NetLok™ Privacy Policy

Effective March 12, 2016

At No Password, Inc., a California Corporation doing business as NetLok™ ("NetLok"), we are driven by our mission to provide a more secure connected world. We understand that when you provide personal data to NetLok™, you place your trust in us. We take this trust very seriously and are committed to respecting your privacy and protecting the personal data we handle with strong encryption and strict policies.

This Privacy Policy describes the types of information we collect via the NetLok website and the services we provide on and through this website (the "Site") located at www.netlok.com (such website, the "Website"; such services, the "Services"), as set out below, how we may use that information, and with whom we may share it. This Privacy Policy also describes the measures we take to protect the security of the information. We also tell you how you may contact us to update your information, remove your name from our mailing lists, or get answers to questions you may have about our privacy practices. This Privacy Policy is only applicable to the Services, and not to any other websites that you may be able to access from the Services, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.

1. COLLECTION AND USE OF PERSONAL INFORMATION

Personal information is data that can be used to identify or contact a single person.  Personal information is not the information that is stored in the Docs, Addresses and/or Messages sections of the NetLokrtm.  Only you are responsible for the contents of Docs, Addresses and Messages contained in your NetLokr.  NetLok does not have access to the contents stored in the Docs, Addresses and/or Messages sections your have in your NetLokr.

You may be asked to provide your Personal Information anytime you are in contact with NetLok™. NetLok may share this personal information with its affiliates, and NetLok™ and its affiliates may use it consistent with this Privacy Policy. NetLok™ and its affiliates may also combine your personal information with other information to provide and improve our products, services, and content.

You are not required to provide the personal information that we may request, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information NetLok™ may collect and how we may use it:

What Personal Information we collect

  • To access certain Services, you may be required to open a NetLok™ account ("Account") by completing a registration form, accepting certain terms of service, providing an Email Address, and one or more personal photos that will be encrypted in a "NetLok™ Photo IDs". You may have either an Account created by you for your personal use (a "Personal Account"), an Account created in connection with a small group you become a member of (a "Family Account"), or an Account created in connection with your employer or other entity with whom your Account is associated (a "Company", and a "Company Account"), or all of the preceding.
  • When you open a NetLok™ Account, purchase a product or service, download a software update, subscribe to our email list, contact us or participate in an online survery, we may collect a variety of information, including your name, email address, contact preferences, and credit card information.
  • When you use NetLok products or services to securely and privately share your content or information or otherwise communicate with a limited audience, NetLok may collect the personal information you provide about those people, such as name, mailing address, email address, and phone number. NetLok™ will use such information to fulfill your requests, provide the relevant product or service, or for anti-fraud purposes.  Neither No Password, Inc, dba NetLok nor its employees have access to the contents of your NetLokr.
  • We may ask for a government issued ID in limited circumstances including when setting up a NetLok™ Account and activating your service, or as required by law.

How we use your Personal Information

  • We do not sell your Personal Information.
  • If you communicate with us through the "Contact Us" or the "Email" links on the Site, we use the Personal Information you may provide to respond to your questions and comments.
  • If you subscribe to our e-mail list through the "Sign Up" or "Subscribe" links on the Site, we use the Personal Information you provide us to send you information about our products and services, newsletters, informative emails, and discounts which may be of interest to you. At any time, you can opt-out from receiving these communications by following the "unsubscribe" directions in the body of the email.
  • We also use Personal Information to help us create, develop, operate, deliver, and improve our products, services, and content, and for loss prevention and anti-fraud purposes.
  • We may use your Personal Information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of NetLok™ account holders.
  • From time to time, we may use your Personal Information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with NetLok™, you may not opt out of receiving these communications.
  • We may also use Personal Information for internal purposes such as auditing, data analysis, and research to improve NetLok™ products, services, and customer communications.
  • If you enter into a sweepstake, contest, or similar promotion, we may use the information you provide to administer those programs.

 

2. COLLECTION AND USE OF NON-PERSONAL INFORMATION

In some instances, NetLok™ may collect data in a form that does not, on its own, permit direct association with any specific individual ("Non-Personal Information"). This information is used to better understand and improve the usability, performance, and effectiveness of NetLok™'s website, products, and services. The following are some examples of Non-Personal Information that we collect and how we may use it:

  • We may collect and aggregate information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where a No Password product is used, without regard to a specific user so that we can better understand customer behavior and improve our products and services.
  • We may collect information regarding customer activities on the Site and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered Non Personal Information for the purposes of this Privacy Policy.
  • With your explicit consent, we may collect data about how you use No Password's products and services in order to improve those products and services.

 

If we do combine Non Personal Information with Personal Information the combined information will be treated as Personal Information for as long as it remains combined.

3. COOKIES AND OTHER TECHNOLOGIES

As is true of most Internet services, we use automatic data collection tools, such as cookies, embedded web links and web beacons. These tools automatically collect certain standard information that your browser sends to our website such as Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We may use this information to administer the Services, to learn about user behavior on and through the Services, and to improve the Services.

We may also use cookies and other technologies to remember personal information when you use the Services. Our goal in these cases is to make your experience with NetLok more convenient and personal. For example, knowing your contact information, hardware identifiers, and information about your computer or device helps us provide you with better customer service. To maximize your Account's security, we will always require you to manually enter your Email Address and NetLok™ Photo ID (your photographic password) at the point of login.

We treat information collected by cookies and other technologies as non personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

4. DISCLOSURE TO THIRD PARTIES

We share your personal information with authorized NetLok™ personnel and trusted third parties who are acting on our behalf in order to provide the services you request or to support our relationship with you. By providing your personal data, you consent to the sharing of your personal data as described in the preceding sentence. We do not share your personal information with third parties for their marketing purposes.

Service Providers
We share your personal information with authorized NetLok™ personnel and trusted third parties who are acting on our behalf in order to provide the services you request or to support our relationship with you. By providing your personal data, you consent to the sharing of your personal data as described in the preceding sentence. We do not share your personal information with third parties for their marketing purposes.

Company
If you have a Company Account, we may share your personal information and/or non-personal information relating to your Company Account with your Company, solely in connection with the performance of the Services, as set forth in our agreement with the Company.

Others
It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence for NetLok™ to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions of use or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale, we may transfer any and all personal information we collect to the relevant third party.

5. PROTECTION OF PERSONAL INFORMATION

NetLok takes the security of your personal information extremely seriously.

When we solicit and collect personal information from you, when we store or transmit your personal information for administrative purposes, and when you store and transmit your personal information using and within our secure "Vault" service, we protect it using the our state-of-the-art, digital security and encryption technologies (including trade secret technologies), using encryption including Transport Layer Security (TLS) and Secure Sockets Layer (SSL), and also with our physical systems subject to limited access and housed in undisclosed and secured facilities.

We may take additional protective measures to protect your content, information, and communications stored or transmitted by means of the Services. Our obligations, if any, with regard to those protective measures are governed solely by the agreements pursuant to which the specific Services are provided, and nothing on this Website should be construed to alter such agreements.

To ensure that your personal information is secure, we communicate our privacy and security guidelines to NetLok employees and strictly enforce privacy safeguards within the company.

6. INTEGRITY AND RETENTION OF PERSONAL INFORMATION

We make it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

7. ACCESS TO PERSONAL INFORMATION

You have the right to update, correct, or remove your personal information. You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging into your Account at www.netlok.com. Access, correction, or deletion requests can be made through the Contact Us address [email protected] or Email Us at [email protected] provided through the Services, or through the other communication channels indicated at the bottom of this Privacy Policy. If requested, and to the extent permissible by applicable law relating to the retention of records or otherwise not required for valid business purposes, you may request that we use our best efforts to remove such data from our repositories. We will respond to your requests within 30 days.

8. CHILDREN

It is not our intent to collect personal data from children under the age of 13. The Site is not designed to attract children, and we request that children under the age of 13 not submit personal data to us through the website. If we learn that we have collected the Personal Information of a child under 13 without first receiving verifiable parental consent, we will take steps to delete the information as soon as possible.

9. THIRD-PARTY SITES AND SERVICES

The Services may contain links to third-party websites, products, and services. These linked sites are not under our control, and we are not responsible for their content. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

10. TERMS OF USE

We have Terms of Use for users of our websites. For more information, please see our Terms of Use.

Please note that as a convenience to our website visitors, we sometimes provide links to other websites. These linked sites are not under the control of NetLok and we are not responsible for their content.

11. CHANGES TO PRIVACY POLICY

We reserve the right to revise this Privacy Policy from time to time. We will date and post the most current version of this Privacy Policy on this Website. Any changes will be effective immediately upon posting of the revised version. If in our sole discretion we deem a revision to this Privacy Policy to be material, we will notify you via the Services and/or by email to the email address associated with your Account.

12. CONTACT INFORMATION

If you have any questions or comments concerning this Privacy Policy, or if you would like to change your communication preferences, update or review the Personal Information we have about you, or withdraw your consent for the collection, use, or disclosure of your Personal Information, please contact us using one of the options below:
(a) By the Contact Us Form;
(b) By regular mail at: NetLok, PO Box 20250, Santa Barbara, CA 93120-0250; and
(c) By telephone at: (805) 283-4100.

Any feedback you provide shall be deemed to be non-confidential. NetLok™ shall be free to use such information on an unrestricted basis.

Effective on March 12, 2016.

The information contained in this website is subject to change without notice.
Copyright © 2016 No Password, Inc. dba NetLok.  All rights reserved.

 

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