Privacy Policy

1.1

This Privacy Policy (the Policy) sets out the rules for the processing of personal data of individuals using the "Unlocks" mobile application (the App) and describes the main principles of such processing.

1.2

The data controller is LIMITED LIABILITY COMPANY "UNLOX", EDRPOU code 45873686, registered address: 11b Lemkivska Street, Lviv, 79019, Ukraine (the Company).

1.3

This Policy applies to the processing of personal data carried out by the Company in connection with the use of the App on devices running iOS and Android, regardless of the User's country of residence.

1.4

Personal data are processed in accordance with the data protection laws of Ukraine and, where applicable to a particular User, with the EU General Data Protection Regulation (Regulation (EU) 2016/679, GDPR).

1.5

In this Policy, the terms "personal data", "processing", "controller" and other terms are used as defined in the applicable legislation.

1.6

By installing and/or using the App, the User is deemed to have read this Policy. Where the law requires separate consent for certain types of processing, such consent is requested via the App interface or device settings.

1.7

For the purposes of this Policy, a User means any natural person with legal capacity who installs and/or uses the App.

2.1

When the App is used, personal data and other information relating to the device, settings and use of the App may be processed. The list below is general, and the actual scope of data depends on the device settings, operating system and the User's choices.

2.2 Device and technical data

The following device and technical data may be processed:

• Device model, operating system version, system language and region;
• Technical device identifiers (including the device advertising identifier where its use is allowed by the device settings);
• Information about the App version, App settings, performance and stability data.

2.3 Installed apps and blocking data

Information related to app functionality and blocking:

• Information about the apps installed on the device to the extent necessary to enable the blocking functionality;
• Data on the apps that have been blocked using the App and the periods for which such blocking was applied;
• The User's internal settings relating to focus modes, lists of apps subject to blocking and related parameters.

2.4 App usage data

Information about how the App is used:

• Information about focus sessions (start time, duration and end time);
• Usage statistics (number of sessions, number of interruptions and similar metrics);
• Event logs, technical logs, and information about App crashes and errors (crash reports).

2.5 Advertising and analytics data

Data collected for advertising and analytics purposes:

• Device advertising identifiers;
• Information on ad impressions in the App and interactions with ads;
• Analytics events related to the use of the App, collected via third-party advertising and analytics tools (SDKs).

2.6 Communication data

Data collected when you contact us:

• E-mail address and other contact details where the User contacts the Company regarding the App or the exercise of their rights;
• The content of the communication and any other information voluntarily provided by the User in their message.

2.7

The Company does not intend to collect and does not require for the operation of the App any special categories of personal data (such as data concerning health, biometric or genetic data, data on political opinions, religious or other beliefs) and does not access the content of messages, files or other information processed within the blocked apps.

3.1

The personal data and other information described in this Policy are processed only for specific, explicit and legitimate purposes. Data are not processed in a manner incompatible with such purposes.

3.2 Ensuring the operation of the App and its core functionality

Personal data are processed in order to:

• Ensure the operation of the App on the User's device, including implementing the app blocking and focus modes;
• Store and apply the User's individual settings related to the use of the App;
• Generate basic usage statistics necessary for correctly displaying the results of the App's operation to the User (for example, duration and number of focus sessions).

The legal basis for such processing is the necessity to enable the use of the App and the Company's legitimate interest in providing Users with a stable and functional product.

3.3 Maintenance, improvement and security of the App

Personal data may be processed for the purposes of:

• Analysing the performance of the App and detecting and fixing errors, malfunctions and vulnerabilities;
• Ensuring information security, preventing abuse and unauthorised access;
• Planning and implementing changes to the App's functionality based on aggregated usage statistics.

The legal basis for such processing is the Company's legitimate interest in maintaining an appropriate level of quality, security and stability of the App.

3.4 Advertising and analytics

Personal data may be processed in order to:

• Display advertising in the App, including taking into account device advertising identifiers and general patterns of App usage;
• Measure the effectiveness of advertising campaigns and maintain statistics on ad impressions and interactions;
• Carry out analytics on the use of the App (including by means of third-party tools such as Google Ads / AdMob, Google Analytics / Firebase and similar services).

The legal basis for such processing is the Company's legitimate interest in financing, developing and promoting the App. In jurisdictions where the law requires obtaining separate consent for the use of certain advertising and analytics tools (in particular for personalised advertising or specific types of tracking), the processing of the relevant data is based on the User's consent. Such consent may be granted or withdrawn via the App settings or the device's privacy settings, unless otherwise specified in the interface.

3.5 Communication with Users and handling requests

Personal data are processed in order to:

• Review Users' requests, provide responses and technical support;
• Handle requests relating to the exercise of data subject rights;
• Document the Company's compliance with data protection legislation.

The legal basis for such processing is the fulfilment of the Company's obligations as a data controller under applicable law and the Company's legitimate interest in ensuring proper communication with Users.

3.6 Compliance with legal obligations and protection of rights

Personal data may be processed for the purposes of:

• Complying with legal obligations imposed on the Company (including obligations in the fields of accounting, reporting and responding to lawful requests from public authorities);
• Protecting the Company's rights and legitimate interests in the event of disputes, claims or proceedings, including court proceedings.

The legal basis for such processing is the fulfilment of the Company's legal obligations and/or the protection of its rights and legitimate interests.

3.7

The Company does not engage in decision-making based solely on automated processing of personal data which produces legal effects concerning the User or similarly significantly affects the User, unless such processing is carried out in compliance with applicable law and accompanied by the safeguards required by law.

4.1

Personal data may be disclosed or made available to third parties only to the extent necessary to achieve the purposes set out in this Policy. The Company does not sell personal data to third parties.

4.2

Personal data may be shared with the following categories of recipients:

• Providers of cloud infrastructure, servers and tools for data storage and processing that ensure the functioning of the App;
• Providers of web and mobile analytics, crash reporting and measurement tools (including services within the Google group such as Google Analytics / Firebase, Google Ads / AdMob and similar solutions);
• Providers of advertising services and partner advertising networks (including services within the Google and Meta groups, such as their respective advertising platforms);
• Providers of technical, legal or other professional support services, acting as processors on behalf of the Company or as separate controllers;
• Public authorities and other public bodies where required by applicable law and to the extent prescribed by such law.

4.3

Depending on the specific service, certain third parties may act as data processors on behalf of the Company (for example, particular infrastructure providers) or as independent controllers (including Google, Meta and other major technology companies that determine the purposes and means of processing within their services). In such cases, the processing of personal data is also governed by the respective third party privacy policies.

4.4

As some of the above-mentioned service providers belong to international corporate groups, the processing of personal data may involve transfers outside Ukraine and/or the European Union, including to countries that do not provide a level of data protection recognised as adequate by the EU.

4.5

In cases of international transfers of personal data, the Company implements appropriate safeguards to ensure an adequate level of protection, in particular by:

• Using the European Union Standard Contractual Clauses within agreements with relevant service providers;
• Relying on other transfer mechanisms and safeguards provided for by applicable law, where relevant to a specific transfer.

4.6

To the extent permitted by law, the Company seeks to limit third-party access to personal data as far as reasonably possible and to share only the amount of information necessary to perform the relevant functions or provide the services.

5.1

Personal data are retained no longer than is necessary for the purposes for which such data were collected and processed in accordance with this Policy.

5.2

Technical logs, usage statistics, analytics data and related information are generally retained for a period of up to twelve (12) months from the date of collection and are then deleted or anonymised.

5.3

Data relating to the display of advertising and the measurement of its effectiveness are retained for as long as necessary to carry out the relevant advertising and analytics operations, but no longer than is reasonably required in view of the purposes of processing and the User's privacy settings in the App and/or on the device.

5.4

Information provided by the User in communications (e-mails or other messages) is retained for the period necessary to handle the request, provide a response and ensure the proper operation of support services, after which it may be deleted or archived in an anonymised or aggregated form.

5.5

Where personal data are no longer needed for any of the purposes described in this Policy, the Company takes steps to delete or anonymise such data within a reasonable time.

5.6

The User has the right to submit a request for the deletion of their personal data in accordance with this Policy. Within ten (10) days from the date of receipt of such request, the Company, provided that it is able to identify the User and link the request to the relevant data, deletes such personal data or fully anonymises them.

6.1

The User has the following rights in relation to their personal data processed in connection with the use of the App:

• The right to submit a request for the deletion of their personal data in accordance with this Policy;
• The right to withdraw their consent to the processing of personal data at any time (where processing is based on consent);
• The right to lodge a complaint with a competent data protection authority.

6.2

To exercise these rights, the User may contact the Company:

• By e-mail at: —
• By post at the Company's registered address: 11b Lemkivska Street, Lviv, 79019, Ukraine (LLC "UNLOX").

6.3

The Company handles Users' requests without undue delay and, as a rule, within ten (10) days from the date of receipt of the request. If additional information is required from the User (in particular to identify the User or clarify the scope of the request), the response period may be extended for the time necessary to obtain such information, and the User is informed of this in a clear manner.

6.4

After personal data are deleted on the basis of a User's request, the Company may retain anonymised statistical and analytical data that do not contain personal data and do not allow the User to be identified.

7.1

The Company implements necessary and reasonable technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. Such measures include, in particular, restricting access to data for employees and contractors on a need-to-know basis, using appropriate information security tools and regularly reviewing security practices.

7.2

Access to personal data is granted only to those persons who need it to perform their functions and who are subject to confidentiality and other information protection obligations.

7.3

Despite the measures taken, no security system can guarantee absolute protection of information. The User acknowledges that data transmission over the Internet and the storage of information on electronic media involve certain risks, and the Company can only guarantee a reasonably expected level of security.

7.4

The User is responsible for taking appropriate measures to protect their device and information, including keeping software up to date, configuring operating system security settings and limiting third-party access to their device.

8.1

The App is not specifically designed for use by children and is not directed at individuals who have not reached the age at which they can lawfully provide consent to the processing of personal data on their own.

8.2

The Company does not intend to knowingly collect personal data of such individuals. If the Company becomes aware that a child's personal data have been collected via the App, it will delete or fully anonymise such data within a reasonable time after receiving that information.

9.1

This Policy may be updated from time to time. The updated version takes effect from the moment it is made available in the App, unless expressly stated otherwise in the text of the relevant version.

9.2

The current version of the Policy is always available in the App. Users are encouraged to review the Policy periodically.

9.3

In the event of material changes to the Policy, the App may display a notice inviting the User to review the updated version and confirm their acceptance of its terms before continuing to use the App. Continued use of the App after such acceptance constitutes the User's agreement to the updated terms of the Policy.