︎OUR PRIVACY POLICY
Effective as of: 5 December 2021
The Locked Stack Privacy Policy is designed to give you a comprehensive understanding of the steps that we take to protect the personal information that you share with us.
Who decides how your information is used?
Locked Stack Ltd. (71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ) generally is the data controller responsible for making decisions about how we use your personal information in the United Kingdom (UK) and the European Economic Area (EEA)
If you have any questions or comments on this policy, you can:
Email us at contact@lockedstack.com
Contact our Data Protection Officer at dpo@lockedstack.com
The information we collect about you and how we use it
This Privacy Policy covers our use of any information that can or could be used to identify you (“Personal Data“). It does not cover information which cannot be used to identify you (“Anonymous Data“).
We need to collect and use certain Personal Data to provide the Services to you and fulfil the promises we make to you in the Terms of Service:
When you sign up for our Services you give us Personal Data voluntarily by providing it to us. We collect and use that information in order to provide you with our catalogue of Services, to make sure you are eligible and able to receive the Services. That information includes your full name, company name, email address and contact telephone number.
The Personal Data we collect will always remain the same irrespective of which services you choose to use.
Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.
Using your email address and device information in order to share updates and news with you by email.
You can unsubscribe from these at any time.
To offer new or additional features for our Services.
To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.
We will only use your Personal Data to do the following if we have your consent.
Send you marketing materials by email You can unsubscribe from these at any time.
We also rely on your consent where we use cookies or similar technologies.
Please see our Cookie Policy for more information about how we use them. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.
Who we share information with
We will not share any Personal Data that we have collected from or regarding you except as described below:
Information Shared with Our Service Providers. We engage external service providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These external service providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The service providers we use help us to: run, operate and maintain our Services through third party platform and software tools; perform analytics; provide technical and customer support.
Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third-Party Service in accordance with their own privacy policy. Such external service provider does not share your financial information, like credit card number, with Locked Stack Ltd., but it may share limited information with us related to your purchase, like your postal code.
Information Shared with Third Parties
We share Anonymous Data with third parties for services analysis. We do not share Personal Data with any third parties for their direct marketing purposes.
Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.
Information Disclosed in Connection with Business Transactions. Information that we collect from our customers, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.
How your Personal Data is transferred
Locked Stack Ltd. operates its Services across the globe. Your Personal Data will however never be transferred and stored in a country outside of the EEA, including in the USA, for the purposes outlined in this Privacy Policy to the extent permitted by applicable laws. The data protection laws in these countries may not be the same as in your home country.
If you require that we transfer your Personal Data from the UK or the EEA to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the UK or the EEA, as applicable, by ensuring that at least one of the following safeguards is implemented:
The country that your Personal Data is transferred to is a country that the European Commission (or the UK Government, if you are based in the UK) has deemed to provide an adequate level of protection for Personal Data as the UK or the EEA, as applicable.
We use specific contracts approved by the European Commission (or the UK Information Commissioner’s Office, if you are based in the UK), which give Personal Data the same protection as it has in the UK or the EEA, as applicable, when we engage with service providers.
How we keep your Personal Data safe
We have appropriate legal, organizational and technical security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we will keep your Personal Data
We keep your Personal Data for as long as we need to provide the Services to you and fulfil the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.
When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.
Your rights and choices
You have certain rights in relation to your Personal Data. This means you can:
Request access to the Personal Data we hold on you by emailing dpo@locked Stack.com
Delete or correct your Personal Data.
Ask us to stop processing your Personal Data, including for direct marketing and promotional purposes.
Have your Personal Data transferred to another organization (where it is technically feasible).
Complain to a regulator. We’d appreciate the chance to deal with your concerns directly, so we’d prefer you to contact us first. However, if you’re based in the UK or the EEA and believe that we have not complied with data protection laws, you can complain to your local supervisory authority.
If you’re based in the EEA, you can also contact our EU Representative, DPO. DPO can be contacted by using DPO’s email: dpo@lockedtack.com
The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.
We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to use the services we provide.
Children
Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not collect Personal Data from them. We define “children” as follows:
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Residents of the UK: anyone under 13 years old.
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Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.
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Residents of the Republic of Korea, anyone under 14 years old.
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Residents of other regions: anyone under 13 years old or the age needed to consent to the processing of personal data in that region.
Changes to this Privacy Policy
Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.
Third Parties
In using our Services you may access links to websites and services that are owned or operated by third parties (each, a “Third Party Service”). Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third Party Service that you access.