Privacy policy.

01Introduction

Welcome to Unlokr. We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform, services, and website (collectively, the “Service”). By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy.

02Information We Collect

Personal Information:

• Name and contact information (email address, phone number)
• Account credentials (username, password)
• Payment and billing information
• Profile information and preferences
• Government-issued identification (KYC): for creator accounts, we collect identity documents (e.g., national ID, passport, or driver's licence) to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under applicable law. This data is processed by our third-party KYC verification provider under a data processing agreement and is retained for a minimum of 5 years from the date of collection, or longer as required by applicable financial regulations. KYC data is stored on secure servers and is not shared with third parties except as required by law or our verification provider.

Usage Information: device information (IP address, browser type, operating system), log data (pages visited, time spent, actions taken), cookies and similar tracking technologies, and location data (if permitted).

Content Information: content you create, upload, or share; comments, messages, and communications; subscriptions and preferences.

03How We Use Your Information

We use the information we collect for various purposes:

• To provide, maintain, and improve our Service and its features
• To process transactions and manage payments
• To verify your identity and conduct KYC checks
• To communicate with you about your account and our services
• To send you updates, newsletters, and promotional materials
• To personalize your experience and content recommendations
• To detect, prevent, and address technical issues and fraud
• To comply with legal obligations and enforce our policies
• To analyze usage patterns and improve user experience
• To protect the rights, property, and safety of Unlokr and our users

04Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA) or United Kingdom, we process your personal data under the following lawful bases as required by the GDPR and UK GDPR:

• Contract Performance (Art. 6(1)(b)): processing necessary to create and manage your account, process payments, and deliver the Service you have signed up for.
• Legitimate Interests (Art. 6(1)(f)): processing necessary for fraud prevention, security, improving our Service, and direct marketing to existing users — where these interests are not overridden by your rights.
• Legal Obligation (Art. 6(1)(c)): processing required to comply with applicable law, including KYC/AML obligations, tax reporting, and responding to lawful government requests.
• Consent (Art. 6(1)(a)): processing based on your explicit consent, including non-essential cookies and marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

For special category data (e.g., government-issued identification for KYC), we rely on explicit consent (Art. 9(2)(a)) and, where necessary, compliance with legal obligations (Art. 9(2)(g)).

05Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

• Service Providers: third parties who perform services on our behalf, such as payment processing, data analytics, hosting, customer support, and email delivery. These providers are contractually obligated to protect your information.
• Business Transfers: in the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.
• Legal Requirements: if required by law, court order, or governmental authority, or to protect our rights, property, or safety, or that of our users or others.
• With Your Consent: with your explicit consent or at your direction.
• Public Information: information you choose to make public, such as your profile or public content, may be visible to other users and the general public.

06Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, secure servers, access controls, and regular security assessments. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

07Your Rights and Choices

Depending on your location, you have the following rights regarding your personal information:

• Access (Art. 15 GDPR): request a copy of the personal information we hold about you.
• Correction (Art. 16 GDPR): update or correct inaccurate personal information through your account settings or by contacting us.
• Erasure / “Right to be Forgotten” (Art. 17 GDPR): request deletion of your account and associated personal data, subject to legal retention obligations.
• Restriction of Processing (Art. 18 GDPR): request that we limit how we process your data in certain circumstances.
• Data Portability (Art. 20 GDPR): receive a copy of your data in a structured, machine-readable format and request transfer to another controller.
• Objection (Art. 21 GDPR): object to processing based on legitimate interests or for direct marketing purposes.
• Withdraw Consent: where processing is based on consent, withdraw it at any time without affecting prior processing.
• Opt-Out of Marketing: unsubscribe via the link in any email, or adjust your account notification preferences.
• Cookie Preferences: manage non-essential cookie consent via our cookie banner or browser settings.

To exercise any of these rights, contact us at support@unlokr.app. We will respond within 30 days of receipt. We may request proof of identity before fulfilling sensitive requests. If you are unsatisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.

08Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to collect and store information about your interactions with our Service. Types of cookies we use:

• Essential Cookies: required for the Service to function properly
• Analytics Cookies: help us understand how users interact with our Service
• Functional Cookies: remember your preferences and settings
• Advertising/Targeting Cookies: used to deliver relevant advertisements. Under the CCPA, this sharing may constitute a “sale” of personal information; California residents may opt out by contacting us at support@unlokr.app or via our cookie consent banner.

You can control cookies through your browser settings or our cookie consent banner, but disabling certain cookies may limit your ability to use some features of the Service.

09Third-Party Services

Our Service may contain links to third-party websites, services, or applications that are not owned or controlled by Unlokr. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through our platform.

10Children's Privacy

Our Service is not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information. If you believe we have collected information from a child, please contact us immediately.

11International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country. By using our Service, you consent to the transfer of your information to these countries. We take appropriate measures to ensure that your information receives an adequate level of protection in accordance with this Privacy Policy.

12Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When you delete your account, we will delete or anonymize your personal information, except where we are required to retain it for legal, regulatory, or legitimate business purposes.

13Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify the relevant supervisory authority (e.g., the Nigerian Data Protection Commission (NDPC), or your local DPA if you are in the EEA/UK) without undue delay and, where feasible, within 72 hours of becoming aware of the breach.
• Notify affected users without undue delay where the breach is likely to result in a high risk to their rights and freedoms, providing details of the nature of the breach, the likely consequences, and the measures we are taking to address it.

We maintain an internal breach register and conduct regular security assessments. If you suspect your account has been compromised, contact us immediately at support@unlokr.app.

14Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last updated” date. Your continued use of the Service after any changes constitutes acceptance of the updated Privacy Policy.

15Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy, or wish to exercise your data rights, contact us at support@unlokr.app or via https://unlokr.app. We will respond to all data rights requests within 30 days of receipt, as required by applicable law.

16California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your personal information, the right to opt out of the sale of your personal information (we do not sell personal information), and the right to non-discrimination for exercising your privacy rights. To exercise these rights, contact us using the information in the Contact section.

17GDPR Rights (European Users)

If you are located in the EEA or the UK, the GDPR and UK GDPR apply to our processing of your personal data. In addition to the rights listed above, you have:

• The right to be informed about how your data is used — which this Privacy Policy fulfills.
• The right to withdraw consent at any time for any processing based on consent.
• The right to object to automated decision-making and profiling that produces legal or similarly significant effects on you.
• The right to lodge a complaint with your local supervisory authority — for example, the ICO in the UK, or your national DPA in the EU.

We will respond to all GDPR requests within 30 days. In complex cases we may extend this by a further two months, and we will inform you of any such extension within the initial 30-day period. We do not charge a fee for exercising these rights unless requests are manifestly unfounded or excessive.

By using Unlokr, you acknowledge that you have read, understood, and agree to this Privacy Policy.