Privacy Policy

This Privacy Policy explains how Donut Apps Pte. Ltd., a Singapore company (“we”, “us”, “our”) handles Personal Information collected through the Padlock application (the “Application” or “Service”).

We are committed to protecting and respecting your privacy. This Privacy Policy describes how we collect, process, retain, and share the Personal Information of users and other individuals in connection with the Application.

If you use our Service you agree to the collection and use of Personal Information as described in this Policy. The Personal Information that we collect is used for providing and improving the Service. We will not share your information with anyone except as described in this Privacy Policy. If you do not agree with this Policy, you should not use our Service.

What Information Is Collected

While using the Application we may collect the following information about you:

Information you provide:

• Account/Profile – In order to create, verify, and manage your account we collect your name, email address, and phone number.
• Contacts – If you choose to send alerts to pre-selected contacts we will access and collect information from your contact list including names, phone numbers, email addresses, and contact profile images.
• User-Generated Content – If you choose to have the Application send images with alert messages we will collect photos using the device camera.
• Correspondence – This refers to information you send to us, including when you contact us for support or feedback.

Information collected automatically:

To support the functionality of the Application, improve your experience, optimize services, and support the other purposes for which we collect information, we or our third-party service providers may automatically collect the following information about you or your device:

• Usage Information – We collect information regarding your use of the Application including which features are utilized, duration of usage, and Application settings.
• Device Data – We collect certain information about the device running the Application such as device make, device model, operating system information, language settings, unique identifiers (including identifiers used for advertising purposes).
• Technical Information – We collect certain information about the device you use to access the Service such as IP address, mobile carrier, time zone settings, network type, device IDs, screen resolution, audio settings, and connected devices.
• Location – We collect information about your approximate location including location information based on your SIM card and/or IP address. With your permission we also collect precise location (such as GPS).

How and why we use your information:

We use the Personal Information we collect for various purposes, primarily to provide you with the Services of the Application but also to develop, maintain, and improve the Service as well as enforce our End User License Agreement (EULA). We generally use your Personal Information in the following ways:

• Create and Manage Your Account – We use your Personal Information to create and maintain your user account associated with the Service including the verification of the provided account information and for providing security functionality (e.g. sending security codes via SMS).
• Security Alerts – The Application is designed to send security alerts in the form of SMS and Email messages to pre-selected contacts when specific user-selected events occur (phone moved, unplugged, etc.). If enabled, those messages may include Personal Information collected from the device to include the user’s provided name and, consistent with enabled permissions, device location and a photo taken from the camera at the time the alerting event occurs.
• Improve, Optimize, Troubleshoot the Service – We may use device specific information to improve and develop our Application, to understand how you use the Application, to conduct troubleshooting, data analysis, testing, and research, and to solicit feedback from users.
• Fraud Prevention and Security – We use Personal Information collected to detect and combat abuse, harmful activity, fraud, spam, and other illegal activity that occurs through the use of the Application and Service. Additionally, we use the information collected to enforce our End User License Agreement.
• Compliance and Legal Obligations – We will share your information with law enforcement agencies, public authorities, or other organizations if legally required to do so or if such use is necessary to:
  • Comply with a legal obligation.
  • Enforce End User License Agreement.
  • Detect, prevent, or otherwise address fraud.
  • Protect the rights and safety of us, our users, or a third party, as required or permitted by law.

Disclosure of Information

We do not share your information with third parties, except where required in order to support the functionality of the Service (e.g. SMS, Email providers) or if we are instructed to do so by a court or authority, or are otherwise compelled by law.

We may disclose your information to third parties for the following reasons:

• User-Selected Contacts – If you choose to have alerts sent to your selected contacts (via SMS or Email), those alerts, consistent with selected Application permissions, may include your name, device location, and/or a photo taken at the time the alerting event occurs.
• Service Providers – We utilize third-party service providers (e.g. Twilio, ClickSend) in order to send SMS and Email alerts to your selected contacts. Personal Information is securely transmitted to these service providers via encrypted means (e.g. https) but is ultimately sent to your contact via either SMS or Email, neither of which are inherently secure.
• Data Analytics – We may share your data with third-party analytics companies (e.g. PostHog) for the purpose of monitoring and measuring your use of the Application as well as understanding Application and Service performance in order to improve and/or optimize the Service we offer.
• Professional Advisors, Authorities, Regulators – We may share your information with our professional advisors (e.g. our lawyers) in response to legal processes (e.g. responding to subpoenas or other requests from law enforcement agencies), in order to enforce our agreements or policies, to protect the rights of us or our users, to detect, prevent, and address actual or suspected fraud, other illegal activities, or security issues, or when it is required by law.

Third-Party Services

As described above, the Application does use select third-party services that may collect information used to identify you. The privacy policies of those third-party services are provided here:

https://posthog.com/privacy

https://www.twilio.com/en-us/privacy

https://www.clicksend.com/en/legal/privacy-policy/

Data Security and Retention

We take steps to ensure that your information is treated securely and in accordance with this Policy. Although we will use reasonable measures to protect your Personal Information (e.g. through encryption) we cannot guarantee the security of your information via the Application. Any transmission of data is at your own risk.

We retain information as long as necessary to provide the Service and for the purposes outlined in this Policy. We also retain data when necessary to comply with legal or contractual obligations.

You may request we delete your account and associated data through the Application or by submitting a request on this page: https://www.mypadlock.app/#manage_account_en.

Changes to This Privacy Policy

We reserve the right to modify this Policy at any time. We encourage you to review this Policy frequently for any changes. Your continued use of the Application after any modifications to this Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Policy.

Contact

If you have any questions about this Policy, you may email us at support@mypadlock.app.

Qingdao Cyanor Innov Co., Ltd. (青岛青橙创新信息科技有限公司) is the distribution service provider for “Padlock” Android App in China.

END USER LICENSE AGREEMENT

This End User License Agreement is a legal agreement between you and Donut Apps Pte. Ltd. regarding your use of Padlock. By downloading, installing, or using the Application, you agree to be bound by the terms of this Agreement.

By downloading, installing, and using the application you (1) acknowledge that you have read and understood this agreement; (2) represent that you are of legal age to enter into a binding agreement; and (3) accept this agreement and agree that you are legally bound by its terms. If you do not agree to these terms, do not download, install, or use the application.

1. License Grant. Subject to the terms of this Agreement, Donut Apps Pte. Ltd. grants you a limited, non-exclusive, and nontransferable license to download, install, and use the application for your personal use.
2. License Restrictions. You may not:
   1. Modify, adapt, translate, reverse engineer, decompile, disassemble, or create derivative works based on the Application;
   2. Use the Application for any purpose that is illegal or prohibited by this Agreement;
   3. Remove, alter, or obscure any proprietary notices (including copyright and trademark notices) of the Company or its licensors;
   4. Use the Application in any way that could damage, disable, overburden, or impair the Company's servers or networks;
   5. Use the Application to violate the security of any computer network, crack passwords, or security encryption codes;
   6. Circumvent, disable, or otherwise interfere with security-related features of the Application;
   7. Use the Application in any manner that could interfere with any other party's use and enjoyment of the Application.
3. Intellectual Property. You acknowledge that the Application contains proprietary information and material that is owned by the Company and/or its licensors and is protected by applicable intellectual property and other laws, including but not limited to copyright. You agree that you will not use such proprietary information or materials in any way whatsoever except for use of the Application in compliance with this Agreement.
4. Privacy. Use of the Application is governed by our Privacy Policy.
5. Termination. The Company may terminate this Agreement at any time without notice if you fail to comply with any of its terms.
6. Disclaimer of Warranty: The Application is provided "as is" without warranty of any kind. The Company makes no warranties, express or implied, regarding the Application or its operation.
7. In no event shall Donut Apps Pte. Ltd. be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the Application.
8. Changes to Agreement: Donut Apps Pte. Ltd. reserves the right to update or modify this Agreement at any time without prior notice. Your continued use of the Application after any such changes constitutes your acceptance of the new Agreement.

By downloading, installing, or using the Application, you acknowledge that you have read this Agreement, understand it, and agree to be bound by its terms and conditions.