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Privacy Policy

Last updated: 21 August 2025

This Privacy Policy explains how we collect, use, disclose, and protect personal information when you use our website, mobile apps, and related services (collectively, the “Services”). It is designed to meet the requirements of the UK GDPR and the Data Protection Act 2018, as well as other applicable laws.

0. Who We Are

Controller: Unlock-L.ink (“we”, “us”, “our”).
Contact: support@unlock-l.ink.
In-app access: You can view this Privacy Policy at any time from the app menu: Profile → Legal → Privacy Policy (website link also available).

1. General Usage and Cookies Policy

When using our site as a general user (without signing up or using any of the pro features), the only data we collect through cookies is fundamental to the operation and security of the site. Specifically:

  • We use cookies to manage sessions, ensuring that your interactions with the site are seamless and functional.
  • A CSRF token is stored via a cookie to protect your data from potential cross-site request forgery attacks.

Any other information we collect is explicitly provided by you when you submit forms or interact with features. We do not collect personal information without your direct input or consent. For general browsing, no personally identifiable information is required or collected unless you choose to provide it. See also Sections 10 (Data Categories, Use & Sharing) and 12 (Cookies & Similar Technologies).

2. Signed-up Users and Pro Account Users

If you sign up or use pro services, we process additional data to provide those services:

  • Identity and contact details (e.g., name, email, phone).
  • Addresses.
  • Date of birth (where needed for verification or legal compliance).
  • Payment details and billing information (processed by our payment provider; see Section 14).
  • Transaction data (payments to/from you; products/services purchased).
  • Usage data (how you interact with our apps/services).

This data may be required to perform a contract with you, comply with legal obligations, or serve our legitimate interests (e.g., securing the Services, preventing fraud).

3. Lawful Bases and Your Rights

3.1 Lawful Bases

  • Contract: To create/manage your account and deliver requested features.
  • Consent: For optional features (e.g., marketing emails, certain analytics). You can withdraw consent at any time (see Section 8 and 11).
  • Legal obligation: For tax, accounting, and regulatory requirements.
  • Legitimate interests: To secure, maintain, and improve our Services, provided these interests are not overridden by your rights.

3.2 Your Data Protection Rights

  • Right of access, rectification, and erasure.
  • Right to restrict or object to processing.
  • Right to data portability.
  • Right to withdraw consent at any time (where processing is based on consent).

We will respond to requests within one month, subject to applicable law.

4. Where We Get Personal Information From

Primarily from you (e.g., forms, account creation, support). We may also receive limited data from payment processors (e.g., payment status), and service providers necessary to run our Services (see Section 14).

5. How Long We Keep Information

5.1 Purpose of Retention

We retain personal data to provide and improve services, fulfil legal obligations, maintain business records, and ensure security and dispute resolution.

5.2 Retention Periods

  • Customer account data: While the account is active and up to 6 years after closure (legal/tax purposes).
  • Transaction data: 6 years after the transaction date.
  • Marketing data: 3 years from last interaction or until you opt out.
  • Complaints/legal records: 6 years after resolution.

5.3 Data Minimisation and Deletion

We periodically review data for accuracy and necessity. Once the retention period expires, we delete or anonymise data.

5.4 Your Rights

You can request deletion or rectification (see Section 11 for account/data deletion options).

5.5 Compliance and Review

We review this policy at least annually. For questions about retention, contact support@unlock-l.ink.

6. Who We Share Information With

We share personal data with processors acting on our instructions, including:

  • Payment processors (e.g., Stripe) for payments and refunds.
  • Hosting, infrastructure, and security providers.
  • Customer support and email service providers.
  • Analytics and crash reporting providers (see Section 14; may be consent-based).
  • Organisations we are legally required to share data with.

7. Sharing Information Outside the UK

If we transfer data outside the UK/EEA (e.g., to the USA), we use appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) and/or the EU/UK Standard Contractual Clauses, plus supplementary measures where necessary.

8. How to Complain

Please contact us first at support@unlock-l.ink. You can also contact the ICO:

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk

9. Children’s Privacy

Our Services are not directed to children under 13 (or under 16 in the EEA/UK). We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, please contact us so we can delete it. If we offer experiences directed to children, we comply with applicable children’s privacy laws.

10. Data Categories, Use & Sharing

The table below summarises common data categories we may process. Your actual data collection depends on how you use the Services (e.g., browsing vs. signed-in use). We do not sell personal data.

Category Collected Shared Purpose Optional?
Personal info (name, email) Yes (account/pro) No* Account setup, customer support Required for accounts
Financial info (billing details) Yes (via Stripe) Yes (to Stripe) Process payments, refunds Required for purchases
App activity (feature usage) Yes No* Improve and secure the app Optional if analytics disabled
App info & performance (crash logs, diagnostics) Yes No* Debugging and reliability Optional if crash reporting disabled
Device or other IDs May collect No* Security, fraud prevention, diagnostics Optional if analytics disabled
Location Not collected N/A N/A N/A
Contacts, Photos/Media, Camera, Microphone Not collected by default N/A Only if you choose a feature that needs it (see Section 13) Always optional

*We do not share personal data with third parties for their own marketing. Limited sharing with processors occurs under contract to provide the Services (see Section 6).

Short version

  • We collect basic account details if you sign up.
  • Payments are handled by Stripe; we don’t store full card numbers.
  • Optional analytics/crash reporting help improve reliability — you can turn these off.
  • We don’t collect location by default. Extra permissions only if you use those features.
  • We do not sell personal data.

Need the full breakdown? View on a larger screen to see the table.

11. Account & Data Deletion

You can delete your account and request deletion of associated personal data as follows:

Deleting your account starts an irreversible process. Some records (e.g., invoices) may be retained for legal/tax reasons (see Section 5). We will confirm completion of deletion steps.

12. Cookies & Similar Technologies

We use strictly necessary cookies (e.g., session, CSRF). With your consent, we may use analytics cookies and mobile SDKs to understand feature usage and improve performance. You can manage optional analytics in-app at Settings → Privacy and via browser controls.

13. Device Permissions

Our app requests permissions only when needed for a feature and after a system prompt. You can deny a permission and still use other features.

  • Photo/Media/Files or Photos – only if you choose to upload content.
  • Microphone – only if you use an audio feature.
  • Notifications – with your consent, to send service notifications. You can turn these off in system settings.

We do not request device location or contacts by default.

14. Third-Party Providers and SDKs

  • Payments: Stripe Payments Europe, Ltd. processes payments on our behalf. We do not store full card numbers. Stripe may act as a separate controller for certain processing (e.g., anti-fraud). See Stripe’s privacy notices.
  • Hosting & Infrastructure: Trusted providers that help us operate, secure, and deliver the Services.
  • Analytics & Crash Reporting: We may use privacy-respecting analytics and crash reporting to improve reliability. These can be disabled where supported in-app.

15. Security

We implement appropriate technical and organisational measures (including encryption in transit, access controls, and regular monitoring) to protect personal data. No method of transmission or storage is 100% secure; we work to continuously improve our safeguards.

16. Your Choices

  • Marketing: Opt out via unsubscribe links or by contacting us.
  • Analytics/Crash Reporting: Toggle off in Settings → Privacy where available.
  • Permissions: Deny at the system prompt or change in device settings.

17. Changes to This Policy

We may update this policy to reflect changes to our practices, legal, or regulatory requirements. We will post updates here and, where appropriate, notify you in-app or by email. The “Last updated” date shows the latest revision.

18. Contact

Questions or requests? Email support@unlock-l.ink.