Release date：September 10, 2024.
Commencement date：September 11, 2024.
Lockin Security APP (hereinafter referred to as the ‘APP’ or the ‘Platform’) is a smart device control and management platform provided to you by LOCKIN INTERNATIONAL PTE.LTD and its affiliates (hereinafter referred to as ‘LOCKIN’ or ‘we’). ‘LOCKIN’ or “we”) provides you with a platform to control, manage and administer your smart devices and collect, use, disclose or otherwise process your personal data in accordance with applicable laws, including Singapore's Personal Data Protection Act 2012 and its amendments from time to time (the “PDPA”). , disclose or otherwise process Users' personal data. This Privacy Policy applies to personal data in our possession or control, including personal data held by organisations that we have engaged to collect, use, disclose or process personal data for our purposes.
This Privacy Policy was last updated on [September 10] 2024.
Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.
This Privacy Policy sets out how APP collects, uses, discloses, processes and protects any personal data that you give us when you use our software or services. Should we ask you to provide certain information by which you can be identified when using our software and services, it will only be used in accordance with this Privacy Policy, our terms and conditions for users and/or applicable laws (including the PDPA).
The Privacy Policy is designed to assist you in understanding how we may collect, use, disclose or otherwise process personal data you provide to us in accordance with the, and in making informed decisions when you are using our software and/or services or any other means through which you disclose your personal data to us.
In this Privacy Policy, “personal data” shall have the meaning ascribed to it in the PDPA. Such personal information may include but not limit to the information you provide to us or upload, device information, etc.
By using our software and/or services, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time.
If you have any concerns about our data processing practices as outlined in this Privacy Policy, please contact our Data Protection Officer, via the contact details below. We will be happy to address any concerns you may have directly. Contact details for the Data Protection Officer: support@lockin.com.
In order to provide our services to you, we will ask you to provide personal data that is necessary to provide those services to you. If you do not provide your personal data, we may not be able to provide you with our services.
We generally do not collect your personal data unless
· It is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or
· You are deemed to have consented to the collection of your data in accordance with the Personal Data Protection Act or other applicable laws;
· The collection and use of your personal data without consent is permitted or required by the PDPA or other applicable laws.
We will seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Depending on the nature of your interaction with us, we may collect your device serial number, network information, geo-location information, login account information, smart device hardware information, operation status, operation records, as well as location information of smart phones and other terminals, smart device sharing information, smart scenarios (smart linkage of devices), etc. (which may or may not constitute personal data). Each of the above information includes, but is not limited to, the following:
· Login account information: APP account, nickname, avatar, email related information, etc.
· Mobile phone related information: hardware device identification (IMEI/OAID, Mac address, Android ID, device serial number), mobile phone model, system version information, system language, country or region where the mobile phone is set up, version number of the app shop, screen size and resolution of the mobile phone, CPU and display device related information..
· Network information: We may collect network-related information when your smart device connects to the network, including Wi-Fi strength, RSSI, current connection mode, IP address, MAC address, network status of the device and the mobile phone, network status of the device and the server, online status of the device (including online, offline), as well as the Wi-Fi name (SSID), Wi-Fi password, etc., provided by you voluntarily.
· App Upgrade: In order for you to continue to enjoy the latest Deerhunter services, we may use your app's version information and mobile phone model for the purpose of providing you with upgrades to the Deerhunter app.
· Other information: We may collect questions, feedback logs, and email addresses that you send to us, and may collect other information that does not identify a specific individual, such as statistical data generated by your use of a particular service, such as user actions (including clicks, page jumps, and time spent browsing). In addition, we may also call your device permissions. Below are the business functions corresponding to the calling permissions, the purpose of our calling, and the circumstances in which we ask you before calling. You can choose to turn off some or all of these permissions in the settings function of your device, so that you can refuse to allow us to call the relevant permissions.
Device authority | Corresponding Business Functions | Purpose of use | Whether to enquire |
Placement | Locate services, add devices | Obtaining user location information to provide device services (e.g., installation, etc.), adding devices when the user discovers a list of nearby Wi-Fi or Bluetooth | Yes |
At the opportune moment | Adding devices, setting up avatars | For taking photos, uploading images, recognising QR codes | Yes |
Photo album | Setting up avatars, downloading videos | Used to write and read the user's photo album information, store the cat's eye video downloaded to the mobile phone | Yes |
Telephones | Call | Calls to customer service, emergency calls to report | Yes |
Save | Setting up avatars, app upgrades | Used to write and read user's photo album information, store APP update installation package | Yes |
Personal data is usually collected for the purpose of providing services to you and our compliance with applicable laws (including the Personal Data Protection Act). By providing us with your personal data, you hereby agree that we may collect, use, process and disclose (including transfer) personal data to our affiliates, Third Party Service Providers (as defined below) for the purposes described in this Privacy Policy and in accordance with applicable law (including the Personal Data Protection Act). If you do not agree to this Privacy Policy, please do not provide us with any Personal Information.
We may use your personal information for the following purposes:
· Providing, processing, maintaining, improving and developing our services to you, including after-sales and customer support and for services on your device or through our websites and applications.
· Where necessary to perform and/or enforce the terms and conditions for users.
· Communicating with you about your device, service or any general queries, such as updates, customer inquiry support, information about our events, notices, and responding to, handling and processing queries, requests, applications, complaints, and feedback from you.
· Storing and maintaining information about you for our business operations or legal obligations.
· Providing local services without communicating with our servers.
· Verifying your identity, updating your personal and contact information, and managing our business relationship with you.
· Sending you marketing information about our services.
· Improve our applications, software, services.
Promote our products, apps, software, services to you, including by email, app notification, phone, SMS or fax.
· Any other purposes for which you have provided the information.
· Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, or for the purposes of legal proceedings.
· To transmit to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes including sub-processors for the processing of your personal data (“Third Party Service Providers”), and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
· Any other incidental purposes reasonably related to or in connection with the above.
We do not sell, trade or rent any personal information to third parties.
We may disclose your personal data where such disclosure is required for performing obligations in the course of or in connection with our provision of the services.
We may disclose and share your personal data with the following parties.
· Within our corporate organisation.The Company is part of a corporate organisation which has multiple legal entities, business processes, management structures and technical systems. We may share your personal data with our relevant group companies and, in some cases, other subsidiaries of our corporate group for business maintenance and personalisation continuity purposes, for example so that you can enjoy a personalised user experience with our digital services, to provide you with a personalised service, or to act on your requests or preferences.
· (Internet) service provider.We may share your personal data with the following types of third party service providers listed in the table below:
Vendor/service provider/processor | Services provided |
IT system and software service provider | Web hosting services (including cloud storage), mobile application or software optimisation services, customer relationship management software, email service providers or system maintenance services. |
Marketing and advertising services | Assist in reaching out to potential new customers through multiple communication channels or share with affiliates who promote our products and/or services on their websites. |
Customer service providers | Assist with customer service and support. |
Fraud prevention and data security service provider | Authentication, fraud prevention or credit risk reduction services to protect our website/application and our business. |
In accordance with our written instructions, we endeavour to ensure that our third party service providers only use your data for the purposes for which it was provided to them and to the extent necessary for such purposes.
· Maintain legal and regulatory compliance.We have the right to disclose your personal data as required by law or if we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, a court order, a request from a regulatory body or any other legal process served on us. We may also disclose your information when we believe it is reasonable to do so, such as when it is necessary to enforce our agreements or policies, or if we believe that disclosure will help us to protect the rights, property or safety of the company or our customers.
· Agree with.We may disclose your personal data for any purpose with your consent.
Information about third-party SDKs with information collection functions involved in the use of the APP is as follows:
Third-party SDK name: Google Location Services
Provider name: Google, Inc
Types of information collected: device identification information (IMEI [for versions of Android Q and below], MAC address, Android ID, OpenUDID, GUID), location information (fuzzy positioning)
Purpose of information collection/use: to match service providers near the user's area to provide fast door-to-door service.
Applicable operating system: Android
Privacy Policy Details:
http://www.android-doc.com/reference/com/google/android/gms/common/package-summary.html
Third-party SDK name: FCM Push
Provider name: Google
Type of information collection: list of running applications.
Purpose of Information Collection/Use: Used to receive push messaging services, including APNS pushes, to those who use the overseas version of the device in overseas areas. Push messages to the mobile phone system notification bar.
Applicable operating system: Android
Privacy Policy Details: https://firebase.google.com/terms/data-processing-terms
Third-party SDK name: meta open source framework - ReactNative
Provider name: Meta Platforms, Inc
Type of information collection: device identification information (Android lD, OpenUDID, GUID, OAID)
Purpose of information collection/use: for rapid cross-platform development of stable and easy-to-use application pages.
Operating system: Android and iOS
Privacy Policy Details: https://opensource.fb.com/legal/privacy/
Third-party SDK name: Tencent Cloud IoT Development Platform
Provider Name: Shenzhen Tencent Computer Systems Limited | Tencent Cloud Computing (Beijing) Co.
Types of information collected: recordings (voice calls), system settings (locally saved audio/video, log files), network status information (IP, current network type and name).
Purpose of information collection/use: to provide video connectivity, storage and smart application services that are secure and efficient
Operating system: Android and iOS
Privacy Policy Details: https://cloud.tencent.com/document/product/1131/74348
Third-party SDK name: Google Analytics
Provider Name: Google
Types of information collected: Device serial number, device identification information ((IMEI [for versions of Android Q and below]), MAC address, Android ID, IDFV, OpenUDID, GUID), SIM card, IMSI, ICCID, IP, SD card.
Purpose of information collection/use: Statistics and reporting of app errors are used to improve app stability.
Operating system: Android and iOS
Privacy Policy Details: https://policies.google.com/privacy?hl=zh-CN
APP may disclose your personal information without consent or further consent as permitted by applicable laws (including the Personal Data Protection Act) and written guidelines issued by the Personal Data Protection Commission of Singapore from time to time.
· Email Communications. From time to time we may send you emails about updates to our services, notices from our organisation or information about products/services we offer that we think may be of interest to you. If you wish to unsubscribe from these emails, simply click on the ‘unsubscribe link’ at the bottom of the email. Please note that you cannot unsubscribe from certain service-related communications (e.g., account verification, transaction confirmation, technical or legal notices).
· Text Messaging. We may use the personal information we collect to communicate with individuals via SMS, including (where you have consented) to market to you or provide you with information and updates on products or services that we think may be of interest to you. You may unsubscribe from subsequent marketing text messages at any time by replying ‘STOP’ or by clicking on the unsubscribe link (if any) in one of our text messages.
· App Notifications. We may send you notifications about this, as well as occasional marketing notifications, through the App. You can deactivate such notifications in your account settings provided by the App.
This Privacy Policy does not apply to aggregated information which summarises statistical information about groups of members, and which does not include name, contact information, or any other information that would allow any particular individual to be identified.
We may share anonymized information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.
We are committed to keeping your personal information secure. In order to protect against unauthorised access, disclosure or other similar risks, we have put in place reasonable processes of physical, electronic and managerial measures to safeguard the information we collect from you when you use Lockin products and services. We will take all reasonable measures to protect your personal information.
All your personal information is stored on secure servers and protected in controlled facilities. We categorise your data according to its importance and sensitivity and ensure that your personal information has the appropriate level of security. We ensure that our employees and third-party service providers who access this information to help provide products and services to you are under strict contractual obligations of confidentiality, and that failure to comply with these obligations may result in disciplinary action or termination of their co-operation. In summary, we regularly review our information collection, storage and processing practices, including physical security measures, to prevent any unauthorised access and use.
We will take all practicable steps to protect your personal information. However, you should be aware that the use of the Internet is not always secure and therefore we cannot guarantee the security or integrity of any personal information when transmitted in both directions over the Internet.
Everyone's privacy concerns are different. As a result, we have provided examples of the various ways that APP provides you with choices to limit the collection, use, disclosure or processing of your personal information and to control your privacy settings:
· Turn on or off location access, camera, recording, Bluetooth, HomeKit and read/write phone storage permissions.
· Agree/disagree to the Privacy Policy window when it pops up.
· Sign in or out of your APP account.
· Click on ‘My’ in the platform to modify your personal information, including nickname, avatar, etc.
We will retain personal information as long as necessary to fulfil the purposes for which it was collected or as required or permitted by applicable law. Whenever it can be reasonably inferred that retention of personal information is not necessary to fulfil the purpose for which it was collected, and retention of the information is no longer necessary for legal, dispute resolution, enforcement of our agreements, or other business purposes, we will delete personal information or eliminate the means by which personal information can be associated with a particular individual.
Our apps may need access to certain features on your device, such as WiFi network status. This information is used to allow the application to run on your device and to allow you to interact with the application. In addition, in order to deal with the possible risks of leakage, destruction and loss of personal information, we have developed a number of systems to clarify the classification and grading criteria for security incidents and security breaches and the corresponding handling processes. In the event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly notify the Personal Data Protection Committee and you of the incident by email, letter or push notification.
· You have the right to request access to and/or correction of any other personal information we hold about you. When you update your personal information, we will ask you to verify your identity before we process your request. Once we have obtained sufficient information to fulfil your request for access to or correction of personal data (unless we are prohibited from doing so under the Personal Data Protection Act and other applicable laws), we will respond to your request within any timeframes set out in applicable data protection laws. If we are unable to provide you with any personal data or correct it as you have requested, we will usually tell you why we are unable to do so (unless we are not required to do so under the Personal Data Protection Act).
· A copy of your personal data collected and processed by us will be provided to you upon your request free of charge unless the request warrants a reasonable fee to be charged. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws. If so, we will inform you of the fee before processing your request.
· If you wish to access the personal data we hold about you, or if you believe that any of the information we hold about you is incorrect or incomplete and you wish to submit a correct request, please submit your request to the Data Protection Officer, using the contact details below. Data Protection Officer contact details: support@lockin.com.
You may withdraw your consent to the collection, use and/or disclosure of your personal information in our possession or control by sending a request to support@lockin.com. This can be done by revoking authorisation to the Terms of Use and Privacy Policy in Settings. We will process your request within a reasonable period of time after you have made it and will not collect, use and/or disclose your personal information thereafter in accordance with your request（Unless your consent is not required for the collection, use and/or disclosure of your personal information under the Personal Data Protection Act or other applicable law）.
Please note that your withdrawal of consent may result in certain legal consequences. Depending on the extent to which you withdraw your consent for us to process your personal information, this may mean that you are unable to enjoy some or all of Deerhunter's products or services..
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is up-to-date, complete and accurate, please notify our Data Protection Officer, of any changes to your personal data using the contact details below. Contact details of the Data Protection Officer: support@lockin.com.
In the event that we need to transfer personal data outside of your jurisdiction, whether to our affiliates (which are in the business of communications, social media, information technology and cloud computing) or to third party service providers, we will do so in accordance with applicable law. In particular, we will take measures to ensure that your personal data continues to be protected to a standard at least comparable to that set out in the Personal Data Protection Act.
By using this site, you represent that you are at least the age of majority in Singapore, and you have given us your consent to allow any of your minor dependents to use this site.
We consider it the responsibility of parents to monitor their children’s use of our services. Nevertheless, it is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category.
APP does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided APP with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of the applicable APP services.
This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.
We conduct periodic reviews of our Privacy Policy and may update this Privacy Policy to reflect changes in our information practices. If we make material changes to this Privacy Policy, we will notify you of the specific changes to this Privacy Policy by email (to the email address specified in your account) or by posting them on all Lockin websites or through your mobile device to ensure that you fully understand and agree to them before you begin using the updated Privacy Policy.
Material changes within the meaning of this Privacy Policy include, but are not limited to:
(1) Significant changes in our products or service models. For example, the purpose of processing personal information, the type of personal information, and how personal information is used;
(2) Significant changes in our ownership structure, organisational structure, etc. Such as changes in ownership due to business restructuring, bankruptcy and mergers and acquisitions;
(3) Changes in the primary recipients of personal information to be shared, transferred or publicly disclosed;
(4) Significant changes in your rights to participate in the processing of personal information and the manner in which you exercise them;
(5) In the event of a change in the department responsible for handling the security of personal information, contact information and complaint channels;
(6) When the personal information security impact assessment report indicates a high risk.
If you do not accept the content of the update, we may not be able to provide you with the corresponding services, the consequences of which you need to bear, so please be sure to read and confirm the content of the update!
Such privacy policy changes will apply from the effective date specified in the notice or website. We recommend that you periodically check this page for updates on our privacy practices. Your continued use of the Products and Services on the Website, mobile phone and/or any other device will be deemed to be acceptance of the updated Privacy Policy. We will ask for your consent again when we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.
Also, if you agree to the applicable user agreement and there is an inconsistency between such user agreement and the changed Privacy Policy, the changed Privacy Policy will prevail.
Our Privacy Policy does not apply to products and services offered by a third party. APP services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.
If you have any comments or questions about this Privacy Policy, or if you have any questions about our collection, use or disclosure of your personal information, please contact us using the contact information below and referring to ‘Privacy Policy’. In response to your request for rights, questions or inquiries regarding your personal information, we will arrange for a professional team to contact you within 15 working days to resolve your issue in a timely manner after confirming your information. If your question involves a major issue, we may ask you to provide more information. If you are not satisfied with the response you receive, you may refer your complaint to the relevant regulatory body in your jurisdiction. If you enquire with us, we will provide you with information on the relevant complaint routes that may be applicable to your situation.
Contact Information:
LOCKIN INTERNATIONAL PTE.LTD
Email: support@lockin.com
Address: 2 VENTURE DRNE#11-31 VISION EXCHANGE SINGAPORE (608526)
Thank you for taking the time to read our Privacy Policy!