Last updated: may 15, 2023
Unlockr (“us”, “we”, or “our”) is the operator of Unlockr (the "App").
We are committed to protecting your Personal Information and your right to privacy. If you have any questions or concerns about our policy, our practices with regards to your Personal Information or if you feel your rights may have been breached, please contact us at contact@unlockr.app.
When you use the App, we collect, process and transfer your Personal Information. In this Privacy Policy, we seek to explain to you in the clearest way possible what Personal Information and User Data we collect, how we use and transfer it and what rights you have in relation to it.
This Privacy Policy applies to all information and data collected through the App. This Privacy Policy is an integral part of our Terms of Use available [here] (the "TOU" and together with this Privacy Policy the "Terms"
Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your Personal Information with us. If you do not agree with this Privacy Policy or any of the Terms, your choice is not to use the App and you are required not to install the App, remove it from your device (if installed) and cease making any use thereof. By accessing or using the App, you agree to the Terms (including this Privacy Policy). This policy may change from time to time as provided below.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS POLICY?
12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE COLLECT?
While using the App, we may require you to provide us with certain personally identifiable information, including but not limited to your name, email address, company name, mailing address, and phone number ("Personal Information"). The Personal Information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use.
We also collect User Data, which is non-identifiable data collected automatically, generated by the use of the App ("User Data"). Any consent you provided hereunder with respect to your Personal Information, you provide with respect to any other User Data we collect, process and transfer (without derogating from any other right we may have in connection with such data). In jurisdiction which certain Personal Information may be treated as User Data, it shall be deemed as such (so we may use it freely and your consents hereunder shall continue to apply with respect to data so collected).
You have no legal obligation to provide us with any information or data, however some or all of the App features or services may not be available should such information or data will/may not be collected, processed or used.
2. HOW DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the App or otherwise contacting us. The personal information we collect can include the following:
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data. All payments are done via itunes and we have no access to your account or details. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you use our Apps.
We automatically collect certain information when you visit, use or navigate the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Information collected through our App
In Short: We may collect information regarding your mobile device, push notifications,
If you use our App, we may also collect the following information:
§ Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's storage, pages browsed on safari, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
§ Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
3. HOW WE MAY USE YOUR PERSONAL INFORMAITON?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use Personal Information collected via our App for a variety of business purposes described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the Personal Information we collect or receive: To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the Personal Information you allow us to collect from those third parties to facilitate account creation and the logon process.
§ To facilitate your use of the App. To facilitate your use of the App and to respond to your inquiries and solve any potential issues you might have with the use of the App.
§ To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with what we may believe are your marketing preferences. You can opt-out of our marketing emails at any time.
§ To send administrative information to you. We may use your Personal Information to send (or have send ) you product, service and new feature information and/or information about changes to our terms, conditions, and policies
§ Fulfill and manage your orders. We may use your information to fulfill and manage your orders, subscriptions, payments, cancelations, returns, and exchanges made through the App.
§ To manage user accounts. We may use your Personal Information for the purposes of managing our account and keeping it in working order.
§ To deliver services to the user. We may use your Personal Information to provide you with the requested service (including the Services as defined I the Terms).
§ To respond to user inquiries/offer support to users. We may use your Personal Information to respond to your inquiries and solve any potential issues you might have with the use the App or any of our Services (including in order to provide you with updates and upgrades of the App, if we decide to you to provide you with such).
§ For other Business Purposes. We may use your Personal Information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our App, products, marketing and your experience. We may use and store this data or information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information or otherwise.
§ Your IP address: Your “IP Address” is a number that is automatically assigned to the device that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user uses the App, along with the time of such use. We use IP Addresses for purposes such as calculating App usage levels, helping diagnose server problems, and administering the App. Please note that we treat IP Addresses, server log files and related information as non-Personal Information, except where we are required to do otherwise under applicable law.
§ Your browser. Certain information is collected through most browsers, such as your Media Access Control (MAC) address, device type, screen resolution, operating system version and internet browser type and version.
4. WILL YOUR PERSONAL INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. The third parties we share Personal Information with may be deemed as independent controllers of your Personal Information with their own responsibility and own policies and practices. We urge you to check such third parties privacy policies, we do not indorse or control their activities and disclaim any responsibility in connection therewith.
We may process or share data based on the following legal basis:
§ Consent: We may process your Personal Information if you have given us specific consent to use your personal information in a specific purpose (including as provided hereunder).
§ Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
§ Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract. For example the App may scan the device you have installed it on in order to try and locate threats and record files which it deem as a possible threat. Such files may contain your Personal Information.
§ Legal Obligations: We may disclose your Personal Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
§ Vital Interests: We may disclose your Personal Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies or rights, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
· Vendors, Consultants and Other Third-Party Service Providers. We may share your Personal Information with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: software support for the App, payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the App, which will enable them to collect data about how you interact with the App over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
Below, we list these partners and tools and their privacy policies:
· Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, all or a portion of our business to another entity or the financing thereof.
Third-Party Advertisers / service providers. We may use third-party advertisers to serve ads.These third parties may use information about your visits to websites that are contained in web cookies and other tracking technologies in
Advertising Partner
Service Provider
Data Categories Processed by Advertising Partner according to its Privacy Policy
One signal
Service that enables collecting and consent to push notifications and sending those push notifications. https://onesignal.com/ More information about data the provider collects and the way it used can be found here:. https://onesignal.com/privacy_policy
· Our Group. Legal entities within our group, we may share Personal Information with our shareholders, subsidiaries or entity which our shareholder hold interest (including shares) therein. our group includes:
· Payments. If you opt to pay for use of our services, we will use a third party payment processor to take payment from you. These are our long-term payment processors:
Payment Processor
Link to Privacy Policy
Apple Store (for mobile apps)
https://www.apple.com/legal/privacy/
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
6. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.
We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than year after you stopped using our app..
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures. However we cannot guarantee it will always be safe.
We have implemented what we deem as appropriate technical and organizational security measures designed to protect the security of any Personal Information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our App is at your own risk. You should only access the services within a secure environment. If you feel that the security of your Personal Information may have been compromised, please immediately notify us of at the email address provided below.
8. CROSS-BORDER TRANSFER
Your Personal Information and User Data may be stored and processed in any country where we have facilities, and by using the App you consent to the transfer of information to countries outside of your country of residence, which have different data protection rules than in your country. In some instances, these may be countries outside of the European Economic Area (“EEA”).
At the same time, when we transfer Personal Information outside of the EEA, we always make sure to put in place appropriate and suitable safeguards, such as standardized contracts approved by the European Commission or specialized regimes such as Privacy shield, which legally bind the receiving party to adhere to a high level of protection, and to ensure that your data remains safe and secure at all times and that your rights are protected
Situations where we transfer Personal Information outside of the EEA include provision of our products and services, processing of transactions and your payment details, and the provision of support services. Further, an outside-EEA transfer may also occur in case of a merger, acquisition or a restructuring, where the acquirer is located outside of the EEA (see the Mergers, Acquisitions and Restructurings section).
9. THIRD PARTY SITES
The App and/or our service may link you to third parties' content (including software, services and products), for example when providing you with advertising content. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the App contains a link. The inclusion of a link on the App does not imply our endorsement of the linked site.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 13 years of age. By using the App, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the App. If we learn that Personal Information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 13, please contact us at the email address provided below.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In some jurisdictions, you may have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Personal Information, (ii) to request rectification or erasure of your Personal Information; (iii) to restrict the processing of your Personal Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Personal Information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
· If you are resident in the European Economic Area and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
· Cookies and similar technologies. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Apps. To opt-out of interest-based advertising by advertisers on our Apps visit http://www.aboutads.info/choices/.
· Controls for Do-Not-Track Features Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the App, you have the right to request removal of unwanted data that you publicly post on the App. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the App, but please be aware that the data may not be completely or comprehensively removed from our systems
13. DO WE MAKE UPDATES TO THIS POLICY?
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated revised date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at contact@unlockr.app