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Privacy Policy - Locck

Last updated: 19 July 2026

This Privacy Policy describes how Torchingale (“Torchingale”, “we”, “us” or “our”) processes information in connection with the mobile application Locck (the “App”).

By downloading, accessing or using the App, you acknowledge that you have read and understood this Privacy Policy.

1. Data We Do Not Collect

The App does not require an account. We do not collect your name, email address, phone number, contacts, precise location, photos or any other directly identifying personal information.

2. Notes and User Content

All notes, reminders and related content you create in the App are stored locally on your device in encrypted form. Such content is not transmitted to, received by or accessible to Torchingale. We have no ability to read, recover or restore your content.

3. Information Processed by Third-Party Services

The App integrates the following third-party services, which may process limited technical data as independent or joint controllers under their own privacy policies:

  • Google Firebase Crashlytics — diagnostic and crash data, including device model, operating system version, application version and anonymous identifiers, used solely to detect and resolve technical faults.
  • RevenueCat — purchase and subscription status data, including anonymous user identifiers and transaction records supplied by the applicable app store, used solely to manage subscriptions and entitlements.
  • Apple App Store / Google Play — payment processing. Torchingale does not receive or store your payment card details.

Where applicable law (including the EU/UK General Data Protection Regulation) requires a legal basis, we rely on our legitimate interests in maintaining the stability, security and commercial operation of the App, and on the performance of our contract with you in respect of subscription management.

5. Data Retention

Locally stored content remains on your device until you delete it or uninstall the App. Diagnostic and subscription data are retained by the respective service providers for the periods set out in their own policies.

6. Permissions

The App may request device permissions, including notification and widget permissions, solely to deliver the features you enable. Permissions may be revoked at any time through your device settings.

7. Children

The App is not directed at children under the age of 13 (or the equivalent minimum age in your jurisdiction), and we do not knowingly process their personal data.

8. Your Rights

Subject to applicable law, you may have rights of access, rectification, erasure, restriction, objection and data portability. As we do not hold identifying information about you, requests concerning third-party services should be directed to the relevant provider. You may exercise your rights in relation to Torchingale by contacting us at the address below.

9. Changes

We may amend this Privacy Policy from time to time. Any amended version will be published within the App or on our website and takes effect upon publication.

10. Contact

Torchingale Email: [email protected]