Privacy Policy

AIRLOCK PRIVACY POLICY


Effective date: February 20, 2019

1. INTRODUCTION

Airlock (“Airlock”, “we”, “us”) is a website and mobile application that helps our users protect their digital privacy. We make specific recommendations (Action Items) that help our users better understand and control their digital privacy. We prioritize Action Items based on two things: the information that our users share about the steps they’ve taken to protect their privacy (their “Privacy Profile”), and the limited diagnostic data collected by our mobile application.

Airlock is a product of Orchard Labs Inc., which has created this Privacy Policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through our website and mobile application (“App” – together with our website, the “Services”) including through our provision and your use of the Services.

The privacy of our end users (“You”) is of the greatest importance to us. By using the Services in any manner, you accept the practices and policies outlined in this Privacy Policy and you consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.


2. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information relating to an identified or identifiable individual (“Personal Information”). The Personal Information that we collect is set out in Section 3 (Collection of Personal Information) below.


3. COLLECTION OF PERSONAL INFORMATION 

3.1 App ID

Our goal is to collect the minimum amount of information required to provide the Services. 

You do not have to create an account to use the Services. When you open the App on your phone, we will assign a unique identifier to your installation of the App (an “App ID”). Your App ID is associated with the diagnostic information gathered by the App (see Section 3.3) as well as the Privacy Profile information that you share with us. 

3.2 Privacy Profile

When you use the Services, you have the option of filling in your Privacy Profile, which gives us more information about your approach and preferences related to protecting your privacy. The following table details the Privacy Profile data that we collect and how it is used:

 
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Note that if you choose to share your email address with us, we will associate it with the other details from your Privacy Profile, as well as with the information associated to your App ID. Your email address is the only identifying data that we collect about you.

3.3 Information collected automatically through the App

When you use our application on your mobile device, we automatically collect limited diagnostic and technical information about your device (“Diagnostic Information”). We set out below the information that we collect regarding your usage of the App and the devices that you access the App from:

 
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3.4 Payment Information

To best protect your data, we only use payment processors that are PCI Compliant. Airlock does not store any payment information, but can securely log in and view the following information via our payment processors, Stripe and PayPal. 

 
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3.5 Optional Services

We may offer optional services to you from time to time. If those optional services require the collection of any additional information about you, we will tell you at the time, setting out clearly what additional information is required, why it is required and how it will be used

Information Not Collected

Airlock values and respects your privacy, and we wanted to be explicit that we do NOT collect any other information from your device other than the information set out above. In particular, Airlock does not collect any of the following from your device (this is only a list of common examples, and does not set out all the information that we do not collect): 

  • Contacts (not collected)

  • Photos (not collected)

  • Videos (not collected)

  • Text messages (not collected)

  • Chat histories (not collected)

  • Emails sent and received (not collected)

  • Call history (not collected)

  • Browser history (not collected)

  • Location (not collected)

  • Fingerprint data (not collected)


4.0 USE OF YOUR PERSONAL INFORMATION

Airlock uses your App ID, Privacy Profile, Diagnostic Information and Payment Information to:

  • provide and deliver the Services and features you request; 

  • send technical notices, updates, security alerts and support and administrative messages; 

  • product improvement purposes

  • provide customer service and support; and

  • prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities


5. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

Airlock processes and stores its data, including Personal Information, on servers located in Canada and the United States. 

By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada and the United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the U.S. under lawful access regimes or court order.

6. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

6.1 Service Providers and Business Partners

We may from time to time employ third parties to perform tasks on our behalf and we may need to share Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is strictly necessary for them to provide the tasks and services on our behalf. The list of third parties that we currently engage is as follows:

 
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6.2 Business Transfers

If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

6.3 With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will ask for your consent before doing so.

6.4 As required by law

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other end users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any Personal Information as we reasonably believe is necessary to satisfy any applicable law, regulation, legal process or governmental request; enforce our contracts or user agreement, including investigation of potential violations hereof; and detect, prevent, or otherwise address fraud, security or technical issues. The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.

7. RETENTION AND DELETION

You can delete the Personal Information that we store relating to you at any time by sending us a message through the App with the title “Delete My Information”, subject to the limitations below. We will endeavor to deal with all requests for access and modifications within 15 business days. This will however reduce the ability of the Services to provide you with tailored recommendations regarding your privacy. You can also terminate your account with us at any time by sending us an email through the App with the title “Terminate My Account”. We will keep your Personal Information until the date of termination of your account, unless a longer period is required by law or you request that we delete it sooner.  If you remove the App from your device without terminating your account and where you have not submitted your email address, we may not be able to retrieve any of your earlier Personal Information. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. Where we no longer need certain Personal Information, we may delete it without telling you, as our policy is to keep as little information about you as is reasonably possible. 

8. ACCESS, CORRECTION AND ACCURACY

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances, we will provide reasons for any data that we are unable to share. We will endeavor to deal with all requests for access and modifications within 15 business days.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. 

9. RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”)

Airlock generally processes Personal Information in order to fulfill contract we have with You (that is, by providing you with our services) and to pursue our legitimate business interests. Otherwise, Airlock will obtain consent from an individual in respect of processing of Personal Information if required by law to do so.

Further, individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. If You are located in to the EEA and wish to exercise these rights, you should contact Airlock using the contact information below in Section 11. 

10. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. If we make any changes to the Personal Information that we collect, or the way we use your Personal Information, we will notify you prior to the change becoming effective via a notification in the App and/or by sending you an email (if you’ve shared your email with us). You are bound by any changes to the Privacy Policy when you use the Services after such changes have been first emailed or, if later, the effective date stated in the email.

11. CONTACT DETAILS

Questions regarding this Privacy Policy, Airlock’s privacy practices or your Personal Information should be directed to our Privacy Officer:

Digitally to: Privacy_Requests@tryairlock.com; or

By Paper to: Privacy Officer

Orchard Labs Inc.

814 Mission St, 6th Floor

San Francisco, CA

94103