This Policy describes the information that we gather from you on the Service, how we use and disclose such information, and the steps we take to protect such information. By using the Service, you consent to the privacy practices described in this Policy.

The information We Collect

• Information You Provide. You may provide us with information about you in various ways on the Service. For example, you may provide us with personal information when you register for the Service, download and install our mobile applications, make a purchase of the Service, or send us customer service-related requests. The information we collect may include your contact information such as name, email address, phone number and postal address. We may also collect registration and account details such as user name and password. If you purchase a product or service from us, we will also collect payment information, such as name, billing address and payment details.

Collection of Information by Automatic Means.When you use and interact with our Services, we obtain information by automated means, including through cookies, web server logs, web beacons, and other technologies.

• We may collect information through these means regarding customer activities on our website, and from our other products and services. The information we obtain may include language preference, device IP address, device characteristics, unique device identifier, referrer URL, GPS location (if you consent), and the time zone where Lockly applications are used.

• If you use our Lockly Smart Lock product, we collect technical information about your product, such as your wifi network information and your product’s model, serial number and software version.

• We may collect and store details of how you use our services, including search queries.

• With your consent, we may collect data about how you use Lockly applications in order to help app developers improve our apps.

Information from Other Sources. We may obtain information, including personal information, from third parties and sources other than the Service, such as our partners and advertisers. We may also obtain information from third-party social media services (e.g., Facebook) or payment services if you choose to link to, create or log into your Lockly account through these services (including when you share Lockly content via your social media account.

How we use the information we collect.

We use the information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:

• To operate, maintain, enhance and provide all features of the Services.

• To provide services and information that you request.

• To respond to comments and questions and otherwise to provide support to users.

• To process and fulfill claims and orders in connection with the Services.

• To identify and authenticate you so that you may use the Services.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To contact you for administrative purposes such as customer service or (ii) to send communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. Generally, you have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”

• We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Lockly applications, services, and customer communications.

When we disclose information.

Except as described in this Policy, we will not disclose your information that we collect on the Service to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances

• We work with third party service providers to provide the website, application development, hosting, maintenance, payment processing, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

• We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

• We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

• Information about our users may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Your Choices

You may decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your account information and preferences at any time by accessing your account preferences page on the Service. If you wish to access or amend any other personal information we hold about you, you may contact us at helpdesk@ncpgroup.co.nz. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained in the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending your request to us by email at sales@ncpgroup.co.nz or by writing to us at the address given at the end of this policy. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Service.

Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

Third-Party Services

The Service may contain features or links to Web sites and services provided by third parties for in-app purchase related matters. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Children’s Privacy

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Service at any time or in any manner. If we learn that personal information has been collected on the Service from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on the Service, then you may alert us at sales@ncpgroup.co.nz and request that we delete that child’s personal information from our systems.

Location-Based Services

To provide location-based services on Lockly applications, Lockly and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of when you use Lockly applications. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Lockly and our partners and licensees to provide and improve location-based services.

Some location-based services offered by Lockly, such as the“Catch Intruders” feature, require your personal information for the feature to work.

Data Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of personal data that we collect and maintain. When your personal data is stored by Lockly, we use computer systems with limited access housed in facilities using physical security measures. We cannot, however, ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

When you use share and post on Lockly applications or social networking services, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights and obligations, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made. Your continued use of the Services after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of the Policy.

Our Contact Information

Please contact us with any questions or comments about this Policy, your Personal Information, our use and disclosure practices, or your consent choices by email at sales@ncpgroup.co.nz

Lockly

Add: 36 Walls Road,Penrose,Auckland 0632

Tel: 0800 666866