collect only necessary information

·       Incident response – Procedures for breach notification and response

5.3 Data Retention

·       Account data – Retained while your account is active

·       Coaching sessions – Available in-app during active subscription

·       Aggregated analytics – Retained indefinitely (anonymized)

·       Voice recordings – Deleted immediately after transcription

·       Account deletion – All personal data removed within 30 days of request

6. YOUR RIGHTS AND CHOICES

6.1 Access and Control

You have the right to:

·       Access your personal data and coaching session history

·       Correct inaccurate information in your profile

·       Delete your account and associated data

·       Opt-out of marketing communications

6.2 Malaysian PDPA Rights

Under Malaysian PDPA, you can:

·       Withdraw consent for data processing

·       Request correction of personal data

·       Request access to your personal data

·       Lodge complaints with the Personal Data Protection Commission

6.3 How to Exercise Rights

Contact us at [email protected] to:

·       Request data access or corrections

·       Delete your account

·       Withdraw consent

·       File privacy complaints

Response time: We will respond within 21 days as required by Malaysian PDPA.

7. INTERNATIONAL DATA TRANSFERS

7.1 Transfer Safeguards

When transferring data from Malaysia to our AWS London servers:

·       Legal basis – Adequate protection under Malaysian PDPA Cross-Border Transfer Guidelines

·       AWS compliance – SOC, ISO 27001, ISO 27018 certifications

·       Contractual protections – Standard contractual clauses for data protection

7.2 Third-Party AI Services

Data processed by OpenAI and ElevenLabs:

·       Limited processing – Only for immediate service delivery

·       Data residency – European data processing where available

·       Contractual safeguards – Data processing agreements with privacy protections

8. CHILDREN’S PRIVACY

PocketCoach is designed for professional coaching and is not intended for children under 18. We do not knowingly collect personal information from children. If we discover we have collected information from a child, we will promptly delete it.

9. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect:

·       Changes in laws or regulations

·       New features or services

·       Improved privacy practices

Notification: We will notify you of significant changes through:

·       In-app notifications

·       Email announcements

·       Updated “Last Modified” date

Your continued use of PocketCoach after changes indicates acceptance of the updated policy.

10. CONTACT US

Privacy Officer: Sue Fei Teh
Email: [email protected]
Address: No. 15, Jalan SS 1/39, Kampung Tunku, 47300 Petaling Jaya, Selangor
Response Time: 21 days for privacy requests

Complaints: You may also lodge complaints with:

·       Malaysia: Personal Data Protection Commission (www.pdp.gov.my)

·       International: Relevant data protection authorities in your jurisdiction

This Privacy Policy is effective as of September 18, 2025, and governs the collection and use of information by D Jungle People Sdn Bhd in connection with the PocketCoach application.