ACL Solutions LLC ("Company," "we," "us," or "our"), operating under the brand name PookieB, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our products and services, including SmartSpender, Shredders, News Daily, DayByDay, Harmony Tracker, and Wilco (collectively, the "Services").
By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this policy, please do not use our Services.
1. Information We Collect
Information You Provide
We may collect information that you voluntarily provide to us, including:
- Account Information: Name, email address, and password when you create an account
- Profile Information: Any additional details you choose to add to your profile
- User Content: Journal entries, financial data, preferences, watchlists, and other content you create through our Services
- Communications: Messages you send to us, feedback, and support requests
- Payment Information: If applicable, billing details processed through our third-party payment processors
Information Collected Automatically
When you use our Services, we may automatically collect certain information, including:
- Device Information: Device type, operating system, browser type, and unique device identifiers
- Usage Data: Pages visited, features used, time spent, click patterns, and interaction data
- Log Data: IP address, access times, referring URLs, and error logs
- Location Data: General geographic location based on IP address (we do not collect precise GPS location without your explicit consent)
- Cookies and Tracking: Cookies, web beacons, and similar technologies to enhance your experience and gather analytics
2. How We Use Your Information
We use the information we collect to:
- Provide, maintain, and improve our Services
- Personalize your experience and deliver relevant content and recommendations
- Process transactions and manage your account
- Communicate with you about updates, features, and support
- Analyze usage patterns and trends to improve our products
- Power AI features such as financial analysis, powder scoring, news summarization, and conversation coaching
- Detect, prevent, and address security issues, fraud, and technical problems
- Comply with legal obligations and enforce our terms
- Develop new products, services, and features
3. Third-Party Services
We use trusted third-party services to help us operate and improve our Services. These providers have access to your information only to perform specific tasks on our behalf and are obligated to protect it. Our key third-party service providers include:
Infrastructure and Hosting
- Amazon Web Services (AWS): Cloud infrastructure, data storage, and computing services. Data may be stored in AWS data centers in the United States. AWS complies with SOC 2, ISO 27001, and other security standards.
- Vercel: Web application hosting, deployment, and edge network services. Vercel processes request data and may collect analytics. See Vercel's Privacy Policy.
Database and Backend
- Supabase: Database hosting, authentication, and backend services. User account data and application data are stored in Supabase-managed PostgreSQL databases. See Supabase's Privacy Policy.
AI and Machine Learning
- OpenAI: AI language model services used to power features such as financial analysis, news summarization, and conversational AI. User prompts and content may be sent to OpenAI's API for processing. See OpenAI's Privacy Policy.
- Anthropic: AI language model services used to power intelligent features across our products. User content may be sent to Anthropic's API for processing. See Anthropic's Privacy Policy.
We may also use additional third-party services for analytics, error tracking, and email delivery. We do not sell your personal information to third parties.
4. Data Security
We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit (TLS/SSL) and at rest
- Regular security assessments and vulnerability scanning
- Access controls and authentication mechanisms
- Secure development practices and code review processes
- Regular backups and disaster recovery procedures
While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.
5. Data Retention
We retain your personal information for as long as your account is active or as needed to provide you with our Services. We may also retain information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:
- Account Data: Retained while your account is active and for up to 30 days after deletion request
- User Content: Retained while your account is active; deleted upon account deletion
- Usage Analytics: Aggregated and anonymized data may be retained indefinitely for product improvement
- Legal Records: Retained as required by applicable law
6. Your Rights
Depending on your location, you may have certain rights regarding your personal information:
- Access: Request a copy of the personal information we hold about you
- Correction: Request correction of inaccurate or incomplete personal information
- Deletion: Request deletion of your personal information, subject to certain exceptions
- Portability: Request your data in a structured, commonly used, machine-readable format
- Objection: Object to the processing of your personal information in certain circumstances
- Restriction: Request restriction of processing of your personal information
- Withdraw Consent: Withdraw consent at any time where we rely on consent as the legal basis for processing
To exercise any of these rights, please contact us at contact@pookieb.com. We will respond to your request within 30 days.
7. Children's Privacy
Our Services are not intended for children under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information promptly.
If you are a parent or guardian and believe your child has provided us with personal information, please contact us at contact@pookieb.com.
8. California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
- Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months
- Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights
- Right to Opt-Out: You have the right to opt out of the sale of your personal information. We do not sell personal information
- Shine the Light: California residents may request information about our disclosure of personal information to third parties for direct marketing purposes
To exercise your California privacy rights, please contact us at contact@pookieb.com or write to us at the address listed below. We may ask you to verify your identity before processing your request.
9. International Users
Our Services are primarily operated from the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country.
By using our Services, you consent to the transfer of your information to the United States and its processing there. We take appropriate safeguards to ensure that your personal information is treated securely and in accordance with this Privacy Policy.
For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we process personal data based on applicable legal bases including consent, contractual necessity, and legitimate interests.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date.
We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of our Services after any changes constitutes acceptance of the updated policy.
11. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
We will respond to all privacy-related inquiries within 30 days.