PRIVACY POLICY

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LOCKING PARTNERS, S.L. (from now on “We”, “Us” or “Our”)  is a limited liability company located in Plaza de los Reyes Magos, 9, 9E, 28007, Madrid, Spain, and with CIF nº B-87902318 and Madrid Mercantile Registry on August 30 of 2017 under Tomo 36318, Folio 140, .Sec GNE, Hoja 652494; we appreciate your confidence in our services and one of our prime commitment is the protection of your personal information and your privacy rights during your visit sessions in our site www.lock-io.com (“website”, “web”) and/or download, install and use our application “lockIO” (“application”, “app”). This Privacy Policy establishes how we collect, manage and/or disclosure the personal information you give us when you use our website and/or when you use our application. 


1. ABOUT YOUR PERSONAL INFORMATION

1.1. - Your Personal Information. There are many features in the website or application that may not require you to input any kind of personal information, but if you want to access the premium service, we may require you to provide us with certain contact information. We don't collect information if it's not necessary to accomplish the task.

1.2. - Additional Information. When you browse our website, we automatically receive and store your computer’s internet protocol (“IP”) address in order to provide us with information that helps us learn about your browser, operating system, and preferences. We may collect this additional information when users visit the website, not necessarily being registered members. When you visit our website, we may collect, store and/or use the following information: how many users visit our website; information about your use and/or transactions on the website and/or application, and pages accessed; country of the users that visit our website, and/or any other information related to the transaction taking place. By collecting this information, we may learn how to customize our website to our users. We may track domain names, IP addresses, demographic locations, browser applications, and other technical information from users (registered and non-registered) who visit our website.

1.3. - Use of Information. To ensure we deliver an optimal performance in our website, we may use the personal and additional information we gather from our users to enhance our service in the platform. We may use this information for the following reasons, not being limited to but rather explanatory: for marketing and promotional purposes, for statistical analysis of user’s, for product development and/or content improvements and to customize the content of our website. We may use this information to send you products and goods, statements and invoices or marketing communications. Also, we may share this information with third parties if we choose to aggregate and disclose our website traffic information for marketing or commercial purposes.


2. CONSENT

2.1. - Consent. Whenever you provide us with personal information via email, request a refund, and/or install our application, you consent the collection and/or use this information for that specific reason only, and as set forth in this privacy statement.

2.2. - Express Consent. If we need your personal information for secondary reasons, like marketing or promotions, we will ask you directly for your expressed consent, or at least provide you with a proper way to decline our offer. 

2.3. - Withdrawal of Consent. If you change your mind and want to withdraw your consent for us to collect, use or disclose your information, you can contact us at contact@lock-io.com or mailing us at Plaza de los Reyes Magos, 9, 9E, 28007, Madrid, Spain.

2.4. - Age of Consent. By using our website or installing our application, you declare that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your express consent to allow any of your minor dependents to use our website. In accordance with the United States Federal Children's Online Privacy Protection Act (COPPA), we do not collect personal information from children under thirteen years of age without the express consent of their parents or a legal guardian. When someone under thirteen years of age attempts to register, he/she will be required to provide the email address of his/her parent or legal guardian, and then we contact their parents or legal guardians and let them know of the child’s registration process. If they give their consent for the children to use our services, we proceed to open his/her user account. However, once downloaded the application and purchase a premium version, we will not sell, transfer or provide to any third-parties this personal information, and/or use it for marketing and promotional purposes. At any time, we understand and imply that parents and legal guardians have given approval to the child to attain this version. In any case, parents and legal guardians can ask to review the personal data and actions gathered about their child, if so please contact us at contact@lock-io.com

 

3. EU USER CONSENT POLICY

3.1. - Since we use Google products that incorporate this tracking of information like Admob and Firebase in our app and Analytics for our website, certain disclosures must be given to and consent obtained from end users in the European Union where EU data protection law requires such disclosures and consents. For end users in the European Union: (1) We commit to use commercially reasonable efforts to disclose clearly, and obtain consent to, any data collection, sharing and usage that takes place on any site, app, email publication or other property as a consequence of your use of Google products; and (2) We ensure you that we use commercially reasonable efforts to ensure that an end user is provided with clear and comprehensive information about, and consents to, the storing and accessing of cookies or other information on the end user’s device where such activity occurs in connection with a product to which this policy applies.


4. DISCLOSURE OF PERSONAL INFORMATION

4.1. - We are willing to protect your privacy by all technical and legal means but sometimes we may disclose your personal information if we are required by law to disclose it to a government official or to a law enforcement officer, as in response to a subpoena, warrant, court demand, or other properly issued legal processes.


5. PERSONAL DATA COLLECTED

5.1. - Whenever you access our website, send us an email or install our application, we might gather and record some personal data from you. We use tools that automatically collect certain information about our users but we would like to indicate first and most importantly: We do not acquire, sell, transfer, or modify from the data collected by us or any of our third-party services.

5.2. - Website. We use a tool called Google Analytics to measure growth which records the I.P address, the country where the access was made and mobile carrier from the user. It does not gather names, addresses or any other identifiable data about yourself. Our website was built using Mobirise and it has a built-in feedback system to send requests or form to contact us. Whenever you send us a message using our contact form, we automatically collect your name, email and I.P. address. This is done to provide a customized response to your inquiries and requests. Also, remember to revise our Cookies Policy to learn more about these tracking devices.

5.3. - lockIO App. Our app lockIO incorporates several SDKs, libraries and development tools from different providers (and their purpose) which will be shown next. These are Google's Android Support Libraries (API used to make our app available for older Android versions); Firebase (for tracking users app usage, retention and other in-app metrics); Google Cloud Messaging GCM (to send data from servers to our app) and Admob (to deliver banner ads); Chartboost (to deliver interstitial ads); OneSignal (to send push-notifications to users); Glide (image loading and caching library to provide smooth scrolling); and Universal Image Loader (library for image loading, caching and displaying). Some of these third-party SDKs and libraries (Firebase, GCM, Admob, Chartboost, OneSignal) collect non-identifiable information about our users, like IP Address, Country, Device Manufacturer, Mobile Carrier or Age. These informations are collected to improve your user experience, send push notifications, fix issues related to our app and to serve proper advertisements to you.

5.4. - Retention. All users data will remain in our possession as long as you keep lockIO installed. If you want to suppress or delete information that is required for us to deliver a certain feature, please contact us. All information received via emails or website thru our contact form will be deleted passed 30 days after receiving it.


6. THIRD-PARTY SERVICES

6.1. - In general, we only allow third-party providers used by us to gather, use and disclose your information only to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. 

In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than you. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction in which that service provider or its facilities are located. Once you leave our website and/or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms and Conditions


7. SECURITY

7.1. - To protect your personal information, we take reasonable precautions and follow industry top practices to make sure your personal information never gets lost, misused, accessed, disclosed, altered or destroyed by third-parties not authorized to reach that data. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements, encryption and implement additional generally accepted industry standards of data protection, in compliance with the GDPR.


8. MODIFICATIONS TO THIS PRIVACY POLICY

8.1. - We reserve the right to modify this Privacy Policy at any time, so be sure to check it out frequently although we'll notify you if there is any change that affects directly with your rights  Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will post on this website, so that you are aware of what information we modified, how to use any new feature, and under what circumstances we use or disclose any personal information.


9. USERS RIGHTS

9.1. - If you want to limit, port, access, correct, update or delete any personal information we have about you; if you do not wish to continue receiving our emails or simply want more information about your privacy rights, contact us at contact@lock-io.com or by mail at Locking Partners, S.L. address: Plaza de los Reyes Magos, 9, Apt. 9E, 28007, Madrid, Spain.


10. APPLICABLE LAW

10.1. - Since Locking Partners, S.L. is a Spanish corporation this Privacy Policy is governed by the Spanish legislation (LOPD) and EU's GDPR.


EFFECTIVE DATE: MAY 25th, 2018