Privacy Policy
PRIVACY POLICY
Lock In LTD is committed to protecting and respecting your privacy in connection with our applications (“Apps”) and other products, services and features thereof (the Website, the Apps and such other products, services and features are collectively referred to herein as the “Product” or “Products”, which may be updated from time-to-time at the sole discretion of Lock In ). This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Products will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data.
1. DATA WE MAY COLLECT
We may collect and process the following data about you:
- Personal data including, for example, your name, e-mail address, password, and data about your usage of the Services, data you provide in connection with your usage of our Services, and data collected by tracking technologies.
- Lock In does not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data with respect to in-app purchases made through the Apps.
- For individuals using the Their organisations for our Services, your business data such as your company name, and company email address will be collected and stored.
- Data collected via tracking technologies, as fully described in section 5.
2. USES MADE OF THE DATA
We use information held about you in the following ways:
- To provide you with our Services.
- To answer your questions or requests for information or handle your complaints.
- To ensure that content provided by our Services is presented in the most effective manner for you and for your computer or other device.
- To provide you with promotional communications, such as email, to the extent that you have provided consent and/or consistent with notice and any opt-out rights to receive such communications under applicable law.
- To carry out our obligations arising from any agreements entered into between you and us.
- To allow you to participate in interactive features of our Services, when you choose to do so.
- To notify you about updates or changes to our Services features and content.
- To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent and/or consistent with notice and any opt-out rights for such uses under applicable law.
- To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- To manage your payments and orders.
- If you are an existing customer, we will only contact you by electronic means (e-mail) with information about products and services similar to those which were the subject of a previous sale to you, except if you do not consent to, or opt-out to such communications.
3. CONFIDENTIALITY AND SECURITY
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at lockn233@gmail.com. Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law. Lock In maintains technical, administrative and physical safeguards to help protect the security of your personal information against unauthorised access, destruction, loss, alteration, misuse or disclosure. Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.
4. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
If you sign up to receive promotional materials from us via email and/or push notifications we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at lockn233@gmail.com, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level.
6. WHERE WE STORE YOUR PERSONAL DATA
All data you provide to us through our App is stored on Firebase. Any payment transactions will be encrypted using SSL technology; all payment data is stored with our payment processor and is never stored on Invent Track database. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.
Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our database; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
7. CORPORATE AND OTHER COMMUNITY SHARING
Lock In is also offered through partnerships with organisations. Sometimes corporations, governments, hospitals, universities and other organisations and groups (“Partner(s)”) wish to make Lock In available to their members, employees and their families, patients, customers, residents or others. For example, employers may offer their employees and their families access to Lock In and brands that promote wellness may wish to and do offer Lock In through their loyalty programs. When an entity provides access to Lock In to others, we call those “Communities.” If you have registered to use the Products through a code, credential, or other means of registration furnished by a Partner (a “Community Subscription”), the Partner may have access to your name, email address, the date you registered to use the Products, and the date on which you last used the Products. The Partner may also have access to your Community's aggregated and anonymised general usage data (including aggregated and anonymised usage data with respect to your Community’s optional engagement with the My Progress feature).
9. YOUR DATA RIGHTS
As you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are: A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. We provide an easy-to-view snapshot of such data via the “My Data” tab in our Service.
A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Lock In will permanently and irrevocably anonymise your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Lock In may have legal or legitimate grounds for keeping such data.
A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
A right to data portability: you have the right to receive the personal data concerning you which you have provided to Lock In, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Lock In. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Lock In. Lock In may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your Lock In account.
A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Lock In personal data protection practices.
A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Unbroken instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email lockn233@gmail.com. You may access your personal data to modify or update at any time via an online account, or by emailing unbrokenlimited@gmail.com. We will respond to your request in a reasonable timeframe in accordance with applicable law.
11. DISCLOSURE OF YOUR DATA
We may disclose your personal data with and among our subsidiaries, ultimate holding company.
We may also disclose your personal data to third parties as follows:
- In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfill a request for data from such party. An example of this is the SMS Service.
- In some circumstances, we may disclose the personal data that you have provided to Lock In to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options.
- In some limited circumstances, our email service provider may receive certain information you share in-app to provide you with personalized email communications.
- If Unbroken service providers (like hosting, IT maintenance, market analytics, and payment service providers) require this data to provide services to Lock In. Lock In requires each of its service providers to agree to maintain the confidentiality and security of your personal data.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Lock In or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of Lock In, our customers, or others. This includes exchanging data with other companies and organisations for the purposes of fraud protection and credit risk reduction.
12. DATA RETENTION
The retention periods applied by Unbroken comply with applicable legislation in effect on the date hereof, namely:
- For data relating to your account: such data will be permanently and irrevocably anonymised in the event that your account is: (i) inactive for a period of two (2) years; and (2) not subscribed to “Lock In Plus.” Moreover, we will permanently and irrevocably anonymise your account data within thirty (30) days of your written request to do so via email to lockn233@gmail.com.
- For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not Unbroken.
- For data collected based on your consent to receive our marketing communications: we will use such data until you opt out, withdraw consent or applicable law requires that such data is no longer used.
- When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.
- When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.
17. USE OF LOCK IN BY MINORS
You must be 4+, to sign up as a registered user of Unbroken. Individuals under the age of 12, may view the audiovisual content displayed in the Products only with the involvement and consent of a parent or legal guardian, under such person's account, and otherwise subject to these Terms. This provision shall not be applicable to registrations made under certain Community (as defined below) offerings where specified in applicable contracts between Lock In and the Community.
19. CHANGES TO OUR PRIVACY POLICY
We may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by in-Product message, email (sent to the e-mail address specified in your account) or by means of a notice in the Products prior to the change becoming effective. We encourage you to periodically review this page for the latest data on our privacy practices.
8. Contact Information
If you have any questions or comments about this CCPA Addendum, the ways in which we collect and use your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at Email: lockn233@gmail.com
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