Privacy Policy

We Respect Your Right to Privacy and Your Right to Control Your Personal Information

ShareLocket is a product of ShareLocket LLC (“we,” “us,” or “our”). We want you to fully understand what information we collect from you and what we do with it. We also believe that you should have full control over your personal information.

We do not disclose your information to anyone without your prior consent, subject to the very narrow extent specified below. We do not sell your information. We never spam you.

FAQ

What personal details do you need to know?

The minimum information we ask for your use of ShareLocket is your name, email address, and phone number. Depending on how you use the Service, we may also ask for details you choose to include about your Album.

You may update this information at any time through your account settings.

We also need your Albums' member lists (including names and email addresses or phone numbers) so that your invitations can be sent and the responses tracked and tallied. Album member information can be added to ShareLocket in the following ways:

• Manually: Type the information into the contact form.
• Copy/Paste: Manually copy and paste the data from your computer or mobile device.
• CSV Import: Import a CSV document with member information from your computer or mobile device.
• Google: Import contact data from your Google account. (This data will not be accessed without your express permission.)
• Outlook: Import contact data from your Outlook account. (This data will not be accessed without your express permission.)
• Phone Import: Import contact data from your phone or mobile device. (This data will not be accessed without your express permission.)

When is my information given out?

Your name, email address, and the details you include in your Album invitations are made available to your invitees and to anyone else who receives a copy of your invitation. That information could be transmitted to additional persons if your invitees or other recipients forward your invitation to others.

Does ShareLocket LLC sell my information to third parties?

We do not sell or lend any of your personal information to third parties without your prior consent except under the narrow guidelines stated in this Policy (for example disclosure to service providers working for us).

What do you use my personal details for?

• Security. We use your name so that we can personalize your experience with us. We use your email address to contact you if needed and to securely confirm your identity. We use your phone number to securely confirm your identity. If you use the Help feature and request assistance or information from us, we will respond to you using [email protected].
• Use of Site. The details you include in your Album help make your invitation informative and accurate. Your member list (including names, email addresses, and mobile numbers) is necessary to enable distribution of your invitation and for you to see who has accepted, declined, or commented on the Album.
• Improving our Site. We collect your IP address and browser information, which we combine with information from other Users of our site. We use this combined information to enhance our site’s functionality and gain a better understanding of our users, ultimately improving our ability to serve them.
• Providing Information. We may deliver information that is targeted to your interests, such as banner advertisements, administrative notices, product offerings, and communications relevant to your use of the Site. By accepting the Terms of Use and Privacy Policy, you expressly agree to receive this information. You may make changes to your email notification preferences at any time through your account settings.
• Using Service Providers. We may use third parties (“service providers”) to facilitate or outsource one or more aspects of the business, product and service operations that we provide to you (e.g., email support, SMS delivery) and therefore we may provide some of your personal information directly to these service providers who are obliged to keep your information confidential. SMS/MMS/RCS opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the text messaging services.
• Non-Personal, Aggregated Information. We disclose non-personally identifiable aggregated information to advertisers and other third parties.
• Analytics. ShareLocket LLC uses the services of site analytics providers such as Google Analytics (or similar services) to analyze traffic and usage on the Site. In the course of providing services, such companies may have access to Users’ IP addresses. We make no effort to match IP addresses with any other personally identifiable information.
• Law Enforcement. In response to a genuine request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can disclose personal information about you and your Album.
• Unintended Access. Although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.
• Acquisition. In event of a merger or acquisition, your personal information may be transferred to the acquiring entity, and become subject to the acquirer’s data practices.

Will I be added to any mailing lists?

We do not sell, rent, or lend email addresses for any other purpose than in direct association with your use of the ShareLocket service or as otherwise described in this privacy policy.

Do you send unsolicited emails/SMS messages?

ShareLocket LLC will not send any unsolicited information, including email or SMS/MMS/RCS messages. You will, however, receive emails/SMS messages which form an essential part of the service.

To discontinue receiving SMS/MMS/RCS messages, reply to any SMS/MMS/RCS message sent by ShareLocket with the keyword ‘STOP’. After you send ‘STOP’ to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS/MMS/RCS messages from ShareLocket.

Users are solely responsible for obtaining permission to send invitations to Album members via email/SMS. Unsolicited invitations to members are expressly prohibited and may result in account termination.

Do you use cookies? How can I opt out of them?

Cookies allow us to store and retrieve login information on a user’s system and help us provide useful features. Most browsers are initially set up to accept cookies; you can set yours to refuse cookies, but you may not be able to take full advantage of our Service if you do so. For more information, see aboutcookies.org.

Circles

A circle is a private space on ShareLocket for a family or another group. What is shared in a circle can be seen only by the people in it. A circle has no public page, and nobody can browse from one circle into another. If you belong to more than one circle, each one is kept separate, and nothing shared in one is used in another.

What do you keep when I use a circle?

• Your membership. Which circles you belong to, your role in each (owner, admin, or member), when you joined, the name and contact details used to invite you, and your settings for each circle, such as how often you hear from it.
• What members share. Posts and notes, photos, videos, voice notes and voice messages, documents, comments, reactions, the people tagged in photos, dates, gift ideas, and links.
• How it arrived. You can add to a circle from the website, by email to the circle email address shown to you, by text or picture message to the circle’s phone number, and, where available, by calling the circle’s number and leaving a voice message, which we record. To post by email, text, or phone, you send from an email address or phone number you have confirmed on your account; that is how we know a message is yours. We keep a record of the messages that reach a circle (who sent them and when) so we can deliver them and fix problems. When a text comes from a number we don’t recognize, we don’t post it, and we keep only part of the number and none of the message.
• Link previews. When someone shares a link, we check it against lists of known unsafe sites. If it passes, our servers visit the page to fetch its title, picture, and icon so the circle can show a preview. The site sees a visit from us, not from you. Some previews, such as a video or a song, can play inside the circle; when someone taps play, it loads from that site, which may collect information under its own policies.

Texts from a circle

Each circle has its own phone number (now and then a member is set up on a different one). Texts about a circle, such as updates, the weekly summary, and a reply when something you texted has been posted, come from the number you are set up on. To stop the posted replies but keep posting, text “quiet” to the circle’s number, and text “replies on” to get them back. Texting STOP to a circle’s number also turns off that circle’s email and text updates for you, and texting START turns them back on.

Who can see what I share in a circle?

• The members of the circle. Every active member can see the posts, comments, and reactions in the circle and can download the original photos, videos, and files shared there. The circle’s owner can also download a full copy of the circle’s archive, which includes everything shared in it and each member’s name and role.
• Your profile in the circle. Other members see your name, profile picture, role, and when you joined, plus a short bio and the month and day of your birthday if you’ve added them (the year only if you choose to show it). We don’t show other members the phone numbers or email addresses on your account.
• Gift ideas. Members can keep gift ideas for each other. An idea someone else adds to your list, or one suggested about you, can be seen by other members but is not shown to you.
• Circle emails and texts. Members receive updates and a weekly summary by email or text, depending on their settings. These can include photos, captions, and members’ names and profile pictures. In an email, each photo and profile picture loads from its own address, which we check every time it is opened: the person reading must still be in the circle and the post must still be there. Email services sometimes keep their own copy of a picture once it has been shown, and we can’t remove those copies. An invitation to a circle shows the inviter’s name and profile picture to the person invited.
• Albums made in a circle. Every active member of a circle is automatically a guest of the circle’s published Albums. They appear in the Album’s guest list, receive its notifications, and can see and download what is in it. An Album can also be shared with people outside the circle, depending on its settings, so anything added to an Album can be seen by that Album’s wider audience. Leaving a circle ends this automatic guest access.
• Picture frames. The owner or an admin of a subscribed circle can connect a digital picture frame. A frame shows only photos, never notes, captions, comments, names, dates, or places, and only from the part of the circle chosen for it. Anyone who has a frame’s private link can see the photos it shows, so the owner and admins can replace the link or switch the frame off at any time.
• Our service providers. The companies that store files for us, deliver texts, emails, and calls, process payments, and provide the AI, speech-to-text, and map services described below handle circle content to do that work for us, as described under “Using Service Providers” above.

How do you organize a circle, and do you use AI?

Where these features are available, ShareLocket reads what is shared in a circle to help its members find things. It gathers related posts into collections, builds pages for the people, places, and dates that come up, suggests gift ideas, and answers questions typed into the circle’s Ask box. To do this, we send the words of posts and comments, the written-out words of voice messages, and photos, videos, and documents (to read any words in them and note what they show) to AI service providers that process them for us. What we work out stays with that circle and is shown only to its members.

An answer to a question is put together only from posts and comments the person asking is allowed to see. It points to the posts it came from, it is shown only to the person who asked, and we don’t save it.

Voice notes and voice messages are written out by a speech-to-text service provider so they can be read and searched.

Turning it off. Organizing is on by default. To turn it off, open the circle’s settings and turn off “Let ShareLocket organize my posts.” We then stop reading your posts and comments in that circle and delete what we had worked out from them. Corrections members made themselves, and information that other members’ posts also support, can stay. It is a choice for each circle, nobody else can change it for you, and it doesn’t change anything for anyone else.

Faces. We may detect where faces appear in a photo, using software we run ourselves, so that members can tap a face to tag someone. We never use face recognition: we don’t try to work out who anyone is from their face, and we don’t create face templates or any other record that could identify someone by their face. People are named only when a member tags them or writes their name.

Places. Where the circle map is available, we send a place’s name (never a person’s name, a post, or a photo’s location) to a mapping service provider to find it on the map, and the map itself loads from a map provider when you view it. If a photo carries its location, we keep that on our servers and don’t show it in the circle.

How are circle subscriptions paid for?

Any active member can pay for a circle’s subscription. The person who pays manages it, and payments are handled by our payment processor; we don’t store full card numbers.

What happens when I leave a circle or close my account?

• Leaving a circle. What you shared stays in the circle for its members. You can delete your own posts and comments before you leave; afterwards, ask the circle’s owner or an admin, who can delete them, or contact us. Albums you made in the circle pass to the circle’s owner. Once you leave, messages from your phone number or email address are no longer added to the circle.
• Closing a circle. The owner can close a circle. A closed circle takes nothing new, but everything in it stays, and members can still look through it and download from it.
• A circle without a subscription. A circle without a subscription shows only posts from the most recent 30 days. Older posts are not deleted, and they return when the circle has a subscription again. The owner can download the circle’s full archive at any time, with or without a subscription, and you can request a copy of your own account’s information from your profile.
• Deleting your account. We remove your account information, but the posts, photos, and comments you shared in a circle stay for its members, shown as from a deleted account, without your name or profile picture. Drafts you never posted are deleted. If you want something you shared removed, delete it before you delete your account.

How do you use my Google data?

ShareLocket works with Google only when you ask it to: to sign in, to import contacts so you can choose who to invite, and to import photos, videos, or files from Google Drive or Google Photos into a Album or a circle. In every case we request the narrowest permission that makes the feature work, use what we receive only to provide that feature, and never use it for advertising or sell it. You can revoke ShareLocket’s access at any time in your Google Account settings.

Signing in with Google

When you sign in with Google, we receive your primary Google Account email address (userinfo.email) and basic profile information such as your name and profile picture (userinfo.profile). We use these only to create your account, sign you in, and identify you within ShareLocket.

Google Contacts (choosing people to invite)

When you choose “Import from Google” while inviting people, we ask for read-only access to your saved contacts (contacts.readonly) and the “Other contacts” Google saves automatically (contacts.other.readonly). We read only each contact’s name, email address, and phone number, and never change or delete anything. We use this only to show you a list to pick from. Your contacts are not stored in our database; we hold them for a few minutes while you choose, then discard them, keeping only the people you actually invite.

Google Drive (importing photos, videos, and files)

When you choose “Google Drive,” Google’s own picker opens and we ask only for the drive.file permission, so Google shares with us only the files you select. We can never see anything else in your Drive, and our access is read-only. We use it only to copy your chosen files into the Album or circle you chose.

Google Photos (importing photos and videos)

When you choose “Google Photos,” Google’s own picker opens and we ask only for the photospicker.mediaitems.readonly permission, so we receive only the photos and videos you select. We can never browse the rest of your library, and our access is read-only. We use it only to copy your chosen items into the Album or circle you chose.

Limited Use

ShareLocket’s use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements. We use Google user data only to provide the features above, do not transfer it to others except as needed to provide those features or as required by law, do not use it for advertising, and do not allow humans to read it except with your consent or for security or legal reasons.

What are my Rights Under the California Consumer Privacy Act (effective 1/1/20)?

What is Personal Information. The California Consumer Privacy Act (“CCPA”) defines your Personal Information broadly as information that “identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Examples include name, address, IP address, email address, personal identification numbers, purchase records, biometric information, browsing and search history, and geolocation data.

Requests for disclosure. CCPA gives you the right to request disclosure from us regarding categories and particular pieces of Personal Information that are collected, sold, or disclosed about you; the categories of sources from which that information is collected; the business purpose for collecting the information; and the categories of third parties with which the information is disclosed.

How to request access, correction, or deletion. Please make your request by contacting us at [email protected]. Certain information cannot be deleted if you intend to continue using the service (such as your email address and phone number).

Non-discrimination. We do not discriminate against any site users who exercise their rights under the CCPA or other data privacy laws.

What are my Rights Under the California Privacy Rights Act (effective 1/1/23)?

What does the CPRA add to the CCPA? The California Privacy Rights Act (“CPRA”) expands the privacy protections in the CCPA. The CPRA covers personal information collected beginning January 1, 2022.

The additional protections added by the CPRA include, but are not limited to, the following rights:

• To know and have access to one’s personal information
• To correct personal information
• To limit use of sensitive personal information (including but not limited to, social security, driver’s license, and passport numbers) so they are used only to perform the services, as reasonably expected by a consumer
• To delete personal information
• To opt-out
• To receive equal service and price regardless of the exercise of rights

What additional obligations does CPRA impose on companies that collect personal information?

• Data retention disclosure
• Vendor and contractor supervision, including specific clauses required in vendor contracts such as prohibiting selling and sharing personal information; retaining, using, or disclosing personal information for any reason other than the contract purposes or outside the business relationship; and combining personal information from the contract with other personal information
• Audit and certification obligations
• Data minimization
• Implementing reasonable security procedures and practices appropriate to the nature of the personal information, to protect it from unauthorized or illegal access, destruction, use, modification, or disclosure

How Long is Information Kept?

ShareLocket LLC keeps different kinds of information for different lengths of time:

• Your Album content. The photos, videos, files, and other materials you upload to your Albums are kept for as long as ShareLocket LLC operates the Service, so that your Albums remain available to you and the people you share them with. We do not delete this content on a fixed schedule. You can delete it yourself at any time, and what happens to it if we ever cease operations is described in the “Preservation and Return of Your Content” section of our Terms of Service.
• Circle content. What is shared in a circle is kept while the circle exists, including after the person who shared it leaves, so the circle stays whole for its members. It can be deleted by the person who shared it while they are a member, or by the circle’s owner or an admin. The “Circles” section above explains what happens when you leave a circle or delete your account.
• Your account information. Information such as your name, email address, and phone number is kept for as long as your account is active, so that we can operate your account and confirm your identity. Certain information cannot be deleted while you continue to use the Service.
• Routine business records. ShareLocket LLC maintains a Record Retention Policy and Schedule (“Policy”) which calls for the deletion of routine business information on a periodic basis according to the type of record and the department that generates it. Our executives are responsible for periodic record deletion in accordance with the Policy. Many such records are deleted after one year.
• Legal records. Some important legal documents are retained permanently as required by the Policy or by law.

When you delete content or close your account, we remove the associated information from the active Service. Residual copies may persist for a limited time in routine backups before being overwritten.

What would you do in case of a data breach?

If ShareLocket LLC experienced a data breach, we would take emergency measures to secure our systems, then promptly notify all users that a data breach had occurred, providing appropriate information to enable individuals to protect their privacy and any affected accounts, and providing contact information for questions.

We would then remove further threats of breach to the best of our ability with the help of our professional and technical advisors. We would also notify applicable law enforcement and cooperate with any investigation.

How will I be notified of changes?

We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms shall automatically be effective immediately after posting on the Site.

How do I contact you?

If you have any questions about this Privacy Policy, the practices of this website, or your dealings with this website, you can contact us via email, or by writing to Customer Support, ShareLocket LLC, 1255 22nd St. NW #57429, Washington, DC 20037.

• Email: [email protected]
• General inquiries: [email protected]