5. Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following limited circumstances:

5.1 Third-Party Service Providers

We use the following third-party services to help us operate our Service:

RevenueCat

• Purpose: Subscription and paywall management

• Data Shared: Anonymous subscription status, purchase history (through Apple)

• Privacy Policy: https://www.revenuecat.com/privacy

Apple App Store

• Purpose: App distribution, payment processing, subscription management

• Data Shared: As required by Apple for app functionality and payments

• Privacy Policy: https://www.apple.com/legal/privacy/

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency), including to:

• Comply with a legal obligation

• Protect and defend our rights or property

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of users or the public

• Protect against legal liability

5.3 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Service of any change in ownership or uses of your personal data.

5.4 With Your Consent

We may share your information for other purposes with your explicit consent.

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6. Data Retention

6.1 Retention Period

We retain your personal data for as long as your account is active or as needed to provide you with our Service. Specifically:

• Account Information (Name, Email, City): Retained indefinitely while your account remains active

• Step Count Data: Retained indefinitely while your account remains active

6.2 Account Deletion

If you wish to delete your account and associated data, you may contact us at support@locktapp.co.uk to request account deletion.

Upon receiving your request, we will delete your personal data within 30 days, except where we are required to retain it for legal or legitimate business purposes

6.3 Retention After Deletion

After account deletion, we may retain certain information in anonymized or aggregated form for analytical purposes. This data cannot be used to identify you personally.

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7. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption: Data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols

Secure Storage: Personal data is stored on secure servers with restricted access

Access Controls: Only authorized personnel have access to personal data, on a need-to-know basis

Regular Audits: We regularly review and update our security practices

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

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8. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal data:

8.1 Rights for All Users

All users have the right to:

• Access: Request a copy of the personal data we hold about you

• Correction: Request correction of inaccurate or incomplete personal data

• Deletion: Request deletion of your personal data

• Withdraw Consent: Withdraw your consent at any time where we rely on consent to process your data

8.2 Additional Rights for EEA/UK Users (GDPR)

If you are located in the EEA or UK, you also have the right to:

• Data Portability: Request a copy of your data in a structured, commonly used, machine-readable format

• Restriction: Request restriction of processing of your personal data

• Object: Object to processing of your personal data based on legitimate interests

• Lodge a Complaint: Lodge a complaint with your local data protection authority UK Information Commissioner's Office (ICO): https://ico.org.uk/

8.3 How to Exercise Your Rights

To exercise any of these rights, please contact us at: support@locktapp.co.uk.

We will respond to your request within 30 days (or as required by applicable law). We may need to verify your identity before processing your request.

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9. Children's Privacy

9.1 Age Rating

Our App is rated 4+ and is suitable for users of all ages. However, we do not knowingly collect personal information from children under the age of 13 (or 16 in the EEA/UK) without parental consent.

9.2 Parental Responsibility

Parents and guardians are responsible for:

• Supervising their children's use of the App

• Providing consent for their children to use the App

• Ensuring the App is appropriate for their child's age and physical condition

9.3 Parental Rights

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us at support@locktapp.co.uk. We will take steps to remove such information from our servers.

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10. International Data Transfers

10.1 Data Storage Location

Your personal data may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that are different from the laws of your country.

10.2 Safeguards

When we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission

• Adequacy decisions by the European Commission

• Other legally recognized transfer mechanisms

10.3 Your Consent

By using our Service, you consent to the transfer of your information to countries outside your country of residence, where we or our service providers operate.

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11. Third-Party Links and Services

11.1 External Links

Our Service may contain links to third-party websites, services, or applications that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

11.2 Recommendation

We strongly advise you to review the privacy policy of every site you visit. We are not responsible for the privacy practices of third parties.

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12. Pedometer and Motion Data

12.1 Pedometer Integration

If you choose to grant permission, the App may access step count data from Pedometer. This data is used solely to:

• Track your daily steps

• Determine when blocked apps should be unlocked

• Display your step progress within the App

12.2 Pedometer Data Protection

In accordance with Apple's requirements:

• We do not use Pedometer data for advertising or marketing purposes

• We do not sell Pedometer data to third parties

• We do not share Pedometer data with third parties for their marketing purposes

• Pedometer data is not stored in iCloud or any unsecured storage

12.3 Motion & Fitness Data

If you grant permission, the App may access your device's motion and fitness activity. This data is processed locally on your device and used only for step counting functionality.

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13. Push Notifications

13.1 Types of Notifications

With your permission, we may send you push notifications to:

• Remind you of your step goals

• Notify you when blocked apps are unlocked

• Provide important updates about the Service

13.2 Managing Notifications

You can manage or disable push notifications at any time through:

• Your device's Settings app

• The notification settings within the App
   

14. Analytics and Tracking

14.1 Analytics We Use

We may use analytics tools to understand how users interact with our App. These tools help us improve the user experience and fix issues.

14.2 No Third-Party Advertising

We do not display third-party advertisements in our App. We do not share your data with advertising networks or use your data for targeted advertising purposes.

14.3 No Tracking Across Apps

We do not track your activity across other companies' apps or websites for advertising purposes.

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15. Changes to This Privacy Policy

15.1 Updates

We may update this Privacy Policy from time to time. We will notify you of any changes by:

• Posting the new Privacy Policy on this page

• Updating the "Last Updated" date at the top of this Privacy Policy

• Sending you an email notification (for material changes)

• Displaying a notice within the App (for material changes)

15.2 Review

We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15.3 Continued Use

Your continued use of the Service after we post changes to this Privacy Policy constitutes your acceptance of those changes.

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16. Data Protection Officer

16.1 Contact

For any questions or concerns regarding this Privacy Policy or our data practices, you may contact our Data Protection Officer at support@locktapp.co.uk.

16.2 Response Time

We will respond to your inquiry within 30 days or as required by applicable law.

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17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at support@locktapp.co.uk.

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18. Summary of Key Points

For your convenience, here is a summary of the key points in this Privacy Policy: