Privacy policy
Last updated: 12 May 2022
Our privacy policy is not just an exercise in complying with the law, but a founding and design principle of LockOnMe. As a case in point, no user account based on name or email address is necessary to use LockOnMe.
We are committed to protecting your privacy and the confidentiality of your personal information.
In this document, "we", "our", or "us" refer to Variable Geometries Ltd ("Variable Geometries" thereafter), owner of the LockOnMe brand.
We are company number 11350103, registered in England and Wales. Our registered office is at International House, 64 Nile Street, London N1 7SR, United Kingdom.
By using our websites (lockonme.com & lockon.me), applications and services (collectively referred to as “the Services” thereafter), you are agreeing with the present Privacy Policy and Terms of Service.
A. Scope
This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this privacy policy, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
Our policy complies with the Data Protection Act 2018 (UK) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org.
Except as set out below (technically required or extraordinary circumstances), we do not share, or sell, or disclose any information collected through our website to any third party.
Data we process
In order to fulfill its function as a location-sharing application, LockOnMe relies on application data consisting of user-generated Target ID(s), Target Password(s) and Tracking Code(s). These represent identifiers pointing to abstract reference objects called “targets”, whose role is to store user-broadcast locations and user-defined Points Of Interest. In that capacity, geographic coordinates are used to store positions, and additional text attributes can be further provided by users to qualify the Points Of Interest (i.e. title, linked webpage, linked image URL).
Application data is linked to personal data when a user account is created for that specific purpose (as detailed further down).
Any personal information is only collected when you voluntarily provide it, such as providing your email address to subscribe to a newsletter. We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:
- Your identity includes information such as first name, last name, title, and other identifiers that you may have provided at some time.
- Your contact information includes information such as billing address, delivery address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.
- Your financial data includes information such as your bank account and payment card details.
- Transaction data includes details about payments or communications to and from you and information about products and services you have purchased from us.
- Technical data includes your browser type and version, internet protocol (IP) address location, operating system and platform you use to access the websites and/or mobile applications.
- Your profile includes information such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
We may aggregate anonymous data such as statistical or demographic data for any purpose, such as to assess interest in a product or service. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.
If we were to combine or connect aggregated data with your personal information so that it could identify you in any way, we would treat the combined data as personal information and it would be used in accordance with this privacy policy.
Special personal information
We do not collect any special personal information about you (i.e. data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
If you do not provide personal information we need
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
B. The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
Information we process because we have a contractual obligation with you
When you create an account on our websites, buy a product or service from us, or otherwise agree to our terms of service, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our websites.
We process this information on the basis that there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our websites or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at privacy@lockonme.com. However, if you do so, you may not be able to use our websites or our services further.
In relation to application data, a user account is not required when creating or using the Target ID(s), Target Password(s) and Tracking Code(s) identifiers, and when done in this manner, i.e. without a user account, no information capable of identifying the user or their device (such as names, emails, phone or IMEI numbers...) is neither stored nor accessed in relation to these identifiers.
When a user account is used, a link would be formed on purpose between personal information and application data. This would be used for example to let users reset their password, or acquire and make use of services that rely on application data (such as premium targets).
Whether or not there is a link to a user account, the application data is treated confidentially in accordance with the two provisions below.
(i)(ii)
In terms of the geographic coordinates saved in the database, location history is not stored insofar as the latest location broadcast associated with a particular Target ID and Tracking Code immediately replaces the prior position stored in the database.
Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a message
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage business risk
- protecting your interests where we believe we have a duty to do so.
Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
C. Specific uses of information you provide to us
Information provided on the understanding that it will be shared with a third party
The LockOnMe websites and applications allow you to post information with a view to that information being read, copied, downloaded, or used by other people.
Examples include:
- submitting a target to us for it to be published on our websites and applications as a “Public Target”
- posting a message below a blog post on our websites
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
We accept no responsibility in case target details and/or locations and/or Points Of Interest were shared with a third party, and it resulted in harm caused to either party involved.
Provided your request is reasonable and there is no legal basis for us to retain it, then we may agree to your request to delete personal information that concerns you. You can make a request by contacting us at privacy@lockonme.com.
Complaints regarding content on our websites or applications
If you complain about any of the content on our websites or applications, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
Information relating to your method of payment
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of WorldPay / SagePay / PayPal / MoneyBookers / Stripe or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
Communicating with us
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need, and we record your request and our reply in order to increase the efficiency of our services.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
Complaining
When we receive a complaint, we record all the information you have given to us, and use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.
The information is not used for any other purpose, and we undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
D. Use of information we collect through automated systems when you visit our websites
Cookies
A cookie is a piece of data stored on a website visitor's hard drive to help improve their access to the site (e.g. recording whether the user wishes to hide specific messages that have been already seen) and to provide us with statistics about how visitors use the websites (e.g. via Google Analytics) so that it can be improved. To that effect, cookies may be enabled to track and target user interests to improve experience on the websites.
Usage of a cookie is in no way linked to any personally identifiable information about you.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
The following is a list of possible cookies collected when visiting our websites. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. Please refer to each service's privacy policy for more information on the exact types of data collected.
- Google Analytics
: _ga, _gid, _gat - ShareThis: euconsent-v2, pubconsent-v2
- Disable Cookies in Chrome
- Disable Cookies in Firefox
- Disable Cookies in Safari
- Disable Cookies in Internet Explorer
Non-personal aggregated information
Requests by your web browser to the servers delivering our webpages are recorded by the third parties whose services we use, such as web hosts and Google Analytics.
The recorded information includes your geographical location, Internet service provider, IP address, browser software, type of computer or device used for browsing, and screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
E. Disclosure and sharing of your information
Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
Data processed outside the European Union
Our websites are hosted in the United States of America.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be at some point processed outside the European Union.
On 25 March 2022, the European Commission and the United States of America announced that they have agreed in principle on a new Trans-Atlantic Data Privacy Framework, with the two sides expected to finalise the details of this agreement in principle and translate it into legal texts that will form the basis of a draft adequacy decision pertaining to data transfers from the EU to a third country.
In the absence of an Adequacy Decision, we use the following safeguard with respect to data transferred outside the European Union:
- adherence to a code of conduct together with obtaining binding and enforceable commitments from the recipient to apply the appropriate safeguards to protect the transferred data.
F. Control over your own information
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
Access to your personal information
To obtain a copy of any information that is not provided on our websites or applications you should contact us to make that request, by writing to privacy@lockonme.com.
Removal of your information
If you wish us to remove personally identifiable information from our websites or applications, you should contact us to make your request, by writing to privacy@lockonme.com.
Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important in order to safeguard your information.
G. Other matters
Background location access
When using the LockOnMe mobile apps (on smartphones or smartwatches), access to location in the background is required whenever users choose to broadcast their own position, for users' convenience; this is to maintain the position broadcast even if users turn off their screen or press on their device's home button – that is, when the app is no longer visible.
Not accessing the background location would mean that users would not be able to broadcast their location when LockOnMe is no longer displayed on their phone.
The background location is no longer accessed once users stop broadcasting their location.
A notification is always present in the device's notification area when the app is running, including when it is accessing location in the background. This was our policy before, and it is now also strictly required by Google Play.
The notification also displays the status of the user's location broadcast: on or off.
Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our websites or applications only with consent from a parent or guardian.
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us through our websites, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
Likewise, regarding the LockOnMe mobile apps (on smartphones or smartwatches), communication between our servers and users' devices is done securely using HTTPS encyption.
How you can complain
If you are not happy with our privacy policy or if you have any complaint then you should email us at privacy@lockonme.com.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern beforehand.
Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with other law, including for the period demanded by our tax authorities;
- to support a claim or defence in court.
Compliance with the law
We undertake to comply with all regulations and legislation relating to confidentiality and personal data submitted by users, and in particular, the rules laid down in the General Data Protection Regulations (European Union Regulation n°2016/679), and in the Data Protection Act 2018 (UK).
To this effect, our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business.
If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our websites, applications and services.
In compliance with its legal obligations, Variable Geometries Ltd has appointed a Data Protection Officer who keeps a data processing register, and who may be contacted at privacy@lockonme.com for any question regarding this privacy policy or the general use of the Data.
Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on this webpage on the day you use our websites or applications. We advise you to print a copy for your records if deemed appropriate.
If you have any question regarding our privacy policy, please contact us at privacy@lockonme.com.
