Last Updated: January 25, 2022

Pin Genie Inc., doing business as Lockly (“Lockly”, “we,” or “us”), has developed this Privacy Policy (this “Policy”)  to inform you, our users, how we collect, store, use, disclose, transfer, and share your personal information when you visit and use our websites, apps, mobile applications, networks, and any of Lockly’s products, devices, or services, comment or post on our social media sites, participate in our surveys, promotions, or signup or agree to receive information from us (collectively, the “Services”).  Your access and use of our Services constitute your acceptance of this Privacy Policy. Please be assured that we make every effort to protect the privacy of our users.

The Information We Collect 

• Information You Provide. You may provide us with information about you in various ways on the Service. For example, you may provide us with personal information when you register for the Service, download and install our mobile applications, make a purchase of the Service, or send us customer service-related requests. The information we collect may include your contact information such as name, email address, phone number and postal address. We may also collect registration and account details such as user name and password. If you purchase a product or service from us, we will also collect payment information, such as name, billing address and payment details. 

 Collection of Information by Automatic Means. When you use and interact with our Services, we obtain information by automated means, including through cookies (You can choose whether to accept cookies by changing the settings on your browser), web server logs, web beacons, and other technologies.

• We may collect information through these means regarding customer activities on our website, and from our other products and services. The information we obtain may include language preference, device IP address, device characteristics, unique device identifier, referrer URL, GPS location, and the time zone where Lockly applications are used.If you use our Lockly Smart Lock product, we collect technical information about your product, such as your wifi network information and your product’s model, serial number and software version.
• We may collect and store details of how you use our services, including search queries. 
• With your consent, we may collect data about how you use or interact with Lockly applications in order to help app developers improve our apps.

 Information from Other Sources. We may obtain information, including personal information, from third parties and sources other than the Service, such as our partners and advertisers. We may also obtain information from third-party social media services (e.g., Facebook) or payment services if you choose to link to, create or log into your Lockly account through these services (including when you share Lockly content via your social media account.

How we use the information we collect. 

We use the information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:

• To operate, maintain, enhance and provide all features of the Services.
• To provide services and information that you request.
• To respond to comments and questions and otherwise to provide support to users.
• To process and fulfill claims and orders in connection with the Services.
• To identify and authenticate you so that you may use the Services.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To contact you for administrative purposes such as customer service or (ii) to send communications on service announcements and service updates, promotions and events, and on products and services offered by us and by third parties we work with. Generally, you have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
• To satisfy our legal obligations, resolve disputes, enforce our agreements and other policies.
• We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Lockly applications, services, and customer communications.

When we disclose information. 

Except as described in this Policy, we will not disclose your information that we collect on the Service to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances 

• We work with third-party service providers to provide the website, application development, hosting, maintenance, payment processing, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
• We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
• We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• Information about our users may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

 Your Choices

You may decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your account information and preferences at any time by accessing your account preferences page on the Service. If you wish to access or amend any other personal information we hold about you, you may contact us at support@lockly.com. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained in the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by email at support@lockly.com or by writing to us at the address given at the end of this policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Service.

Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service. 

Third-Party Services

The Service may contain features or links to Web sites and services provided by third parties for in-app purchase related matters. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Children’s Privacy

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Service at any time or in any manner. If we learn that personal information has been collected on the Service from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on the Service, then you may alert us at support@lockly.com and request that we delete that child’s personal information from our systems.

Location-Based Services

To provide location-based services on Lockly applications, Lockly and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of when you use Lockly applications. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Lockly and our partners and licensees to provide and improve location-based services.

Some location-based services offered by Lockly, such as the “Catch Intruders” feature, require your personal information for the feature to work.

Data Security

We strive to maintain adequate technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of personal data that we collect and maintain. When your personal data is stored by Lockly, we use computer systems with limited access housed in facilities using physical security measures. However, no method of transmission over the phone, internet, and method of electronic storage, is 100% secure. We cannot guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Your consent to this Policy followed by your submission of such information indicates your understanding and acceptance of such risks.

When you use share and post on Lockly applications or social networking services, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

International Visitors

The Service is hosted in the United States and is intended for visitors located within the United States. All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from United States law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing. 

Also, we may transfer your data from the United States and to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including personal information, on or to the Service, you consent to such transfer, storage, and processing.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights and obligations, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made. Your continued use of the Services after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of the Policy. 

Your California Privacy Rights

The California Consumer Privacy Act (“CCPA”) affords the Californian consumer specific rights regarding personal information. These rights have been generally described in this policy overall and are further highlighted in this section. If you have a specific question or concern about your rights, or questions about our policy in support of your rights as a Californian consumer, please contact us by email at support@lockly.com.

What is Personal Information under the CCPA?

 “Personal information” is anything that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Your Rights with regards to your Personal Information:

You have the right as a Californian consumer to expect disclosures as to how we collect, use and care for personal data and we have provided these disclosures in the above sections of our Privacy Notice.

You can continue to expect us to disclose how we collect personal information and the sources from which we may obtain that information, and the specific personal information or categories of information that we have collected. You have a right to the disclosure of the business or commercial purposes we have for collecting personal information, the legal basis on which we do so, disclosure of the categories of personal information that have been transferred, shared or disclosed in the preceding 12-month period for commercial purposes, and the categories of recipients to which that personal information has been disclosed, shared, or transferred.

The CCPA requires opt in consent to data use for minors under the age of 16 and verified parental consent for children under the age of 13. If notified that children have provided data without appropriate process and consent, it will be deleted as immediately as practicable on advisement. Lastly, you have the right to ask what information we have about you specifically.

You may exercise these rights without concern. You cannot be denied benefits or services or charged differently for doing so. We, or our partners, on verification of your identity and legitimate standing to make the request, and if not an undue or unreasonable hardship for the company, shall act on your request, or at a very minimum, advise you as to why we cannot. There are specific reasons under the law which prevent accommodation of some requests, but if denied, we will advise as to why, to whom you may submit a complaint, and your options for challenge, redress or escalation.

We do not sell any personal information for the commercial benefit of any party. However, the term “sale” is defined broadly under the CCPA. As explained above, we do share with our service providers personal information that is necessary for such service provider to perform a business purpose. To the extent our use or disclosure of personal information is interpreted to constitute a “sale” under the CCPA, California residents are entitled to opt-out of the “sale” of their personal information at any time and can do so by contacting us.

You may request a disclosure describing what types of personal information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us at support@lockly.com, or by sending a letter to the address listed below.  You also have the right to request that we erase your personal information and for us to direct the same of any third-party service providers processing your data on our behalf.

Canada Residents

Your personal information may be sent to the United States for processing and while the information is in the United States it may be accessed by the courts, law enforcement and national security authorities, if required by law. Please be assured that we make every effort to protect the privacy of our Canadian users, including complying with the legal requirements of Canada’s federal privacy law, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and similar provincial laws in British Columbia, Alberta, and Quebec. Under these laws, you have the right to access of your personal information at minimal or no cost, including whether we have your personal information, how it is or has been used, and a list of any third parties to which it has been disclosed. We are obligated to respond to your request within 30 calendar days, unless your information falls under one of the exemptions listed in the PIPEDA. You can exercise your right to access by contacting us.

Our Contact Information

Please contact us with any questions or comments about this Policy, your Personal Information, our use and disclosure practices, or your consent choices by email at support@lockly.com.

If we have reasonable doubts about the authenticity of any request to us, we may request additional information necessary to confirm your identity.

LocklyPRO

2024 Macopin Rd,
West Milford, NJ 07480