Last updated 10/06/2022
Thank you for choosing to be part of our Locket community.
(It’s not 1999 Ltd or any group company; trading as Locket and referred to as “Locket”, “we”, “us”, or “our” in this document).
Locket is committed to protecting your personal information and your right to privacy.
1. What information do we collect?
When you register an account for one of our Apps or Services, fill in a form on our website, place an order with us, participate in one of our training events or otherwise contact or interact with us, you will normally voluntarily provide us with information about yourself in the process. We collect and store that information so that we can provide Services to you and improve them over time.
The personal information that we collect depends on the context of your interactions with us, the choices you make and the products and features you use. However, it can include:
Your Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Information automatically collected. Some information – such as your IP address, browser or device characteristics – is collected automatically when you use our Apps and Services. This information does not reveal your specific identity (like your name or contact information) but may details like the make and model of your device, its operating system, your country, the URL that referred you to our site and information about how and when you use our Apps and Services. This information is primarily needed to maintain the security and operation of our apps, and for internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
Information collected through our Apps
When you use our Apps, we may collect information about the way you use them in order to improve how the Apps and Services work.
Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address. We collect this information to secure and improve our Apps and Services.
Push Notifications. We may request to send you push notifications regarding Locket Products and Services through our mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Data from Products. We may collect data generated by Locket Products. We use this data to provide and improve our Services and for internal reporting.
Information collected from other sources
We may collect data from other sources such as public databases, marketing partners, social media platforms, and other outside sources. If you discover our Products and Services via a search engine like Google, that search engine provides us with information about your searching behaviour such as the search terms that lead you to our website.
2. How do we use that information?
We use the personal information we collect to conduct legitimate business operations, to provide you with Services, to fulfil our contractual obligations to you and other parties and to ensure compliance with our various legal obligations (“Business Purposes”, “Contractual Purposes” and “Legal Reasons”).
We use the information we collect or receive:
To facilitate our account creation and logon process. We use the information you willingly provide us with when creating an account to create that account and verify your identity when you subsequently log in.
To enforce our terms, conditions and policies.
To respond to legal requests and prevent harm. If we receive a legal request we may need to inspect the data we hold to determine how to respond.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, and to evaluate and improve our Apps, products, services, marketing and your experience.
3. Do we share your information with anyone else?
We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work.
For example: payment processing, data analysis, email delivery, hosting services, customer service, marketing. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used, among other things, to analyse and track activity and use of our Services. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
5. Do we transfer any of this information internationally?
We may transfer, store, and process your information in countries other than your own.
6. How long do we keep your information?
7. How do we keep your information safe?
We aim to protect your personal information through a system of organisational and technical security measures. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps and Services is at your own risk. You should only access them within a secure environment.
8. Do we collect information from minors?
We do not knowingly collect data from or market to children under 16 years of age.
By using the Apps, you represent that you are at least 16 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 16, please contact us at email@example.com.
9. What are your privacy rights?
Depending on where you live in the world, you have a set of rights as to how the data that companies collect about you gets treated. In the European Union, this typically includes the right:
To be told about the data that’s being collected and how it’s used.
To have access to the data that’s being collected and request a copy.
To have incorrect information about you corrected, or completed if it’s incomplete.
To ask for information about you to be deleted (although it’s not automatically granted).
To restrict how your data is used (although it’s not automatically granted).
To data portability, meaning you can take the data that’s been collected and reuse it for your own purposes across different services.
To object to the processing of your personal data under certain circumstances.
And rights relating to decisions about you that are made automatically, like profiling.
Wherever you live in the world you can amend your information via the Apps or by emailing firstname.lastname@example.org. You can also request that we terminate your account. Upon receiving your request to terminate your account, we will deactivate or delete your account and information from our active databases within 30 days, but some information may be retained in our files as detailed in “How long do we keep your information”.
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.
10. Do we make changes to this policy?
11. Who can I contact about this policy?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Andrii Votiakov, by email at email@example.com, or by post to:
It’s Not 1999 Ltd
5 Jardine House, Bessborough Road,
Harrow HA1 3EX,