Privacy Policy

Unlokie d.o.o.
Last updated: August 26, 2026

This Privacy Policy explains how Unlokie d.o.o. ("Unlokie", "we", "us", "our") collects, uses, shares and protects personal data when you use:

• our website at unlokie.com;
• our Unlokie app for iPhone and Android (the "App");
• our smart lockers, the equipment we rent from them, and our support channels.

Together these are the "Services".

Read this policy together with our Terms & Conditions, our Cookie Policy and our Account Deletion page.

1. Data Controller

Controller: Unlokie d.o.o.
Address: Rožmanići 23B, 51221 Kostrena, Croatia
Email: [email protected]
Website: unlokie.com

Unlokie is the data controller for the personal data described in this policy, and is responsible for it under the GDPR.

Where a municipality, city, venue or other partner processes personal data for its own purposes, that partner is a separate controller for that processing.

2. Personal Data We Process

2.1 Account and profile

• Your email address, and the account identifier from Google or Apple if you sign in that way.
• Your first name and last name.
• Your date of birth. We ask for it to check that you are 18 or older.
• Your phone number, if you give us one.
• Your gender, if you give us one.
• Your Unlokie account number, and the sign-in identifier our authentication provider gives you.
• Your language preference.
• The fact that you accepted our Terms & Conditions when you created your account.

2.2 Photographs you take in the App

To end a rental you must photograph the locker compartment. The App cannot close a rental without one. You can also photograph damaged equipment before or during a rental, and attach a photograph when you report a problem with a return.

We process:

• the photograph itself;
• the account, rental, locker and compartment it belongs to, stored alongside the image file;
• every photograph you submit for a return, including the ones our automated check did not accept, not only the final one.

The App asks you to step back so the whole locker fits in the frame, and our lockers stand in public places, so a photograph can also show people, vehicles or surroundings near the locker. We use these photographs to check that equipment was returned, to deal with damage, non-return and fraud, and to improve the accuracy of the automated return check: a small number of return photographs have been labelled by hand and used to train the models that run that check. We do not run face recognition on them.

Section 11 explains the automated check we run on the return photograph.

2.3 Rentals and locker use

• Which locker and which compartment you used, which equipment you took, and the start and end time of each rental.
• The unlock and return commands sent to the locker, their technical result, and the locker's own status such as door state and battery level.
• The state of each return, including whether the automated check accepted it, and how many attempts it took.
• Each locker stands at a fixed address, so this record shows which locker you were at and when.

2.4 Payments and invoicing

• Your customer identifier and saved payment method identifier at our payment provider.
• The amount, currency, status and identifiers of every payment, pre-authorization hold and refund.
• Fiscal invoice records. These carry your first and last name, your email address, the invoice number, the amount and the Croatian fiscalization codes.

We never receive or store your full card number. You type card details into our payment provider's own screen. The customer, payment method and payment identifiers above come from our payment provider, not from you. The name and email address on a fiscal invoice come from your account.

2.5 Fees, restrictions and case records

• Non-return and damage cases: the amount, the reason, when the case was opened, and how it was resolved.
• Whether your account is restricted, and the notes our staff add when they review a case.

2.6 Things you write to us

• Support messages, and the enquiry form on our website.
• The rating, the issue codes and up to 1000 characters of free text you can submit after a rental.
• The notes you add when you report damage or a problem with a return.

2.7 Device, technical and diagnostic data

• Device model and manufacturer, operating system version, App version, language, time zone, and on Android the mobile network operator.
• The push notification token for your device, and on iPhone the tokens for the rental Live Activity on your lock screen.
• Application and web server logs. These include IP addresses.
• Error, crash and performance reports. These include a screenshot of the App screen at the moment of the error, a description of the layout on that screen, and a record of the network requests the App made around that time. One of those requests, the check the App runs when you type your email address at sign-in, carries your email address. Error reporting runs for everyone who uses the App. The analytics choice below does not switch it off. You can object to it under Section 9.
• If you turn on usage analytics: app events linked to your account, your device and app details, your IP address, and a screen recording of a small sample of sessions.

2.8 Location

• The App uses your device location while you have it open, to show nearby lockers and sort them by distance. That location stays on your device. We do not receive it and we do not store it.
• On Android, the operating system also requires location permission for the Bluetooth scan that finds the locker in front of you. That scan runs on your device.
• We do record which locker you used and when, as described in 2.3. Read together, those records are a trail of where you were and when.

2.9 Website

Our website sets no cookies of its own. The only thing it stores in your browser is your chosen site language. The provider that delivers and protects the site, named in Section 4, can set a short-lived security cookie of its own to tell a person from a bot. If you use the enquiry form, the name, email address, organization and message you type are passed to the form provider named in Section 4, which delivers them to us by email. We do not store them on the website.

We do not intentionally collect special category data.

3. Purposes and Legal Bases

We process personal data under the GDPR on one or more of the legal bases below.

Where we rely on consent, you can withdraw it at any time. Withdrawing it does not affect processing we carried out before you withdrew it.

Where we rely on legitimate interest, you can object to that processing. Write to [email protected].

4. Service Providers

Most of the providers below process personal data only on our instructions and only for the purposes listed here. Some of them, including our map, sign-in and payment providers, also process some data as controllers in their own right under their own terms, and we say so in the rows below. We can give you the full legal name and registered address of any provider on request.

5. Sharing of Personal Data

We share personal data with the providers named in Section 4, on the terms set out in that section. Most of them act only on our instructions. Our map, sign-in and payment providers also act as controllers in their own right for parts of what they do, and their own privacy policies cover that part.

We also share personal data:

• with our professional advisers, and with public authorities or courts where the law requires it, or where it is necessary to establish, exercise or defend legal claims;
• with an acquirer or successor if we merge, are acquired, or restructure.

Our own staff can see the data in Section 2 through an internal console, in order to run the service, review a fee, or answer a support request. Access is limited to staff we have authorized.

We may give municipalities, cities and partners aggregated statistics that do not identify anyone.

We do not sell personal data, and we do not share it for advertising.

6. International Data Transfers

Most of our processing happens inside the European Economic Area. Our servers are in Finland and Germany. Our photograph storage, our database backups and our server logs are in Frankfurt. Our analytics provider uses its European Union region and our error reporting provider uses its German region. The automated return check also runs on our own servers inside the EEA, up to its last step.

These recipients process personal data outside the EEA:

• Alibaba Cloud, Model Studio, in Singapore. Every time you submit a return photograph that reaches that last step, a cropped image of the locker compartment is sent there, with the name of the equipment we expect to see. No name, email address, account number or rental identifier goes with it. This transfer relies on the Standard Contractual Clauses in Commission Implementing Decision (EU) 2021/914, Module Two.
• Cloudflare, Formspree, Anthropic and Linear in the United States, and, for parts of their processing, Google, Apple and Stripe. These transfers rely on the EU-US Data Privacy Framework where the provider is certified under it, and otherwise on the Standard Contractual Clauses in that provider's terms.

You can ask for a copy of the safeguards we rely on for a specific transfer by writing to [email protected].

7. Data Retention

We keep personal data only as long as we need it for the purposes in this policy, or as long as the law requires. The criteria we apply are how long your account is open, how long a rental, a fee or a dispute can still be questioned, and the periods Croatian accounting and tax law sets for invoices.

Where the table below shows a period in square brackets, we have not fixed that period yet. Until we do, that data stays in our systems and we delete it by hand, either when you ask us to or when we no longer need it. Most of these periods are applied by our staff rather than by an automatic deletion job, so treat them as the longest we will keep the data.

Backups and copies. We back up our database every day and keep each backup for 35 days. Our hosting provider also keeps up to seven daily snapshots of our servers. If we delete or anonymize your data, a copy can still sit in a backup or a snapshot until that copy is overwritten on its normal cycle. We do not use backups to bring a deleted account back.

When we no longer need personal data, we delete it or make it permanently anonymous.

8. Account Deletion

You can ask us to delete your account from inside the App, or by email. Our Account Deletion page explains how to ask, what happens next, and how long it takes. Deleting your account anonymizes it rather than erasing it: your account record stays, and we overwrite your email address, sign-in identifier, name, phone number, date of birth and gender with values that cannot be linked back to you.

What stays, and why. We want you to know exactly what deletion does not reach today:

• Rental and locker session records stay, for the period in Section 7. They no longer carry your name or your contact details.
• Photographs from your returns and from damage reports stay, for the period in Section 7.
• Fiscal invoices and payment records stay for the period in Section 7, including the name on the invoice and the email address we sent it to, because Croatian accounting and tax law requires it. The raw event records our payment provider sends us also stay, and they carry the name, email address, phone number and billing address you gave at payment.
• Records of a non-return, damage or fraud case, and of any restriction on your account, stay for the period in Section 7.
• Feedback and support messages stay, for the period in Section 7.
• Your customer record at our payment provider is not deleted at that point, and any card you saved stays attached to it. Your sign-in record at our authentication provider is disabled rather than deleted, so the email address you used stays registered there and cannot be used to open a new Unlokie account.

You can ask us to delete anything in that list that we are not required to keep. Write to [email protected] and we will do it by hand and tell you what we did.

9. Your Rights

Subject to the limits in the law, you have the right to:

• ask for access to your personal data;
• have inaccurate data corrected;
• ask for deletion;
• ask us to restrict processing;
• object to processing we base on legitimate interest, including the error reporting in Section 2.7 and the operational alerts in Section 4;
• ask for portability of the data you gave us;
• withdraw consent at any time, for anything we do on the basis of consent;
• complain to a supervisory authority.

Some of these rights have limits. For example, we cannot delete an invoice we are required by law to keep.

To use any of these rights, write to [email protected].

If you are in Croatia, the supervisory authority is the Agencija za zaštitu osobnih podataka (AZOP), azop.hr, [email protected]. You can also complain to the supervisory authority in the EU country where you live or work.

10. Cookies and Device Technologies

Our website sets no cookies of its own and uses no analytics, advertising or tracking pixels. It stores your chosen site language in your browser. The provider that delivers and protects the site can set a short-lived security cookie to tell a person from a bot.

The App stores data on your device to keep you signed in, to keep a payment session intact, to remember your settings, and to remember your analytics choice.

Your analytics choice is stored on your device only. It is never sent to our servers, so we hold no server-side record of it. If you reinstall the App, the choice goes back to off. You can change it at any time in the App, under Settings, then Privacy.

Our Cookie Policy has the detail.

11. Automated Return Verification

When you end a rental you photograph the compartment. An automated check reads that photograph to confirm the equipment is back and is the equipment you rented.

The check compares a cropped image of the compartment against the equipment we expect to see in it, and answers whether it is there. The last step of the check is performed by a provider outside the EEA, named in Sections 4 and 6.

The check does not decide any fee on its own. What it decides is whether a return is confirmed. Section 12 explains what happens when a rental is never confirmed as returned.

12. Automated Decisions

Two things happen automatically, with no person reviewing them first. We set them out here because they affect you.

1. The automated return check. When you end a rental, an automated check reads the photograph you take, as described in Section 11. If it cannot confirm the return, the rental stays open and the App asks you to try again or to report a problem, unless the failure is on our side, in which case we accept the return rather than leave you unable to finish.

2. The 24 hour non-return boundary. The App tells you about this limit and the fee before you unlock. If a rental is still open 24 hours after it started, our system automatically:

• ends the rental as not returned;
• takes the maximum payment for that rental from the pre-authorization hold placed when the rental started, because by then the time used has passed that maximum;
• opens a non-return fee of EUR 50;
• restricts your account, so you cannot start a new rental until the fee is settled or we cancel it after review.

The EUR 50 is never charged to your card automatically at that moment. You settle it yourself in the App, or a member of our team charges it after reviewing the case.

Your rights over these decisions. You can ask us to have a person review either decision, tell us your side of it, and challenge the outcome. Write to [email protected] or [email protected]. We will look at the rental records, the photographs and anything you send us, and we will tell you the result. If the decision was wrong, we cancel the fee and lift the restriction.

Neither of these two decisions uses a profile of you or a prediction about your behaviour. Where you turn usage analytics on, our analytics provider does build a record of how you use the App linked to your account, as described in Sections 2.7 and 4. That record plays no part in either decision above.

13. Security

All traffic between the App, our website and our servers is encrypted in transit. Our servers, our database, our photograph storage and our server logs are inside the European Economic Area. Section 6 names the recipients that are outside it. Access to personal data is limited to staff we have authorized. We back up our database every day. If you think you have found a security problem in the Services, write to [email protected].

14. Changes to This Policy

We may update this policy. The current version and its date are always published in the Services. If we start processing your data for a new purpose, or introduce a new automated decision, we will tell you before it takes effect.