LOCPIN PRIVACY POLICY

Locpin Limited ("the company", "we" or "us") is committed to safeguarding the privacy of our customers, whilst also providing a personalised and valuable service. This Privacy Policy explains the basis on which information we collect from you, or that you provide to us, will be processed by us. We appreciate that you do not want your personal information distributed and used indiscriminately, and here we explain how we collect information via our secure website at https://www.locpin.com ("the website") and our mobile applications ("the apps") and our application program interface ("the API") to provide the Locpin service ("the service"). By visiting the website, or using the apps, you are accepting and consenting to the practices described in this policy. The company is registered as a data controller in accordance with United Kingdom Data Protection Act 1998. We will process any personal information we collect about you in accordance with the Data Protection Act 1998. Information submitted by you or collected about you via the website or the apps is stored on a system managed in the United Kingdom. This information may be transferred to our other offices which are situated outside the UK, but will only be used for the purposes outlined in this policy and in accordance with our data security guidelines. If you have any requests concerning your personal information, or wish to make any amendment to your personal information, or have any queries with regard to our practices, please let us know by using the Contact Us form on the website, or by writing to us at the address in section 4.5 below.

1. INFORMATION WE COLLECT FROM YOU

1.1 We may collect and process the following data from you:

1.1.1 You provide us with personal information when registering for the service, and whenever you update your registration details. You may provide us with information about you in correspondence with us by phone, email or otherwise. You may also give us personal information when engaging in other activities commonly carried out on the website (for instance, when participating in discussion boards, or entering a competition, promotion, or survey). The information you provide us may include your name, email address, postal address and telephone number.

1.1.2 With regard to each of your visits to the website we may automatically collect technical information, including the Internet Protocol (IP) address used to connect to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We may also collect information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page and any phone numbers used to call our customer services team.

1.2 You are under no obligation to provide us with such information. However, if you choose to withhold requested information, we may not be able to provide you with the service or respond effectively to you.

1.3 We may receive information about you from third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).

1.4 We may use the personal information you give to us via the website and apps for the purposes of:

1.4.1 providing you with the Locpin service; or

1.4.2 conducting market consultation exercises; or

1.4.3 providing you with information about products and services offered by the company and its associates; or

1.4.4 to notify you about changes to our service; or

1.4.5 to ensure that content from the website is presented in the most effective manner for you and for your computer.

1.5 We may use the information collected about you via the website and the apps for the purposes of:

1.5.1 Administering our website/apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, or

1.5.2 Improving our website/apps to ensure to ensure content is presented in the most effective manner for you and for your computer, or

1.5.3 Keeping our website/apps safe and secure, or

1.5.4 measuring and understanding the effectiveness of advertising we serve to you and others, and delivering relevant advertising to you, or

1.5.5 making suggestions and recommendations to you and other users of our website/apps about goods and services that may interest you or them.

1.6 We may send you information by email or post about the company’s products and services that may be of interest to you. This information will only come from us and only if you have indicated that you wish to receive this information in your registration.

2. DISCLOSURE OF PERSONAL INFORMATION

2.1 We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

2.2 We may share your information with selected third parties, including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, as well as advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. The information we may provide to advertisers or advertising networks will be in aggregate form. We may also share your information with analytics and search engine providers that assist us in the improvement and optimisation of our website and apps.

2.3 We may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. Personal data may also be transferred if Locpin Limited or substantial assets belonging to Locpin Limited are acquired by a third party.

2.4 We may use information in aggregate form, so that no individual user is identified, to:

2.4.1 build up marketing profiles; or

2.4.2 aid strategic development; or

2.4.3 manage our relationship with advertisers; or

2.4.4 audit usage of the site.

2.5 We reserve the right to disclose personal information if required to do so by law or if we believe that it is necessary to do so to protect and defend the rights, property or personal safety of the company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

3. LINKS

3.1 Our website may contain links to third-party websites and services and our API may be used by other websites and services. We cannot be responsible or liable for the privacy policies and practices of those parties, even if you access their services using links from us or our API, and we recommend that you check the privacy policy of each site or service you visit.

3.2 If you linked to our website using links or our API from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check their own privacy policy.

4. YOUR ACCEPTANCE OF THIS POLICY

4.1 By using our service, you consent to the collection and use of your information by the company and to this principle set out in this policy. If we change this policy, we will publish the changes and if the change affects the use of your personal information, then we will use our best endeavours to contact you by email.

4.2 You have a legal right to a copy of any personal information about you that is held by us. You also have a right to correct any errors in that information, and to request that we cease to use your personal information for direct marketing purposes. You can exercise this right at any time by using the Contact Us form on the website, or by writing to us at the address in section 4.5 below.

4.3 The company shall not be responsible for any failure to adhere to this policy. Whilst we use all reasonable endeavours to protect your privacy in the manner described above, data transmission over the Internet and the World Wide Web cannot be guaranteed as secure and you use the service at your own risk.

4.4 The company may reasonably vary this policy from time to time and will notify you of those changes.

4.5 The service is owned and operated by Locpin Ltd, 5 North Street, Hailsham, East Sussex, England BN27 1DQ. Locpin Ltd is a company limited by guarantee and registered in England and Wales, company number 08042338, VAT registration number 169314787.