Last Updated: January 25, 2022
The Information We Collect
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.
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:
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
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 email@example.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 firstname.lastname@example.org 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.
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.
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 email@example.com and request that we delete that child’s personal information from our systems.
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.
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.
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 firstname.lastname@example.org.
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 email@example.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.
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 firstname.lastname@example.org.
If we have reasonable doubts about the authenticity of any request to us, we may request additional information necessary to confirm your identity.
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Saint Paul, MN 55114