Photos Not Passwords for Secure Login Authentication | Netlok

Photolok® is a highly secure passwordless authentication and access login using photos not passwords.

Privacy Policy

Effective February 7, 2022

Thank you for choosing to be a part of our community at Netlok, LLC (“Company”, “we”, “us”, or “our”).   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 protecting your personal information and your right to privacy.  If you have any questions or concerns about this Privacy Policy or our practices regarding your personal information, please contact us at [email protected].

This Privacy Policy describes how we might use your information if you:

  • Visit our website at netlok.com
  • Use Photolok®, Netlok’s image-based innovative identity and authentication software
  • Engage with us in other related ways – including any sales, marketing, or events

In this Privacy Policy, if we refer to:

  • “Website”, we are referring to any website of ours that references or links to this policy
  • “Services”, we are referring to our Website, and other related services, including any sales, marketing, or events
  • “Photolok”, we are referring to Netlok’s innovative image-based, identity and authentication software

The purpose of this Privacy Policy is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it.  If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services immediately and contact us to let us know your concern(s).

Please read this Privacy Policy carefully, as it will help you understand what we do with the information that we collect.

This policy contains:

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE USE YOUR INFORMATION?
  3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  5. HOW LONG DO WE KEEP YOUR INFORMATION?
  6. HOW DO WE KEEP YOUR INFORMATION SAFE?
  7. WHAT ARE YOUR PRIVACY RIGHTS?
  8. CONTROLS FOR DO-NOT-TRACK FEATURES?
  9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  10. DO WE MAKE UPDATES TO THIS NOTICE?
  11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
  12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

1. WHAT INFORMATION DO WE COLLECT?

Personal Information you disclose to us.

Summary: We collect personal information that you provide us.

“Personal information” is data that can be used to identify or contact a single person.  We collect personal information that you voluntarily provide us when you register to use Photolok, express an interest in obtaining information about us or our products and services, when you participate in activities on the Website or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us, the Website, use of Photolok, the choices you make, and the products and features you use.  The personal information we collect may include the following:

Personal Account Information Provided by You.  In creating your Photolok account, you will only be asked to provide and verify your first name, last name, text cell number, and email address.  These four pieces of personal information are generally available and, most commonly, appear on business cards.

Payment Data.  We may collect data necessary to process your payment if you sign on to services, such as your payment information number, and the security code associated with your payment instrument.  All payment data is stored by Netlok’s payment processor.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information Automatically Collected.

Summary:  Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Website or use Photolok.

We automatically collect certain information when you visit, use, or navigate the Website and use Photolok.  The information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, location, information about how and when you use our Website or Photolok and other technical information.  This information is primarily needed to maintain the security and operation of our Website and the Photolok service, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes log and usage information.  Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Website and the Photolok service and which we record in log files.  Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, information about your activity on the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information such as system activity, error reports, and hardware settings) and activity and interaction with Photolok services.

 

2. HOW DO WE USE YOUR INFORMATION?

Summary:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our obligations, and/or your consent.

We use personal information collected via our Website and the Photolok service for a variety of business purposes described below.  We process your personal information for the purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.  We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To facilitate account creation and logon process. If you choose to link your account with us to a third-party account, we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested services.
  • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of the Services.
  • To protect our services. We may use your information as part of our efforts to keep our Website, Photolok, and other products safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.
  • To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
  • Fulfill and manage orders. We may use information to fulfill and manage your registration and payments made through the Website or other registration processes.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • Request feedback. We may use your information to request feedback and to contact you about your use of our Website, Photolok, or any Netlok products.
  • To post testimonials. We post testimonials on our Website that may contain personal information.  Prior to posting testimonials, we will obtain your consent to use your name and the content of the testimonial.  If you wish to update, or delete your testimonial, please contact us at [email protected] and be sure to include your name, testimonial location, and contact information.
  • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, Photolok, other products, marketing, and your experience.  We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

We do not sell or give away your information.

  

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

Summary:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a contract. Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

  • Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

 

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Summary:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.  Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

 

5. HOW LONG DO WE KEEP YOUR INFORMATION?

Summary:  We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other requirements).  No purpose in this policy will require us keeping information longer than Sixty (60) Days past the termination of the user’s account unless the account is part of a Master Contract, whereby Netlok must abide by the terms and conditions of such contract.

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

Summary:  We aim to protect your personal information through a system of organizational and security measures.  It is your obligation to keep your photos protected and not share or show them with anyone.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process or maintain.  However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal or modify your information.  Although we will do our best to protect your personal information, transmission of personal information to and from our Website and Photolok program/app is at your own risk.  You should only access the Website and Photolok program/app within a secure environment.

It is critical, and a key part of the security system, and your obligation to keep the identity of your photos protected and ensure that they are not shared with or shown to anyone.

 

7. WHAT ARE YOUR PRIVACY RIGHTS?

Summary:  You may review, change, or terminate your account at any time.

If you a resident in the European Economic Area (EEA) or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.  You can find their contact details here:

https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

If you are a resident in Switzerland, the contact details for the data protection authorities are available here:

https://www.edoeb.admin.ch/edoeb/en/home.html .

If you have questions or comments about your privacy rights, you may email us at:

[email protected]   or  [email protected]

 

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you must contact us either at [email protected]   or  [email protected]

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases unless your account is part of a Master Contract.  In that case, we must contact the Master Contract Administrator to verify your request and obtain their approval. In addition, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies:  Most Web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.  If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website, Photolok, and other products and services.

Opting out of email marketing:  You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below.  You will then be removed from the marketing email list – however, we may still communicate with you, for example to end you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.  To otherwise opt-out, you may click the link at the bottom of the communication.

Opting out of alerts:  The Photolok Program/app includes a default setting that notifies you when someone has gained access to your account.  While this feature is an important security component of the program/app, you can choose to disable that function by going to your settings page and unclick the “Send Photolok Alert” box in the Security Alert Choices section in the upper left part of the page.

 

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized.  As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

 

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Summary:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.  If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provide below.

If you are under 18 years of age, reside in California, and have a registered account with Photolok, you have the right to request removal of unwanted data not critical to the operation of your account.  To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.  We will make sure the data is not publicly displayed, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).  Please send your requests to:

[email protected]   or  [email protected]

Note: If your account is operating under a Master Contract, we must inform the Master Contract Administrator before removing any data covered by the Master Contract.  You may want to contact your Master Contract Administrator before making your request.

 

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

  1. Every individual who is in the State of California for other than a temporary or transitory purpose, and
  2. Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as “non-residents”.

If this definition of “resident” applies to you, we must adhere to  certain rights and obligations regarding your personal information.

1. What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Information Collected? Type Collected
Personal information categories listed in the California Customer Records statute Name, contact information, education, employment history and financial information Yes Name, email address, security questions
Identifiers Contact details, such as real name, alias, postal address, telephone or mobile number, unique personal identifier Yes Mobile number, security questions
Audio, electronic, visual, thermal, olfactory, or similar info Images and audio, video or call recordings created in collection with our business activities Yes Images
Protected classification characteristics under California or federal law Gender and date of birth No None
Commercial Information Transaction information, purchase history, financial details and payment information No None
Biometric information Fingerprints and voiceprints No None
Internet or other similar network activity Browsing history, search history, online behavior, interest data, interactions with our and other websites, applications, systems and advertisements No None
Geolocation data Device location No None
Professional or employment-related information Business contact detail in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us No None
Education information Student records and directory information No None
Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics No None

 

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our services and to respond to your inquiries.

 

2. How do we use and share personal information?

More information about our data collection and sharing practices can be found in this Privacy Policy.

You may contact us by email at [email protected] , by calling  Anthony Perez at 805-717-9898, by visiting www.netlok.com or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to op-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.  If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.

3. Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider.  Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration.  This is not considered to be “selling” of your personal data.

Netlok, LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose since its founding.  Netlok, LLC will not sell personal information in the future belonging to Website visitors, users, and other consumers.
4. Your rights with respect to personal data.

Right to request deletion of the data – Request to delete

You can ask for the deletion of your personal information.  If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.

Right to be informed – Request to know

Depending on the circumstances, you have a right to know:

  • Whether we collect and use your personal information;
  • The categories of personal information that we collect;
  • The purposes for which the collected personal information is used;
  • Whether we sell your personal information to third parties;
  • The categories of personal information that we sold or disclosed for a business purpose;
  • The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • The business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to non-discrimination for the exercise of a consumer’s privacy rights.

We will not discriminate against you if you exercise your privacy rights.

Verification process.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system.  These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us.  For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us.  We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request.  To the extent possible, we will avoid requesting additional information from you for the purposes of verification.  If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purpose of verifying your identity, and for security or fraud-prevention purposes.  We will delete such additionally provided information as soon as we finish verifying you.

If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent to verify and provide information on your account as stated in the terms and conditions of the Master Contract.

Other privacy rights

  • You may object to the processing of your personal data
  • You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the data.
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
  • You may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
  • If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.

To exercise these rights, you can contact us by email at [email protected] , by calling Anthony Perez at 808-717-9898, by visiting www.netlok.com, or by referring to the contact details at the bottom of this document.  If you have any complaint about how we handle your data, we would like to hear from you.

 

10. DO WE MAKE UPDATES TO THIS POLICY?

Summary:  Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time.  The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.  If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.  We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

If your membership is part of a Master Contract, the Master Contract Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.

 

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, you may contact us by calling 408-909-9252, by email at [email protected], or by mail to:

Netlok, LLC
C/O Anthony Perez
1171 Crestline Drive
Santa Barbara, CA 93105
United States

 

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances.  To review, update, or delete your personal information, please send an email to: [email protected].

If your membership is part of a Master Contract, please contact the Master Contract Administrator first because the Administrator may act as an authorized agent and/or take action on your account as stated in the terms and conditions of the Master Contract.