This ATLAS Privacy Notice (the "Notice") describes how Pocket Entertainment Ventures Private Limited ("Pocket FM", "we", "us", or "our") collects, uses, discloses, retains, and protects personal information when you access or use ATLAS, our AI-powered tool for translating and adapting genre stories and related text (the "Service"). This Notice supplements, and should be read together with, the Pocket FM Privacy Policy. Where this Notice and the Pocket FM Privacy Policy address the same topic, the provisions of this Notice shall be applicable specific to ATLAS only.
Capitalised terms not defined here have the meaning given to them in the Pocket FM Privacy Policy or the ATLAS Supplemental Terms of Service.
1. Scope of This Notice
This Notice applies to all visitors and authenticated users of the ATLAS microsite. It does not apply to the Pocket FM website at pocketfm.com, mobile applications, podcasts, audiobooks, or Pocket Novels, which remain governed solely by the Pocket FM Privacy Policy.
2. Information We Collect
When you use ATLAS, we collect the following categories of personal information:
2.1 Information You Provide Directly
- Account & Authentication Data: your Google account email address, name, profile identifier, and authentication tokens received through Google Sign-In (we do not receive your Google password).
- Submitted Content: source text, stories, manuscripts, prompts, instructions, or other material you input into ATLAS for translation or adaptation ("Input").
- Generated Content: the translated, adapted, or otherwise transformed text that ATLAS returns to you ("Output").
- Feedback Signals: ratings, written feedback, and reported-issue flags you submit in relation to an Output.
- Correspondence: information you provide when you contact us for support, including the contents of your message.
2.2 Information We Collect Automatically
- Technical & Device Data: IP address, browser type and version, operating system, device identifiers, language settings, time zone, and referring URL.
- Usage Data: session timestamps, features used, languages selected, character/word counts processed, download events, and history views.
- Cookies & Similar Technologies: cookies for authentication and session management, and, only where you have consented (where consent is required), analytics cookies and tags set by Google Analytics 4 (see Section 8).
- Security & Diagnostic Logs: request logs, error traces, rate-limit events, and abuse-detection signals retained for the purposes set out in Section 3.
2.3 Information We Do Not Want You to Submit
ATLAS is not designed for, and you must not submit through it: (a) special categories of personal data under Article 9 GDPR (including health, biometric, genetic, racial, ethnic, religious, political, sex-life, sexual-orientation, or trade-union data); (b) personal data of children under the age of 13 (or the higher age of digital consent applicable in your jurisdiction); (c) government-issued identification numbers, financial account or payment card details, or login credentials; (d) confidential business information or third-party personal data you are not authorised to disclose; or (e) content that infringes intellectual property rights or violates applicable law. We may filter, refuse to process, or remove such content.
3. Why We Use Your Information and Our Legal Bases
We process your personal information for the purposes set out below. For users in the EEA, the United Kingdom, and Switzerland, the corresponding legal bases under Articles 6(1) GDPR / UK GDPR are indicated.
| Purpose | What This Means | Legal Basis (EEA/UK) |
|---|---|---|
| Provide the Service | Authenticate you, accept your Input, route it to our AI providers, return Output, maintain your session and history, and allow downloads. | Performance of a contract (Art. 6(1)(b)) |
| Quality, Debugging & Improvement | Use feedback signals and logs to monitor Service quality, diagnose errors, and improve ATLAS features and prompts (without using your Input/Output to train AI models; see Section 5). | Legitimate interests (Art. 6(1)(f)) |
| Security & Fraud Prevention | Detect and prevent fraud, account abuse, automated scraping, prompt-injection, denial-of-service, and violations of our Terms of Use. | Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
| Analytics | Measure aggregate usage, performance, and adoption through Google Analytics 4, subject to consent where required. | Consent (Art. 6(1)(a)) |
| Legal & Compliance | Comply with applicable laws, respond to lawful requests, enforce our Terms, and protect our rights and the rights of others. | Legal obligation (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f)) |
4. AI and Infrastructure Service Providers
ATLAS relies on third-party processors and sub-processors operating under written data-processing agreements that incorporate appropriate technical and organisational safeguards and, where relevant, the European Commission's Standard Contractual Clauses ("SCCs") or the UK International Data Transfer Addendum.
- AI model providers: Anthropic, PBC and Google LLC (or affiliated entities) process your Input to generate Output on our behalf.
- Analytics providers: Google Analytics 4 (Google LLC): deployed only with consent where consent is legally required.
- Identity provider: Google LLC (Google Sign-In) for authentication.
5. No Use of Your Content to Train AI Models
We do not use your Input or Output to train, fine-tune, or otherwise improve any generative AI or foundation model, whether owned by Pocket FM, Anthropic, Google, or any other third party. Our contracts with Anthropic and Google prohibit them from using your Input or Output for their own model-training purposes. Feedback signals are used only for product quality monitoring, evaluation, and debugging, and are not used as training data for AI models. If this practice ever changes, we will update this Notice, provide prominent advance notice, and, where required by law, obtain your prior, separate consent.
6. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes set out in this Notice, unless a longer period is required or permitted by law.
- Input and Output: retained for up to ninety (90) days from creation, after which they are deleted or irreversibly anonymised.
- Feedback signals: retained in pseudonymised form for as long as necessary for quality and safety analysis.
- Account and authentication data: retained for the duration of your ATLAS account, except where longer retention is required for legal, accounting, or dispute-resolution purposes.
- Security and abuse-prevention logs: retained for as long as necessary to provide the service and for the purposes described in this notice, except where longer retention is required for legal, accounting, or dispute-resolution purposes.
- Analytics data: retained for up to fourteen (14) months.
7. How to Access or Delete Your ATLAS Information (AYI/DYI)
You can access or delete your ATLAS information (AYI/DYI) at any time through the following channels:
- Account closure: request closure of your ATLAS account at privacy@pocketfm.com; closure triggers deletion of your Input, Output, and feedback history.
- Email request: send an information access or deletion request toprivacy@pocketfm.com from the email address associated with your ATLAS account.
We will action verified deletion requests within thirty (30) days, and complete deletion from our active systems within sixty (60) days of the request, except where longer retention is required for legal, accounting, fraud-prevention, or dispute-resolution purposes.
8. Cookies and Similar Technologies
ATLAS uses two categories of cookies and similar technologies:
- Strictly-necessary cookies: required for authentication, session management, load balancing, and security. These are set without consent because they are essential to deliver the Service you request.
- Analytics & product-experience cookies: set by Google Analytics 4 to measure usage and detect irregular behaviour. In the EEA, the United Kingdom, Switzerland, Brazil, and any other jurisdiction where prior consent is legally required, these are set only after you affirmatively consent through our cookie banner.
9. No Advertising or Cross-Context Behavioral Use
We do not sell or share your ATLAS Input, Output, feedback, or account data for cross-context behavioural advertising, profiling for advertising purposes, or any form of targeted advertising, within the meaning of the California Consumer Privacy Act / California Privacy Rights Act ("CCPA/CPRA"), the Colorado Privacy Act, or analogous laws. ATLAS data is not made available to advertising partners.
10. International Data Transfers
ATLAS is offered globally. Your personal information may be transferred to, stored in, and processed in countries other than your country of residence, including the United States, India, and the European Economic Area. Where personal data is transferred from the EEA, the United Kingdom, or Switzerland to a country that has not received an adequacy decision, we rely on appropriate safeguards, which may include standard contractual clauses approved by the relevant authority, binding corporate rules, or other recognised transfer mechanisms, together with any supplementary measures required by applicable law. A copy of the relevant transfer mechanism is available on request.
11. Your Privacy Rights
Depending on where you reside, you may have the following rights in respect of your personal information:
- Access, rectification, and erasure of your personal information;
- Restriction of, or objection to, certain processing;
- Data portability, to receive your data in a structured, commonly-used, machine-readable format;
- Withdraw consent at any time where processing is based on consent;
- Opt out of sale/sharing, targeted advertising, and certain profiling (CCPA/CPRA and U.S. state privacy laws), note that, as stated in Section 9, we do not engage in these activities in respect of ATLAS data;
- Non-discrimination for exercising your rights;
- Lodge a complaint with your local supervisory authority (for EEA users), the Information Commissioner's Office (for UK users), or the relevant data protection authority in your jurisdiction.
To exercise any of these rights, contact privacy@pocketfm.com. We will respond within the time frames required by applicable law (30 days under the GDPR; 45 days under the CCPA/CPRA, extendable where permitted). We may need to verify your identity before fulfilling your request.
12. Notice at Collection (California Residents)
Consistent with the CCPA/CPRA and the California Attorney General's guidance, this Notice serves as our notice at collection for California residents. The categories of personal information we collect, the purposes of collection, and our retention periods are described in Sections 2, 3, and 6. We do not sell or share personal information, and we do not use or disclose sensitive personal information for purposes other than those permitted under Cal. Civ. Code § 1798.121.
13. Children
ATLAS is not directed to, and we do not knowingly collect personal information from or about, individuals under the age of thirteen (13), or the higher minimum age applicable in your jurisdiction. If you believe a minor's personal information has been provided through ATLAS, please contact privacy@pocketfm.com.
14. Changes to This Notice
We may update this Notice from time to time. Material changes will be communicated by updating the "Last Updated" date and, where required, by prominent in-product notice or email. Your continued use of ATLAS after the effective date constitutes acceptance of the updated Notice.
15. Contact Us
Questions, requests, or complaints relating to this Notice or your personal information should be directed to:
ATLAS - Privacy Team
Email: privacy@pocketfm.com
Postal address: Indiqube Royal Arcade, No. 6, 80 Feet Road, KHB Colony, Koramangala Industrial Layout, Koramangala, Bengaluru, Karnataka-560034, India