3. WHEN AND
WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In
Short:
We may share information in
specific situations described in this section and/or
with the following
categories of
third parties.
Vendors, Consultants, and
Other Third-Party Service Providers. We may share
your data with third-party vendors, service providers,
contractors, or agents (
"third parties"
) who perform
services for us or on our behalf and require access to such
information to do that work.
The
categories of
third parties we may share personal information with are
as follows:
-
Affiliate Marketing Programs
-
Communication & Collaboration
Tools
-
Data Storage Service Providers
-
Finance & Accounting Tools
- Order Fulfillment Service
Providers
-
Product Engineering & Design Tools
-
Performance Monitoring Tools
-
User Account Registration &
Authentication Services
-
Website Hosting Service Providers
We
also may
need to share your personal information in the following
situations:
- 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.
- When we use Google
Maps Platform APIs. We may share your
information with certain Google Maps Platform APIs (e.g., Google Maps
API, Places API).
We obtain and store on
your device ("cache") your location
. You may revoke your
consent anytime by contacting us at the contact details
provided at the end of this document.
- Affiliates.
We may share your information with our affiliates,
in which case we will require those affiliates to honor this privacy
notice. Affiliates include our parent company and any
subsidiaries, joint venture partners, or other companies
that we control or that are under common control with
us.
- Business Partners.
We may share your information with our business partners to
offer you certain products, services, or
promotions.
- Other Users.
When you share personal information (for example, by posting
comments, contributions, or other content to the Services)
or otherwise
interact with public areas of the Services, such personal
information may be viewed by all users and may be publicly
made available outside the Services in perpetuity. If you interact with
other users of our Services and register for our Services
through a social network (such as Facebook), your contacts
on the social network will see your name, profile photo, and
descriptions of your activity. Similarly,
other users will be able to view descriptions of your
activity, communicate with you within our Services, and view
your profile.
- Offer Wall. Our
application(s) may display a third-party hosted "offer wall." Such an offer
wall allows third-party advertisers to offer virtual
currency, gifts, or other items to users in return for the
acceptance and completion of an advertisement offer. Such an
offer wall may appear in our application(s) and be displayed
to you based on certain data, such as your geographic area
or demographic information. When you click on an offer wall,
you will be brought to an external website belonging to
other persons and will leave our application(s). A unique
identifier, such as your user ID, will be shared with the
offer wall provider in order to prevent fraud and properly
credit your account with the relevant reward.
4.
WHAT IS OUR STANCE ON THIRD-PARTY
WEBSITES?
In
Short: We are not responsible for the
safety of any information that you share with third parties
that we may link to or who advertise on our Services, but
are not affiliated with, our Services.
The Services
, including our offer wall,
may link to
third-party websites, online services, or mobile applications
and/or contain advertisements from third parties that are not
affiliated with us and which may link to other websites,
services, or applications. Accordingly, we do not make any
guarantee regarding any such third parties, and we will not be
liable for any loss or damage caused by the use of such
third-party websites, services, or applications. The inclusion
of a link towards a third-party website, service, or application
does not imply an endorsement by us. We cannot guarantee the
safety and privacy of data you provide to any third parties. Any
data collected by third parties is not covered by this privacy
notice. We are not responsible for the content or privacy and
security practices and policies of any third parties, including
other websites, services, or applications that may be linked to
or from the Services. You should review the policies of such
third parties and contact them directly to respond to your
questions.
5. DO WE USE
COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In
Short: We may use cookies and
other tracking technologies to collect and store your
information.
We may use cookies and similar
tracking technologies (like web beacons and pixels) to
gather information when you interact with our Services. Some
online tracking technologies help us maintain the security
of our Services and your
account,
prevent crashes, fix bugs, save your preferences, and assist
with basic site functions.
We also permit third parties
and service providers to use online tracking technologies on
our Services for analytics and advertising, including to
help manage and display advertisements, to tailor
advertisements to your interests, or to send abandoned
shopping cart reminders (depending on your communication
preferences). The third parties and service providers use
their technology to provide advertising about products and
services tailored to your interests which may appear either
on our Services or on other websites.
To the extent these online
tracking technologies are deemed to be a "sale"/"sharing" (which includes
targeted advertising, as defined under the applicable laws)
under applicable US state laws, you can opt out of these online
tracking technologies by submitting a request as described below
under section "DO UNITED
STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
"
Specific information about how
we use such technologies and how you can refuse certain
cookies is set out in our Cookie Notice
.
6. DO WE OFFER ARTIFICIAL
INTELLIGENCE-BASED PRODUCTS?
In
Short: We offer products, features,
or tools powered by artificial intelligence, machine
learning, or similar technologies.
As part of our Services, we offer
products, features, or tools powered by artificial intelligence,
machine learning, or similar technologies (collectively, "AI Products"). These tools are
designed to enhance your experience and provide you with
innovative solutions. The terms in this privacy notice govern
your use of the AI Products within our Services.
Our AI
Products
Our AI Products are designed for
the following functions:
How We Process Your Data Using
AI
All personal information processed
using our AI Products is handled in line with our privacy notice
and our agreement with third parties. This ensures high security
and safeguards your personal information throughout the process,
giving you peace of mind about your data's safety.
How to Opt
Out
We believe in giving you the power
to decide how your data is used. To opt out, you can:
-
Log in
to your account settings and update your user
account
-
Contact us using the
contact information provided
7. HOW DO WE
HANDLE YOUR SOCIAL
LOGINS?
In Short:
If you choose to register or log in to
our Services using a social media account, we may have
access to certain information about
you.
Our Services offer you the
ability to register and log in using your third-party social
media account details (like your Facebook or X logins).
Where you choose to do this, we will receive certain profile
information about you from your social media provider. The
profile information we receive may vary depending on the
social media provider concerned, but will often include your
name, email address, friends list, and profile picture, as
well as other information you choose to make public on such
a social media platform.
We will use the information we
receive only for the purposes that are described in this
privacy notice or that are otherwise made clear to you on
the relevant Services. Please note that we do not control,
and are not responsible for, other uses of your personal
information by your third-party social media provider. We
recommend that you review their privacy notice to understand
how they collect, use, and share your personal information,
and how you can set your privacy preferences on their sites
and apps.
8. HOW LONG DO
WE KEEP YOUR
INFORMATION?
In Short:
We keep your information for as long
as necessary to
fulfill
the purposes outlined in this privacy notice unless
otherwise required by law.
We will only keep your
personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer
retention period is required or permitted by law (such as
tax, accounting, or other legal requirements). No purpose in this notice
will require us keeping your personal information for longer
than
the period of time in
which users have an account with us
.
When we have no ongoing
legitimate business need to process your personal
information, we will either delete or anonymize such
information, or, if this is not possible (for example,
because your personal information has been stored in backup
archives), then we will securely store your personal
information and isolate it from any further processing until
deletion is possible.
9. HOW DO WE
KEEP YOUR INFORMATION
SAFE?
In Short:
We aim to protect your personal
information through a system of organizational and
technical security measures.
We have implemented
appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal
information we process. However, despite our safeguards and
efforts to secure your information, no electronic
transmission over the Internet or information storage
technology can be guaranteed to be 100% secure, so we cannot
promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties
will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although
we will do our best to protect your personal information,
transmission of personal information to and from our
Services is at your own risk. You should only access the
Services within a secure environment.
10. DO WE
COLLECT INFORMATION FROM
MINORS?
In
Short: We do not knowingly collect
data from or market to
children under 18 years of age.
We do not knowingly collect,
solicit data from, or market to children under 18 years of
age, nor do we knowingly sell such personal information. By
using the Services, you represent that you are at least 18
or that you are the parent or guardian of such a minor and
consent to such minor dependent’s use of the Services. If we
learn that personal information from users less than 18
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
may have collected from children under age 18, please
contact us at
broker@locke.pro
.
11. WHAT ARE
YOUR PRIVACY
RIGHTS?
In
Short:
You may review,
change, or terminate your account at any time, depending
on your country, province, or state of
residence.
Withdrawing your
consent: If we are relying on your
consent to process your personal information, which may be express
and/or implied consent depending on the applicable law, you have the
right to withdraw your consent at any time. You can withdraw
your consent at any time by contacting us by using the
contact details provided in the section "
HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
" below.
However, please note that this
will not affect the lawfulness of the processing before its
withdrawal nor, when
applicable law allows,
will it affect the processing of your personal
information conducted in reliance on lawful processing grounds
other than consent.
Opting out of marketing
and promotional communications:
You can unsubscribe from our marketing and promotional
communications at any time by
clicking on the unsubscribe link in the emails that we send,
or by contacting us using
the details provided in the section "
HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?
" below. You will
then be removed from the marketing lists. However, we may still
communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of
your account, to respond to service requests, or for other
non-marketing purposes.
Account
Information
If you would at any time like to review
or change the information in your account or terminate your
account, you can:
-
Log in to your account settings and
update your user account.
Upon your request to terminate
your account, we will deactivate or delete your account and
information from our active databases. However, we may retain
some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal
terms and/or comply with applicable legal
requirements.
If you have questions or comments about
your privacy rights, you may email us at
broker@locke.pro.
12. CONTROLS
FOR DO-NOT-TRACK
FEATURES
Most web browsers and some
mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or
setting you can activate to signal your privacy preference
not to have data about your online browsing activities
monitored and collected. At this stage, no uniform
technology standard for
recognizing
and implementing DNT signals has been finalized. As such, we
do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to
be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform
you about that practice in a revised version of this privacy
notice.
California law requires us to let
you know how we respond to web browser DNT signals. Because
there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do
not respond to them at this time.
13. DO UNITED
STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short:
If you are a resident of California, Colorado,
Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky,
Montana, New Hampshire, New Jersey, Oregon, Tennessee,
Texas, Utah, or Virginia,
you may have the right to request access to and receive
details about the personal information we maintain about
you and how we have processed it, correct inaccuracies,
get a copy of, or delete your personal information. You
may also have the right to withdraw your consent to our
processing of your personal information. These rights
may be limited in some circumstances by applicable law.
More information is provided
below.
Categories of Personal
Information We Collect
We have collected the
following categories of personal information in the past
twelve (12) months:
Category
|
Examples
|
Collected
|
A.
Identifiers
|
Contact
details, such as real name, alias, postal
address, telephone or mobile contact number,
unique personal identifier, online
identifier, Internet Protocol address, email
address, and account
name
|
YES
|
B. Personal
information as defined in the California
Customer Records
statute
|
Name, contact
information, education, employment,
employment history, and financial
information
|
YES
|
C. Protected
classification characteristics under state
or federal law
|
Gender, age,
date of birth, race and ethnicity, national
origin, marital status, and other
demographic data
|
YES
|
D. Commercial
information
|
Transaction
information, purchase history, financial
details, and payment
information
|
YES
|
E. Biometric
information
|
Fingerprints
and voiceprints
|
YES
|
F. Internet or
other similar network activity
|
Browsing
history, search history, online behavior
, interest data, and interactions with
our and other websites, applications,
systems, and
advertisements
|
YES
|
G. Geolocation
data
|
Device
location
|
YES
|
H. Audio,
electronic, sensory, or similar information
|
Images and
audio, video or call recordings created in
connection with our business
activities
|
YES
|
I. Professional
or employment-related information
|
Business
contact details in order to provide you our
Services at a business level or job title,
work history, and professional
qualifications if you apply for a job with
us
|
YES
|
J. Education
Information
|
Student
records and directory
information
|
YES
|
K. Inferences
drawn from collected personal information
|
Inferences
drawn from any of the collected personal
information listed above to create a profile
or summary about, for example, an
individual’s preferences and
characteristics
|
NO
|
L. Sensitive personal
Information
|
|
NO
|
We may also collect other personal
information outside of these categories through instances where
you interact with us in person, online, or by phone or mail in
the context of:
- Receiving help through our customer
support channels;
- Participation in customer surveys or
contests; and
- Facilitation in the delivery of our
Services and to respond to your inquiries.
We will use and retain the
collected personal information as needed to provide the Services or
for:
- Category A - As long as the user has an account with us
- Category B - As long as the user has an account with us
- Category C
- As long as the user has an
account with us
- Category D
- As long as the user has an
account with us
- Category E
- As long as the user has an
account with us
- Category F
- As long as the user has an
account with us
- Category G
- As long as the user has an
account with us
- Category H
- As long as the user has an
account with us
- Category I
- As long as the user has an
account with us
- Category J
- As long as the user has an
account with us
Sources of Personal
Information
How We Use and
Share Personal
Information
We collect and share
your personal information through:
-
Targeting
cookies/Marketing cookies
Will
your information be shared with anyone
else?
We may use
your personal information for our own
business purposes, such as for undertaking
internal research for technological
development and demonstration. This is not
considered to be "selling"
of your personal information.
We have
disclosed the following categories of
personal information to third parties
for a business or commercial purpose in
the preceding twelve (12) months:
- Category B. Personal
information as defined in the California Customer
Records law
- Category
C
. Characteristics of
protected classifications
under state or federal
law
- Category
D
. Commercial
information
- Category
E
. Biometric
information
- Category
F
. Internet or other
electronic network activity
information
- Category
G
. Geolocation
data
- Category
H
.
Audio, electronic, visual, and
similar information
-
Category
I
.
Professional or employment-related
information
- Category
J
.
Education information
We
have sold or shared the
following categories of
personal information to
third parties in the
preceding twelve (12)
months:
The
categories of
third parties to
whom we sold
personal
information are:
-
Affiliate
Marketing
Programs
-
User
Account
Registration
&
Authentication
Services
The
categories of third
parties to whom we
shared personal
information with are:
-
Affiliate
Marketing
Programs
-
User Account
Registration &
Authentication
Services
Your
Rights
You
have rights under
certain US state
data protection
laws. However, these
rights are not
absolute, and in
certain cases, we
may decline your
request as permitted
by law. These rights
include:
-
Right
to know
whether or not we
are processing your
personal data
-
Right
to access
your
personal data
-
Right
to correct
inaccuracies
in your personal
data
-
Right
to
request
the deletion of your
personal data
-
Right
to obtain a copy
of the
personal data you
previously shared
with us
-
Right
to
non-discrimination
for exercising your
rights
-
Right
to opt
out of
the processing of
your personal data
if it is used for
targeted advertising
(or sharing
as defined under
California’s privacy
law)
, the sale of
personal data, or
profiling in
furtherance of
decisions that
produce legal or
similarly
significant effects
(
"profiling"
)
Depending
upon the state where
you live, you may
also have the
following
rights:
-
Right
to obtain a list of
the categories of
third parties to
which we have
disclosed personal
data (as permitted
by applicable law,
including
California's
and Delaware's
privacy law)
-
Right
to obtain a list of
specific third
parties to which we
have disclosed
personal data (as
permitted by
applicable law,
including Oregon’s
privacy law)
-
Right
to limit use and
disclosure of
sensitive personal
data (as permitted
by applicable law,
including
California’s privacy
law)
-
Right
to opt out of the
collection of
sensitive data and
personal data
collected through
the operation of a
voice or facial
recognition feature
(as permitted by
applicable law,
including Florida’s
privacy law)
How
to Exercise Your
Rights
To
exercise these
rights, you can
contact us
by
submitting a
data
subject access
request,
by
emailing
us
at
broker@locke.pro
,
or
by referring to the
contact details at the
bottom of this
document.
You
can opt out from the
selling of your
personal
information,
targeted
advertising, or
profiling by
disabling cookies in
Cookie Preference
Settings.
Under
certain US state
data protection
laws, you can
designate an
authorized
agent to make
a request on your
behalf. We may deny
a request from an
authorized
agent that
does not submit
proof that they have
been validly
authorized
to act on
your behalf in
accordance with
applicable
laws.
Request
Verification
Upon
receiving your
request, we will
need to verify your
identity to
determine you are
the same person
about whom we have
the information in
our system. We will
only use personal
information provided
in your request to
verify your identity
or authority to make
the request.
However, if we
cannot verify your
identity from the
information already
maintained by us, we
may request that you
provide additional
information for the
purposes of
verifying your
identity and for
security or
fraud-prevention
purposes.
If
you submit the
request through an
authorized
agent, we may
need to collect
additional
information to
verify your identity
before processing
your request and the
agent will need to
provide a written
and signed
permission from you
to submit such
request on your
behalf.
Appeals
Under
certain US state
data protection
laws, if we decline
to take action
regarding your
request, you may
appeal our decision
by emailing us at
broker@locke.pro
. We will
inform you in
writing of any
action taken or not
taken in response to
the appeal,
including a written
explanation of the
reasons for the
decisions. If your
appeal is denied,
you may submit a
complaint to your
state attorney
general.
California
"Shine The
Light"
Law
California
Civil Code Section
1798.83, also known
as the
"Shine The
Light"
law, permits
our users who are
California residents
to request and
obtain from us, once
a year and free of
charge, information
about categories of
personal information
(if any) we
disclosed to third
parties for direct
marketing purposes
and the names and
addresses of all
third parties with
which we shared
personal information
in the immediately
preceding calendar
year. If you are a
California resident
and would like to
make such a request,
please submit your
request in writing
to us by using the
contact details
provided in the
section
"
HOW
CAN YOU CONTACT
US ABOUT THIS
NOTICE?
"
14.
DO
WE
MAKE
UPDATES
TO
THIS
NOTICE?
In
Short:
Yes,
we will
update this
notice as
necessary to
stay
compliant
with
relevant
laws.
We
may update this
privacy notice
from time to
time. The
updated version
will be
indicated by an
updated
"Revised"
date at
the top of this
privacy notice.
If we make
material changes
to this privacy
notice, we may
notify you
either by
prominently
posting a notice
of such changes
or by directly
sending you a
notification. We
encourage you to
review this
privacy notice
frequently to be
informed of how
we are
protecting your
information.
15.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If
you have
questions or
comments about
this notice, you
may
email us
at
broker@locke.pro
or
contact
us
by
post
at:
Locke
Connect
Inc.
3000 El Camino
Real Building 4
Palo Alto
,
CA
94306
United States
16.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
Based on
the applicable
laws of your
country
or state
of residence in
the US
, you may
have the
right to
request
access
to the
personal
information
we
collect
from
you,
details
about
how we
have
processed
it,
correct
inaccuracies,
or
delete
your
personal
information.
You may
also
have the
right to
withdraw
your
consent
to our
processing
of your
personal
information.
These
rights
may be
limited
in some
circumstances
by
applicable
law. To
request
to
review,
update,
or
delete
your
personal
information,
please
fill out
and
submit a
data
subject
access
request
.
;