Privacy Policy

Last updated: November 27, 2023

1. Introduction

Locket Labs Inc., its subsidiaries and affiliates (collectively “Locket”, “us”, “we”, or “our”) operates the Locket Widget mobile application, which allows users to share photos and videos on the home screens of the phones of their friends and to connect with people they might know (our “Services”).

We are committed to protecting your privacy. This Privacy Policy (“Policy”) describes how we collect, process, share and safeguard Personal Data that is collected through or in connection with the Services. It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any questions or concerns. Some features may be disabled depending on your location to comply with local laws.

2. Personal Data we collect

We collect Personal Data about you from different sources listed below. In this Policy, “Personal Data” means any information related to an identified or identifiable individual, and does not include data whereby personally identifiable information has been removed (such as anonymous data).

Personal Data You Provide to Us

• Account information: When you create an account with us we collect your phone number, email, full name, and birthday (day and month).
• Contact information of your friends: Locket may, with your permission, access your mobile contact list including saved phone numbers and names, to help you connect with people you know on Locket.
• Photos and videos: When you choose to send a photo or video to a friend’s Locket Widget, you provide Locket with the photo or video taken and associated metadata, including the file type and size, and the time the photo or video was taken.
• Correspondence and other communications: When you contact us, including about our Services, via email, social media or by other means, you provide us with Personal Data, such as your full name, email address, telephone number and the content of your communications.
• Payment information: Our payment processor(s) will collect the financial information necessary to process your payments, including name, payment card information, and billing information. Our third-party payment processors will handle your payment information in accordance with their own privacy policy. We do not have access to your full payment card information.
• Chat messages and reactions: When you choose to send messages and reactions to friends on Locket, you provide Locket with the message or reaction sent. We may review the contents of these messages if a user reports, or we otherwise detect, a potential trust and safety violation or potentially illegal or illicit activity or violations of our Terms and Conditions, as permitted by applicable laws.

Where you provide us with the Personal Data of third parties, such as people in your mobile contact list, it is your responsibility to inform them about the processing of their Personal Data in accordance with this Policy, and to confirm that they have given their permission.

Information Collected via Automated Means

• Device data: We collect information about your device such as your mobile device’s operating system type and version, manufacturer and model, browser type, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
• Usage data: When you access and use the Services, we receive and store information about interactions with our Services, including pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Please read our Cookie Policy for more information about how we use cookies and similar technologies

Information We Receive from Third Parties

• We maintain pages on social media platforms, such as Facebook, TikTok, Twitter and Instagram, that collect and process your Personal Data in accordance with their own privacy policies. You or the platform providers may provide us with information through the social media platform, and we will treat such information in accordance with this Policy.
• If you are a mobile contact of a Locket user and that user has given Locket permission to access their mobile contact list, Locket may collect and process your phone number from that list.

3. How we use your Personal Data

We will use your Personal Data for one or more of the purposes set out below:

• To provide you with the Services. We use your Personal Data to operate, maintain and provide you with the Services to perform any contract we have with you under the Locket Terms and Conditions. In particular we use Personal Data to allow you to create and use an account, add contacts and upload photos to share on friends’ Locket Widgets. The Personal Data we process when doing so includes your account information, contact details of your friends and photos you choose to upload.
• To provide you with special features. It is in our legitimate interests to use your Personal Data to create special features such as anniversary video collages using photos you have uploaded and usage information.
• To enable you to sync your mobile contact list to find and connect with people you may know on Locket and to invite new people to join Locket more easily. We will only access your mobile contact list with your consent. You can withdraw this consent at any time by changing your phone settings, or contacting us as set out in the “Contact Us” section below. It is in our legitimate interests to process the mobile contact details, such as the phone number, of individuals in your mobile contact list to enhance your user experience by enabling you to find and connect with people you know on Locket.
• To provide you with support and to respond to your requests and complaints. If you reach out to us for support, it is in our legitimate interests to use Personal Data to respond and resolve your queries and facilitate support. The Personal Data we process when doing so includes your correspondence with us, your contact details, and to the extent applicable other Personal Data processed about you when you use our Services.
• To communicate with you about our Services. It is in our legitimate interests to communicate with you about our Services including by sending you announcements, updates, security alerts, and support and administrative messages. The Personal Data we process when doing so includes your contact details, account information and usage data.
• To send marketing and promotional messages. Except where we rely on your consent, it is in our legitimate interests to send marketing and promotional messages relating to our Services, or the services of our affiliates and subsidiaries, that we believe will be of interest to you, in accordance with applicable law.
• To measure the effectiveness of advertising campaigns to promote the Services. Except where we rely on your consent, it is in our legitimate interests to use your Personal Data to track the effectiveness of advertising campaigns. Please see our Cookie Policy for more information.
• To show you ads on the Services. We engage advertising partners, including third party advertising companies and social media companies, to display ads on the Services. We use technologies provided by such parties, such as SDKs, to collect information about you over time across the Services, and we and our partners use that information to serve online ads that may be interesting or useful to you. The information we collect for such purpose includes your profile information and your activity on the Services. Except where we rely on your consent, it is in our legitimate interests to use your Personal Data for the purposes described above. Please see our Cookie Policy for more information on how we use these technologies and your choices for limiting interest-based advertising.
• To improve or monitor usage of our Services and to protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity. It is in our legitimate interests to improve and keep our Services safe for our users, which includes conducting troubleshooting, testing and research and to keep the Services secure. When doing so we may use Personal Data that we automatically collect about you such as usage and device information.
• To monitor and analyze trends and use of our Services. It is in our legitimate interests to analyze the use of our Services. When doing so, we will process Personal Data that we automatically collect about you or that is generated about you when you use the Services.
• To enforce the Locket Terms and Conditions, to comply with legal obligations and to defend Locket against legal claims or disputes. It is in our legitimate interests to enforce and comply with our terms and policies, to ensure the integrity of our Services and to defend ourselves against legal claims or disputes. Where we do so, we will use the Personal Data relevant to such a case. Some processing may also be necessary to comply with a legal obligation placed on Locket for example to keep records of transactions, or as requested by any judicial process or governmental agency.
• For aggregation and anonymization. It is in our legitimate interests to aggregate or anonymize Personal Data in a form that does not allow users to be personally identified and use the resulting information for statistical analysis regarding the use of the Services, such as to better understand our customer base, or for other purposes.

We will only process Personal Data on the basis of our legitimate interests where such interests are not overridden by your interests or your fundamental rights and freedoms.

If, where we are processing your Personal Data to perform our contract with you, you do not provide the Personal Data, we may not be able to conclude or fulfill such contract.

4. How we disclose your Personal Data

We disclose Personal Data about you with the following recipients and in the following circumstances:

• Affiliates: Affiliates and subsidiaries of Locket, for purposes consistent with this Policy.
• Service Providers for the provision of our Services: We rely on vendors and service providers solely for the provision of our Services and for the purposes set out above, such as providers of analytics, hosting and cloud computing services and other IT services and customer support services in addition to other administrative services, and advertising technology vendors. These third parties may have access to or process your Personal Data as part of providing these services.
• Advertising Partners: We share information that you provide through the Services or that we automatically collect (described under “Information Collected via Automated Means” above), such as the links you click, pages you visit, IP address, advertising ID, and device type, with advertising companies for interest-based advertising. Sharing this information allows us and our advertising partners to target and serve advertising to you.
• Advisors: We work with various advisors, including tax consultants and legal advisors, to whom we may disclose your Personal Data.
• Legal: Information about our users, including Personal Data, will be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Locket, users, a third party, or the public.
• Business Transaction: If Locket is involved in a merger, acquisition or asset sale, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data may be sold, transferred or otherwise disclosed including as part of any due diligence process.

You can use Locket to share photos and videos with your friends.  Once you’ve sent a photo it isn’t possible to delete it from other user’s phones, even if you delete it from your own, so please be careful what photos you choose to send.

5. Your rights and choices

1. Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “Contact us” section below. You may continue to receive Services-related and other non-marketing emails from us.
2. Limit online tracking. Some internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Please see our Cookie Policy for more information on your choices relating to our use of cookies and for limiting interest-based advertising.
3. Personal Data requests. We also offer you choices that affect how we handle the Personal Data that we process. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to Personal Data:
   • Information about how we have collected and used Personal Data. We have made this information available to you without having to request it by including it in this Policy;
   • Access a copy of the Personal Data we hold about you;
   • Correction of Personal Data that is inaccurate or out of date;
   • Deletion of any Personal Data that we no longer need to provide the Services or for other lawful purposes. You can delete your account in your account settings;
   • Receive any Personal Data we hold about you in a structured and commonly used machine readable format or have such Personal Data transmitted to another company;
   • Opt out of selling Personal Data and sharing for targeted advertising We share information with third-party advertising partners and allow them to collect information about your use of the Services to show you ads on our Services as described in the “How we use your personal data” and “How we disclose your personal data” sections above. Our disclosure of information to these partners may be considered a “sale” or “sharing” of Personal Data or “targeted advertising” under applicable laws. You can opt out of these disclosures and limit our use of tracking technologies as described in our Cookie Policy or by clicking the “Your Privacy Choices” link in your Locket Widget mobile application.
   • Withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent;
   • Additional rights, such as to object to and request that we restrict our use of Personal Data.

   To make a request, please email us or write to us as provided in the “Contact us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

   In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us at privacy@locketcamera.com. Depending on where you reside, such as if you reside in the European Economic Area ("EEA”) or United Kingdom (“UK”), you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. For example, if you are based in the UK, you may choose to lodge a complaint with the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/.

6. International data transfers

If you provide us with your Personal Data when using the Services from the EEA, Switzerland or the UK 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 Data outside of those regions to the United States for storage and processing.

If we transfer your Personal Data internationally, these countries may not provide the same protections as the data protection laws where you are based.  We will ensure that relevant safeguards are in place to afford adequate protection for your Personal Data and we will comply with applicable data protection laws, in particular if you reside in the EEA, Switzerland or UK by relying on an EU Commission or UK government adequacy decision, on contractual protections for the transfer of your Personal Data or a derogation if available.  For more information about how we transfer Personal Data internationally, please contact us as set out in the “Contact Us” section below.

7. Children’s privacy

Our Services are not directed to children, and we do not knowingly collect Personal Data from anyone under the age of 13.  If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us as set out in the “Contact Us” section below.

8. Retention of Personal Data

We retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention procedures, and in accordance with applicable laws or until you withdraw your consent (where applicable).

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Security of Personal Data

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of Personal Data we process.  Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your Personal Data, we cannot guarantee its security.

10. Links to other sites

The Services may contain links to other sites that are not operated by us.  If you click a third party link, you will be directed to that third party’s site.  We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11. Changes and updates to this Policy

We will update this Policy from time to time.  Please review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

If we make material changes, we will let you know.

12. Contact us

Locket Labs Inc. is the entity responsible for the processing of your Personal Data, and is the data controller in respect of such processing.  If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Data, please contact us by email at privacy@locketcamera.com

Alternatively, we have appointed VeraSafe Ireland Ltd. at Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland as our EU data representative, and VeraSafe United Kingdom Ltd. at 37 Albert Embankment, London SE1 7TL, United Kingdom as our UK data representative. You can contact our EU representative at the address above or alternatively using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +420 228 881 031. You can contact our UK representative at the address above or alternatively using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +44 (20) 4532 2003.