Last Updated: 24.12.2025
We deeply value your privacy and are committed to protecting your personal information in line with industry-standard security practices. This Privacy Policy (the "Policy") aims to explain in clear and understandable terms how we collect, use, store, disclose, and protect your personal information when you use the "LockMemo - Secure Private Album" application (the "App").
Please read this Policy carefully before using the App. If you do not agree with any part of this Policy, you may not be able to use all features of the App and should discontinue use immediately. Your continued use of the App signifies your acceptance of this Policy.
We adhere to the principles of lawfulness, fairness, necessity, and data minimization. We only collect information necessary for specific, legitimate purposes related to providing our services.
Photos, Videos & Associated Metadata: When you grant the App permission to access your device's photo library, the photos and videos you actively choose to import or capture are processed locally. We access metadata (e.g., creation date, file size, format, and location data if you have granted location access to your photos) locally on your device to enable encryption, organization, and display. The original media files are by default stored only locally on your device and are not automatically uploaded to our servers.
App Access Credentials: The local access password you set and any biometric data (such as Face ID or Touch ID) used for quick unlocking. This highly sensitive information is processed and verified exclusively within your device's secure hardware enclave (e.g., Apple's Secure Enclave). We cannot access, upload, or store this data.
Basic Device Information: To ensure stable operation, provide basic anti-fraud functionality, and collect anonymized crash statistics, we may locally access your device model, operating system version, App version number, and anonymized device identifiers (such as IDFV). This information is de-identified or anonymized for analytics and cannot be directly linked to your identity.
iCloud Sync Data: If this feature is available and you choose to enable "Sync/Backup with iCloud," your encrypted data package will be synchronized via Apple's iCloud service. This process is handled by Apple Inc. and is governed by its iCloud Terms and Conditions and Apple Privacy Policy. We cannot access the contents of your iCloud account.
To support the free version of our App, we may display advertisements and use third-party analytics to improve our product.
For users in the European Economic Area (EEA) and the United Kingdom, we process your personal information based on the following legal grounds:
As a primarily local tool-based App, we currently do not actively use Cookies or similar technologies for user tracking or behavioral analysis. Any future use of such technologies will be disclosed in an updated version of this Policy, and we will obtain your prior consent where required.
1. Sharing: We do not share your private photos, videos, or other core user content with any company, organization, or individual, except in the following circumstances:
2. Transfer and Public Disclosure: We will not transfer your personal information to any third party, nor will we publicly disclose it, except as required by laws, regulations, or mandatory national standards, or with your explicit consent.
To enable specific features and ensure the stable operation of the App, we integrate third-party Software Development Kits (SDKs). We conduct stringent security assessments of these SDKs and enter into data protection agreements requiring them to handle information in accordance with our privacy policy and relevant confidentiality and security measures.
Details of the integrated third-party SDKs are as follows:
| SDK Name | Provider | Purpose | Types of Information Collected | Privacy Policy Link |
|---|---|---|---|---|
| Umeng Mobile SDK | Umeng Tongxin (Beijing) Technology Co., Ltd. | App Data Statistics and Analysis | Device Information (e.g., iOS Advertising Identifier (IDFA), Identifier for Vendors (IDFV)), Network Information, Installed App List (Optional) | https://www.umeng.com/page/policy |
Important Notes Regarding Umeng SDK:
1. Storage Location: Personal information collected and generated within the territory of the People's Republic of China will be stored within China. Your private media files are primarily encrypted and stored within your device's local file system.
2. Retention Period: We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Policy. When you actively delete data within the App or uninstall the App, the corresponding locally stored data will be erased.
Critical Data Risk Notice: Due to the "local-first, encrypted storage" core design of this App, all photos, videos, and other data stored within it are bound to your device. If you uninstall the App, all encrypted data stored locally within the App will be permanently deleted and cannot be recovered through any means. You are solely responsible for backing up any important data via export or other means before uninstallation. We cannot be held responsible for data loss resulting from App uninstallation.
3. Security Measures: We implement a variety of technical and organizational security measures, including but not limited to encryption, access controls, and secure protocols, to protect your information. However, please note that no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
In accordance with relevant laws and regulations, you have the following rights regarding your personal information:
1. Access, Correction, and Deletion: You can directly access, edit (e.g., rename albums, modify notes), and delete any content you store within the App.
2. Modifying Authorization Scope: You can change the App's access permissions to your photo library at any time in your iOS device's Settings > Privacy & Security > Photos. You can also manage the App's biometric unlock permissions in Face ID & Passcode (or Touch ID & Passcode) settings.
3. Withdrawing Consent: You may withdraw your consent for processing based on your consent by disabling features (e.g., turning off iCloud sync), modifying device permissions, or uninstalling the App. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
4. Managing Advertising Preferences: You can manage how advertisers use your interests to show you ads through your device's operating system settings (e.g., on iOS: Settings > Privacy & Security > Tracking to manage "Allow Apps to Request to Track").
5. Data Portability and Objection: Depending on your jurisdiction, you may have the right to receive a copy of your data in a structured format or object to certain types of processing. To exercise these rights, please contact us using the details in Section 12.
Your personal information may be transferred to, and processed in, countries other than your country of residence. These countries may have data protection laws that are different from those in your country. We will ensure appropriate safeguards are in place, such as relying on adequacy decisions or implementing standard contractual clauses approved by relevant authorities, to protect your information during such transfers.
Our App and services are primarily intended for adults. We do not knowingly collect personal information from children under the age required by applicable law in your region (e.g., under 13 in the US, under 16 in the EEA without parental consent). If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.
We use Apple's In-App Purchase system for subscriptions. Payment data (e.g., credit card) is handled securely by Apple and not accessed or stored by us. We may collect anonymized subscription status for analytics to improve the app. For details, see Apple's privacy policy.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other reasons. The updated version will be indicated by the "Last Updated" date at the top of this page and will be effective upon posting. For material changes, we will provide more prominent notice within the App. We encourage you to review this Policy periodically.
If you have any questions, concerns, or requests regarding this Privacy Policy or wish to exercise your privacy rights, please contact us. We have established a user complaint mechanism and are committed to responding promptly.
Data Protection Officer / Contact Email: locksy@snweilai.com
We will endeavor to respond to your request within fifteen (15) business days.
If you are not satisfied with our response, particularly if you believe our processing of your personal information infringes applicable data protection laws, you have the right to lodge a complaint with a supervisory authority in your country of residence.
© 2025 Chengdu Shangen Future Technology Co., Ltd. All Rights Reserved.