Unlockd Privacy Notice Website
Your use of the Unlockd website at https://unlockd.com/ (Website) and how we use the information collected through the Website is governed by this Privacy Notice.
1. We are the Data Controller in respect of your personal data.
Our full name: Unlockd Limited
Our contact details: Suite 2, 111 Coventry Street, South Melbourne, Victoria 3205, Australia
Data Protection Officer’s email address: email@example.com
2. We collect the following information from you through your use the Website and/or one of the Unlockd Apps:
Information you give us during the App sign-up process
- Your mobile number;
- Your email address;
- Your age;
- Your gender; and
- Your interests
By registering with Facebook, you allow us to collect this information from your Facebook account. If you do register using Facebook, you may revoke our access at any time by amending the appropriate settings from within your account settings on Facebook.
Information you allow us to collect or provide to us
Location data. If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may collect and use that information to provide geographically relevant ads and offers. If you would like to deactivate this feature, you can disable location services on your device at any time, but please be aware that not all features of the App will work optimally without such location services.
We will also collect information that you provide to us when you correspond with us regarding your use of the Website, the Services or the App.
Information automatically collected
- Generally. The Website and/or the App may collect certain information automatically, such as: the type of mobile device you use, mobile device identifiers, such as the resettable advertising identifier assigned to your device, the IP address of your mobile device, your mobile operating system, Wi-Fi mac address in your area, the type of mobile Internet browsers you use, and information about the way you use the Website and/or the App. In addition, in the event our App crashes on your mobile device, we will receive information about your mobile device model software version, which allows us to identify and fix bugs and otherwise improve the performance of our App.
- Log Files. We gather certain information automatically and store it in log files (“Log Files”), including IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to improve the content of the Website, the App and Services, market research purposes, to communicate information to visitors and to better tailor the App and Services to our users’ needs, including to serve advertisements tailored to our users’ interests.
- Cookies. We may log information using “Cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience through our Website, the App and Services. This type of information is collected to make the Unlockd App and services more useful to you and to tailor the experience with us to meet your special interests and needs.
Collection of Information by Advertisers
We may work with analytics companies to help us understand how the Website and/or the App is being used, such as the frequency and duration of usage. We also work with advertisers and third party advertising companies that collect information about how you interact with advertising and content provided in the Website and/or the App. Advertisers and advertising companies use some of the information collected by the Website and/or the App, including the advertising identifier assigned to your mobile device to serve advertisements that are targeted to your interests in the App.
These third parties may also obtain anonymous information about other applications you’ve downloaded to your mobile device, the mobile websites and applications you visit, and your location in order to help analyze user behavior and serve targeted advertising on the Website, the App and on other applications and websites.
3. We are collecting your personal data for the following purpose(s):
a. Respond to comments, requests and questions and provide customer service;
b. Provide you with and communicate with you about the services offered through the Website and/or the App (“Services”);
c. Help understand your needs and tailor the features and content of the Services to you;
d. Process and deliver the products and services you request;
e. Identify you as a user in our systems;
f. Facilitate the creation of and secure and administer your Unlockd account;
g. Resolve disputes and/or troubleshoot problems;
h. Develop and improve marketing and advertising for the Website, the App and Services;
i. Market our products and services and those of third parties to you that we believe may be of interest to you; and
j. Provide services to our partners or their affiliates.
k. We may also create anonymous and/or de-identified data records from your personal information by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use and disclose anonymous data for any purpose, including to analyze trends and gather demographic information about our user base as a whole, and to administer and improve the Website, the App and Services.
4. The legal basis for processing your personal data is:
a. You have consented to the processing of your personal data for the receipt of electronic marketing (as part of receiving the services provided by Unlockd through the Website and/or the App), such consent obtained when you register for the Unlockd App;
b. Processing is further to the legitimate interests of Unlockd in order to provide you with, and facilitate the provision of, the services provided by Unlockd and which you have signed up to and agreed to receive through the Website and/or the App; or
5. The recipients or categories of recipients of your personal data are:
a. Third parties chosen by you. We may share your personal information with any third parties that you authorize us to share it with, including our third party partners who have branded the App.
b. Third party service providers. We may share your personal information with our third party service providers that help us provide the Website, the App and the Services.
c. Affiliates. We may share your personal information with our parent company, subsidiaries, or other companies under common control with us (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Notice.
d. Third parties involved in corporate restructuring. We may share your personal information with third parties in connection with any corporate restructuring of our company involving the sale or transfer of all or a part of our business. This may include, for example, any merger, financing, acquisition, or bankruptcy transaction or proceeding.
e. Where necessary or required by law. We may share personal data as we believe necessary or appropriate (a) to comply with applicable law; (b) to comply with legal process, including to respond to requests from our regulators and public and government authorities; (c) to enforce our Privacy Notice; and (d) to protect our rights, privacy, safety or property, and that of you or others.
6. Information, including personal information that we collect from you, may be transferred to, stored at and processed in a country outside the EEA, including, but not limited to the United States and Australia. When we are transferring your data to the United States, the recipient of your data is self certified under the Privacy Shield. When we are transferring your data to Australia or another country standard data protection clauses have been put in place.
7. Cookies. If you decide at any time that you no longer wish to accept cookies from the Website and/or the App for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions or functionality of the Website and/or the App. If you have any questions about how to disable or modify cookies, please contact firstname.lastname@example.org.
8. The personal data will be stored for no more than 7 years. We may also retain an archived copy of your records as required by law or for legitimate business purposes.
9. You may review, update, correct or delete your personal information by accessing your Account or by contacting Unlockd at email@example.com. If you completely delete all of your personal information, then your Account may become deactivated, although your personal information associated with your Account will remain on the App unless you have deleted such personal information. Please note that if we have disclosed your personal data to third parties, we cannot subsequently access that personal information or require its deletion or modification by such third parties.
10. You have the right to request from us access to and rectification or erasure of personal data or to restriction of processing concerning you or to object to our processing of the data as well as the right to data portability. If you wish to make such a request, please contact firstname.lastname@example.org.
11. If we are relying on your consent to process data, you may withdraw your consent at any time by notice to us.
12. You have the right to complain to the Information Commissioner’s Office about the manner in which or otherwise in respect of the manner in which we process your personal data.
13. Your provision of personal data to us is not a contractual or legal requirement.
14. Our Website and/or App may contain links to third party websites. When you click on a link to any other website or location, you will leave our Website or App and go to another site and another entity may collect information from you. We have no control over, do not review, and cannot be responsible for, these outside websites, their content, or the use by them of the information that they collect about you. The terms of this Policy do not apply to those websites or the use by them of the information that they collect about you.
15. This Website, the App and Services are not directed to children under the age of 13 and children under the age of 13 are not eligible to use our App or Services. We do not knowingly collect personal information from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at email@example.com. We will delete such information from our files within a reasonable time.
16. We may change this Policy from time to time for any reason. If we make any changes, we will change the Last Updated date above and post the new Policy here. You should consult this Policy regularly for any changes.
Last updated: 21 May 2018