Privacy Notice

Effective date: July 1, 2024

This Privacy Notice is provided by Xender (HK) Limited, the developer of the AppLock & Picture Privacy App.

This Privacy Notice ("Notice") describes how Xender (HK) Limited ("Xender", "we", "our" or "us") collects, processes, and protects personal data about you through the AppLock & Picture Privacy App (the "App"), xender.com, and all other Xender websites and applications (collectively, the "Services") that link to this Notice. This Notice also describes your rights in relation to your personal data.

Xender is the controller of your personal data. If you have any questions about this Notice or how we use your data, our details are provided in the "Contact Us" section below.

This Notice may be provided in more than one language. In the event of any conflict, where permitted under local law, this English language version of the Notice shall prevail.

1. PERSONAL DATA THAT WE COLLECT

Personal data is information, or a combination of pieces of information that could reasonably allow you to be identified. We collect personal data from a variety of sources, including from you directly (e.g., when you contact us), information we generate about you in the course of our relationship with you, and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law), and third-party services (such as third-party social media companies, advertising partners, and analytics providers).

We may also collect certain personal data about you as required by law, or as a consequence of our contractual relationship. Failure to provide this information may prevent or delay the fulfilment of these obligations. We will inform you at the time when your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.

We may collect the following categories of personal data from and about you:

2. HOW WE USE YOUR PERSONAL DATA AND THE BASIS ON WHICH WE USE IT

We may use your personal data for the following purposes:

We must have a legal basis to process your personal data, as specified under applicable laws. In most cases the legal basis will be one of the following:

3. HOW AND WHEN WE SHARE YOUR PERSONAL DATA

We may share your personal data as follows:

4. INTERNATIONAL DATA PROCESSING & TRANSFER

Where permitted under applicable laws, your personal data may be transferred to, stored, and processed outside of your jurisdiction, including, if you are an EU or UK-based user of the Services, in a country that is not regarded as ensuring an adequate level of protection for personal data under European Union law / by the European Commission or under UK law / by the UK Government, including Singapore.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protection for your personal data. For more information on the appropriate safeguards in place, and to obtain a copy of such safeguards, please contact us at the contact information below.

5. DATA SECURITY AND RETENTION

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing.

We retain your personal data for as long as we have a relationship with you. After our relationship has ended, we retain your information as long as required by law. We may also retain records to investigate or defend against potential legal claims, deal with any complaints or official enquiries or investigations regarding the Services, or maintain business records for analysis and/or audit purposes.

6. YOUR RIGHTS OVER YOUR PERSONAL DATA

You have certain rights regarding the personal data we hold about you, subject to local law. These may include the following rights:

If you would like to discuss or exercise any rights you may have under law, please contact us at the contact details below.

7. CHILDREN'S INFORMATION

The Services are not directed to children, and we do not knowingly collect any personal data from children under the age of 13 (or such legally required age of consent as defined under applicable laws) or knowingly allow such person to register on our Services. In the event that we are notified that we have collect personal data from a child of or under the age of 13 (or such legally required age of consent as defined under applicable laws) without parental consent, we will suspend the account and delete relevant information as quickly as possible. If you believe that we might have any information from a child of or under 13 (or such legally required age of consent as defined under applicable laws), please contact us at the contact details provided below.

8. CONTACT US

Xender is the controller responsible for the personal data Xender collects and processes. If you have questions or concerns regarding the way in which your personal data has been used or would like to exercise any right, please contact us at: xenderlockservice@xender.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

9. CHANGES TO THE NOTICE

You may request a copy of this Notice from us using the contact details set out above. We may modify or update this Notice from time to time.

If we change this Notice, we will notify you of the changes. Where changes to this Notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing) or to terminate your use of the Services.

10. Nigeria-Specific Terms

If you are using our Services in Nigeria, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of these Terms, the following terms shall prevail.

11. Indonesia-specific terms that comply with the PDPL

If you are using our Services in Indonesia, the following additional terms shall apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Notice, the following terms shall prevail.

12. Singapore-specific terms that comply with the PDPA

If you are using our Services in Singapore, the following additional terms shall apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Notice, the following terms shall prevail.

Where we rely on personal data provided by you (or your authorised representative), in order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided above.

13. California, USA-specific terms that comply with the CCPA

If you are using our Services in California, USA, the following additional terms shall apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Notice, the following terms shall prevail.

California law grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, California residents have the following rights:

14. Virginia, USA-specific terms that comply with the VCDPA

If you are using our Services in Virginia, USA, the following additional terms shall apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Notice, the following terms shall prevail.

Virginia law grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, Virginia residents have the following rights: