True Locker – Privacy Policy

[Last modified: April 20 , 2020]

Introduction

This privacy policy (“Privacy Policy”) governs the data collection practices (“Company”, “us”, “we” and “our”) uses when you use our True Locker mobile app (“True Locker Product”) or our website, www.truelocker.app (the “Website”). This Privacy Policy is provided to make important disclosures on how or why we collect, share and use our users’ information. Our users’ privacy is important to us. We encourage you to read the Privacy Policy carefully prior to using our True Locker Product and use it to make informed decisions.

By using the True Locker Product or Website, you agree to the terms of this Privacy Policy. Your continued use of the True Locker Product or Website constitutes your agreement to this Privacy Policy. This Privacy Policy is part of our End User License Agreement (Link: https://truelocker.app/terms_conditions) and, to the extent that the processing of personal data is based on consent (see below), is a legally binding agreement between you and the Company. Definitions herein shall have the same meaning as defined therein. If you do not agree to these terms, please do not access or use the True Locker Product or Website.

IF YOU OBJECT TO THESE TERMS PLEASE DO NOT ACCESS OR USE THE WEBSITE, DOWNLOAD, INSTALL, OR USE THE True Locker PRODUCT OR SERVICES IN ANY MANNER.

What Information Do We Collect?

The information we collect includes non-identifiable information which may be made available or gathered via the user’s use of the True Locker Product and, where applicable and enabled by users of the mobile app, via the Android accessibility service (“Non-Personal Information“). This Non-Personal Information is cleaned and scrubbed on your device – prior to being sent to our servers and prior to any other use – for the purpose of removing information that could be used to identify you. As such, we are not aware of and cannot determine the identity of the user from which the Non-Personal Information is collected.

Non-Personal Information collected through your use of the browser extension and desktop app includes:

• Browsing history information (URLs/domains visited)
• Internet Protocol address – but note that we permanently delete and hash the last portion of your Internet Protocol address before storing it, thus preventing us from having the ability to use it to transmit any information to your device or to otherwise identify you.

Non-Personal Information collected through your use of the mobile app includes:

Android

• Device information (operating system version, device model name, screen size, and mobile network code)
• Browser type
• List of installed apps (app name, app ID, installation and update date, version, whether app is a system app, whether app is on home page)
• App usage (including duration of use) – but note that we do not collect data from within the installed apps, but rather solely aggregated data concerning use itself
• Browsing history information (URLs/domains visited, bookmarks, and the dates, times and durations of visits)
• Internet Protocol address and device ID – but note that we permanently delete and hash the last portion of the Internet Protocol address before storing it, and we permanently encrypt and hash the device ID, thus preventing us from having the ability to transmit any information to your device or to otherwise identify you

Such Non-Personal Information is processed for the purposes described in the “How Is the Data Used?” section hereunder.

We may disclose or share this Non-Personal Information with third parties as specified below and solely if applicable.

We do not collect from you any individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Information“) except as may be voluntarily provided by you if and when you register and create an account or otherwise contact us, such as your name and email address, provided that such information will be used solely to communicate with and support you, and will not be shared with any third parties except as set forth in the “How is the Data Shared” section below.

How is the Data Used?

We collect your information during your access or use of the True Locker Website or the True Locker Product as detailed above, and use that information to block your access to certain sites based on parameters you define and control (the “Services”). We use that information based on our legitimate interests in promoting and improving the True Locker Product and our services, on the necessity of such information for the provision of the True Locker Product and our services where applicable (as described in this Privacy Policy) or, where permitted under applicable law, on the implied consent that you provide by using the True Locker Product, or by requesting support, registering for the True Locker Product, or through your use of the various forums and blogs available within the website.

In practice, in order to provide the True Locker Product and the Services, we need to scan the web pages you browse, and we need to retrieve the apps you are trying to open. Meaning, we use the data collected from you, as detailed and specified above, and transmit it to our servers for the purpose of enabling the True Locker Product and in order to know when and where there is content, a website or an app to block. Thus, the processing of Non-Personal Information in this context is necessary for a user-facing feature, namely the provision of the Services as described above. Accordingly, without access to such information, some or all of the site-blocking would not work. You acknowledge and agree that by using the True Locker website and by downloading and using the True Locker Product, you request that we provide you with the Services.

We also use Non-Personal Information, aggregated information or statistics regarding user browsing behavior as a measure of interest in, and use of, the True Locker Product in the form of aggregated data, such as overall patterns or demographic reports, which do not describe or identify any individual user.  Aggregated Non-Personal Information may also be shared with affiliated companies for purposes of market analytics.

How is the Data Shared?

We do not share any Personal Information collected from you with third parties or any of our partners. We may disclose information you submitted if we have a good faith belief that disclosure of such information is reasonably necessary:

(i) to comply with any applicable law, regulation, legal process or governmental request;

(ii) to enforce our policies (including our policies and agreements), including investigations of potential violations thereof;

(iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;

(iv) to establish or exercise our rights to defend against legal claims;

(v) to prevent harm to the rights, property or safety of us, our users, yourself or any third party; or

(vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.

Note that we may also appoint third-party service providers, or have certain services provided by one of our affiliated companies, operating under our instructions, who may need access to your information in connection with their services on our behalf. Transfers of your Personal Information will be made in accordance with applicable data protection laws.

We will take the necessary steps to ensure that international transfers of personal data (including Personal Information) meet all requirements under applicable data protection laws. When personal data collected within the European Economic Area (“EEA“) is transferred outside the EEA, we will take the steps necessary to ensure that the transfer of such data provides sufficient safeguards, and you may exercise your rights, where applicable, to receive information on such transfer mechanisms.

Cookies and Third-Party Tools

When you use the True Locker Website or our Product, we may use Cookies that enable us to identify you. Please note that a “Cookie” is a small text file found in a browser directory, which a website assigns and stores on your computer while you view a website. It is a standard practice to use Cookies, and they are used for different purposes including allowing you to navigate among pages efficiently, facilitating automatic activation of some features, remembering your preferences, and making the interaction between you and various services such as ours easier and faster. In addition, Cookies are used to help customize your user experience. More information about cookies can be found at www.allaboutcookies.org.

True Locker’s Website may use third-party tools (e.g. www.google.com/analytics/,  https://keen.io or some of the tools described below) or third-party content (e.g. www.youtube.com). These third parties may use and store their own Cookies on your device, which Cookies may collect information about you, including Personal Information, subject to the privacy practices of these third parties. These third-party Cookies may collect information such as how often users access our Website, what pages users visit, and when. For additional information on third party Cookies, please check with the relevant third party.

We use the information we receive from third parties such as Google Analytics based on our legitimate interests in promoting and improving the True Locker Product and our services. Note that we do not combine the information collected through the use of third-party tools with any Personal Information collected from you. You may remove Cookies by following the instructions on your device governing the setting of your preferences. Our Cookies do not enable any access to or inspection of other information on your device. If you wish to be notified of when Cookies are placed on your device, you may set your web browser to provide such notices.

These are some of the tools used in our Products and/or Website:

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize our service and user experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and do not like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt out of the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites, by following this opt-out link.

Taboola

Our Website uses technologies from Taboola Inc. (28 West 23rd St. 5th Fl, New York, NY 10010, www.taboola.com, “Taboola”). Taboola uses Cookies that determine how you navigate our Website, which of our pages you visit, and to determine what content and video services you use. The Cookie enables us to create pseudonymous user profiles by collecting device-related data as well as log data, and to recommend content that suits your personal interests, so that we can design our offer individually for you. These usage profiles are not merged with data about the bearer of the pseudonym and do not allow us to draw any conclusions about the data subject. For more information about Taboola and the ability to disable the Taboola Cookie, visit https://www.taboola.com/privacy-policy.

Facebook Pixel

Our website measures conversions using visitor action pixels from Facebook Inc. (1601 S. California Ave, Palo Alto, CA 94304, USA, “Facebook”).

These allow the behavior of site visitors to be tracked after they click on a Facebook ad to reach the provider’s website, allowing an analysis of the effectiveness of Facebook advertisements for statistical and market research purposes and their future optimization.

The data collected is anonymous to us as operators of this website and we cannot use it to draw any conclusions about our users’ identities. However, the data are stored and processed by Facebook, which may make a connection to your Facebook profile and which may use the data for its own advertising purposes, as stipulated in the Facebook privacy policy. This will allow Facebook to display ads both on Facebook and on third-party sites. We have no control over how this data is used.  See Facebook’s privacy policy to learn more about protecting your privacy: https://www.facebook.com/about/privacy/.

You can deactivate the Facebook custom audiences remarketing feature in the Ads Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

Sentry

We use Sentry (https://sentry.io/welcome/) for real-time error tracking for our Products and Website, in order to obtain the insight needed to reproduce and fix bugs, errors and crashes. For further details, please see Sentry’s privacy policy by clicking on this link.

Firebase

We use Firebase (https://firebase.google.com/) for user registration and authentication, for users who decide to create accounts and provide their email address and create passwords for that purpose. For further details, please see Firebase’s privacy policy by clicking on this link.

Opt out right

You may opt out of the automatic collection and sharing of Non-Personal Information described above as follows:

For the mobile app (Android):

By selecting the checkbox next to the words “Opt Out” which can be found in the “Settings” screen of the application.

For Cookies used on the Website:

Follow the instructions of the relevant third party, as indicated.

After you opt out, we will no longer automatically collect and share your Non-Personal Information as described in this Privacy Policy. Note that once you opt out, some or all of the Services provided by True Locker will no longer be available.

User Rights

Please note that, unless you instruct us otherwise, we retain the information we collect for as long as needed to provide the services described herein and to comply with our legal obligations, resolve disputes and enforce our agreements. If you object to the aforesaid collection, use and share of data, please uninstall or disable the True Locker Product immediately from your device.

Where provided under applicable law (e.g., within the European Union), you may have the right to ask us to delete Personal Information which you have provided to us,  subject to applicable exceptions, such as in order to preserve that information for anticipated litigation or demands from a regulator, or some or all of the following rights: the right to obtain information on our use of your Personal Information, the right to obtain a copy thereof, the right to data portability, the right of data rectification, the right to object to processing based on our legitimate interests, the right to restriction of the processing, and the right to withdraw your consent.

In order to assert any of these rights, please contact our Data Protection Officer at: [email protected]. Note that we may request proof of your identity, and we reserve the right to charge a fee where allowed by law, such as in circumstances where your request is deemed to be excessive.

In addition, you may have the right to lodge a complaint with a supervisory authority, subject to applicable law (as is the case in the European Union).

How do we safeguard your information?

We make best efforts to use security methods and encryptions when handling sensitive data (i.e., handle the user data securely, including transmitting it via modern cryptography). Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through the True Locker Products cannot be 100% guaranteed.

Minors

Children under 13 are prohibited from using the True Locker Product. In the event that we become aware that a user under the age of 13 has shared any information, we will discard such information. If you have any reason to believe that a child under the age of 13 has shared any information with us, please contact our Data Protection Officer at: [email protected]. If you are under 18, please be sure to read this policy with your parents or legal guardians and ask questions about things you do not understand.

Amendments

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy Policy. The last revision date will be reflected in the “Last modified” heading. Your continued use of the True Locker Product, following the notification of such amendments on our website, constitutes your acknowledgement of such amendments to the Privacy Policy and, where the processing of personal data is based on consent (see above), your agreement to be bound by the terms of such amendments.

How to contact us?

If you have any questions about these terms, please contact us at: [email protected]

November 2020