Welcome to Aksh Agency Private Limited (“we”, “our”, “us”) have a product named Phone Locker. We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (“App”). Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
We may collect and process the following types of information:
This includes any information that can be used to identify you, such as your name, email address, phone number, or other contact information. We may collect this information when you register or use the App.
We may collect information about your device, including the device model, operating system, unique device identifiers, IP address, and mobile network information.
If you permit the App to access location services, we may collect information about your precise or approximate location. You can manage location permissions in your device settings.
We use the information we collect, including location and IMEI data, for various purposes to enhance your experience with our App. Below is a detailed explanation of how we use this data:
Location data is collected to help track and recover your device if it is lost or stolen, or to track other devices associated with your account. This information is collected when the app is uninstalled or upon request for customer tracking purposes.
We collect location data only with your explicit consent, which you provide when you install or use the app. You can manage or revoke this permission at any time through your device settings.
Location data is securely stored on Google Cloud with encryption and restricted access to ensure it is protected from unauthorised access or disclosure.
The IMEI number is used as an additional verification layer for users with multiple devices. This helps ensure secure access and manage devices linked to your account.
We collect and use the IMEI number with your explicit consent, obtained during device setup or registration.
The IMEI number is securely stored on Google Cloud with encryption and limited access to prevent unauthorised use.
We use SMS to send verification codes, notifications, and updates related to the app, including One-Time Passwords (OTPs) and important alerts. This service is used only to the extent you have consented to receive such communications.
While SMS transmission itself is not encrypted, we ensure that any sensitive data related to SMS services is handled securely and in compliance with applicable privacy laws.
The user will receive an SMS containing a One-Time Password (OTP) solely for registration purposes.
The security of your personal data is a top priority for us. We adhere to widely recognized standards to protect the personal data you provide, both during transmission and after it is received.
If you have any questions about how we secure your personal data, please feel free to contact us at akshagency@gmail.com
Except as outlined in the "Disclosure of Your Data" section below, we do not share your personal data with any third party without your explicit consent, in accordance with applicable law. Aksh Agency implements technical, administrative, and physical safeguards to protect your personal information against unauthorised access, destruction, loss, alteration, misuse, or disclosure.
Access to your personal information is restricted to a select number of personnel who require it to perform their duties.However, please be aware that no method of transmission over the Internet or method of electronic storage is completely secure.
Aksh Agency collects information in a few ways. We collect information directly from you when you provide it to us, such as through filling out forms. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone.
This software may record data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
We store your personal data on secure servers located in [Specify Location, e.g., the United States, the European Union, etc.], as well as in cloud-based environments provided by trusted service providers. These storage locations are chosen to comply with applicable data protection laws and to ensure the highest levels of security for your information.
Access to your personal data is strictly limited to administrators who need it to perform their job duties. These individuals are subject to strict confidentiality obligations and undergo regular training on data protection best practices.
We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Once your data is no longer needed, we securely delete or anonymize it to ensure that it cannot be used to identify you.
As you may know, a European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights.
As required under applicable law, the rights afforded to you are:
(i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain
(ii) access to such data and a copy thereof.
You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Upon request, Aksh Agency will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Aksh Agency may have legal or legitimate grounds for keeping such data.
In a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from us.
This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
Aksh Agency may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your Aksh Agency account.
A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give akshagency@gmail.com instructions concerning the use of your personal data after your death.
To exercise one or more of these rights, you can email akshagency@gmail.com You may access your personal data to modify or update at any time via an online account, or by emailing akshagency@gmail.com We will respond to your request in a reasonable timeframe in accordance with applicable law.
Under the General Data Protection Regulation (GDPR), we collect personal data based on your consent and for specific purposes as outlined in our Privacy Policy. However, we do not process this data beyond its collection nor share it with any third parties. Your personal information is securely stored but remains unprocessed and confidential. We ensure that it is not disclosed or utilised outside the scope of its initial collection, thereby maintaining your privacy and security.
We do not share your personal information with third parties except in the following circumstances:
We may share your information with third parties when you provide explicit consent to do so.
We may disclose your information if required by law or in response to legal processes, such as a court order or subpoena.
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing akshagency@gmail.com
Our app does not include links to third-party websites.
Our Products on the web include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.
Our app is intended exclusively for adults aged 18 years and older. It is not designed for or directed towards children. We do not knowingly collect, use, or process any personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a child under 18, we will take immediate steps to delete such information from our records.
We may update this Privacy Policy from time to time. We will notify you of any changes by updating the “Effective Date” at the top of this policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
This California Consumer Privacy Act (“CCPA”) Addendum for California residents supplements the information contained in the above Privacy Policy and applies solely to all visitors, users and others who reside in the State of California.
We adopt this CCPA Addendum to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Addendum.
Our Products collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device, whether collected online or offline (“personal information”).
In particular, the Products have collected the following categories of personal information from consumers within the last twelve (12) months: CATEGORY EXAMPLES COLLECTED
Identifiers First and last name, email address, Internet Protocol address, online identifiers.
● Yes Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). First and last name.
● Yes Internet or other similar network activity. Browsing history or information on a consumer’s interaction with the Products or our advertisements on third-party platforms.
● Yes The specific types of personal information we collect are described more fully in section 1 of the Privacy Policy.
Personal information does not include:
(1) de identified or aggregated consumer information;
(2) publicly available information from government records; or
(3) information excluded from the CCPA’s scope. We obtain the categories of personal information listed above from the following categories of sources:
● Directly from you.For example, from forms you complete when registering for the Products.
● Indirectly from you. For example, from observing your actions on our Products.
● Directly from Partners associated with your Community, if you have a Community Subscription that is authenticated through the Community’s use of eligibility files as described in section 6 of the Privacy Policy.
We may use or disclose the personal information we collect for the purposes described in section 9 of the Privacy Policy.
We may disclose your personal information to third parties for specific business purposes. This includes sharing data necessary to provide SMS services. Additionally, we may share a limited set of data, such as cookies and pixels collected from your visits to our websites, with third parties to display tailored digital advertisements. For more details on how we use cookies and similar technologies, please refer to Section 4 of our Privacy Policy.
If the sharing of data for online advertising is considered a "sale" under California’s broad definition, you have the option to opt out using the tools described in Section 5 of this CCPA Notice. However, we do not sell your personal information to third parties.
For specific examples of our data sharing practices, please see sections 6 and 11 of our Privacy Policy.
Access to Specific Information and Data Portability Rights
The CCPA provides consumers (California residents) with specific rights regarding their personal information.
This section describes your CCPA rights and explains how to exercise those rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
Once we receive and confirm your verifiable consumer request, we will disclose to you:
● The categories of personal information we collected about you.
● The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
● The categories of third parties with whom we share that personal information.
● The categories of personal information we share with third parties.
● The specific pieces of personal information we collected about you (also called a data portability request).
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will permanently and irrevocably anonymize your personal information, unless an exception applies.
We may deny your deletion request if certain CCPA exemption apply, including but not limited to, if retaining the information is necessary for us or our service provider(s) to:
● Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
● Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
● Debug products to identify and repair errors that impair existing intended functionality.
● Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
● Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. Comply with a legal obligation.
● Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
● Exercising Access, Data Portability, and Deletion Rights to exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at akshagency@gmail.com
Only you, or someone legally authorised to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
The verifiable consumer request must:
● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorised representative.
● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
● We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
● We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
● Upon receiving a request for access, portability, or deletion, we will confirm receipt of the request within 10 business days and provide information about our verification process and how we will process the request.
● We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt.
● If we require more time, we will inform you of the reason and extension period in writing.
● We will deliver our written response to the email address associated with the account for account holders, and to the email address provided with the request submission for non-account holders.
● Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.
● The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your personal information that is readily readable and usable.We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
● We do NOT use cookies so that third parties can serve ads to you about their own products or services.
● We do NOT sell or rent your personal information to any third parties for their own advertising or marketing purposes.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
● Deny you goods or services.
● Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
● Provide you a different level or quality of goods or services.
● Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.
Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
We reserve the right to amend this CCPA at our discretion and at any time. When we make changes to this CCPA, we will post the updated notice on the Website and update the effective date.
Your continued use of our Products following the posting of changes constitutes your acceptance of such changes.
You can review and change your personal information by logging into the Website and visiting your account profile page. You may also send us an email at akshagency@gmail.com to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Proper access and use of information provided on the Website is governed by our Terms & Conditions, at web.phonelocker.co.in
We have implemented measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential.
● We ask you not to share your password with anyone.
● We urge you to be careful about giving out information in public areas of the Website like message boards.The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.
We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
If you have any questions about this Privacy Policy or our data practices, please contact us at: