App Privacy Policy

Unlockator ("we", "us", "our", " Unlockator") is a game from David Krulich.

We are committed to protecting and respecting your privacy. We are a data controller under CZ law. This means we are responsible for determining the purposes for which and the manner in which the personal information provided through the Unlockator mobile application is processed. Please note that the App interacts with other third parties. In some cases, we are simply processing your personal information on their behalf. Such third parties may also be data controllers in their own right and have their own privacy policies.

Personal Information means information that identifies you personally such as your nick, e-mail.

What does this policy relate to?

This policy applies to your use of the Unlockator mobile application software ("App"), from the site from which you downloaded the App ("Appstore"), once you have downloaded the App onto your mobile or handheld device. This policy also applies to any of the services accessible through the App ("Services").

This policy sets out the basis on which any personal information we collect from you, or that you provide to us or that is provided to us by other third parties will be processed by us. Please read this policy carefully to understand our practices regarding your personal information and how we will treat it.

What personal information does Unlockator collect?

1.       Information you give us.

This is information you give us about you when filling in forms/screens on the App, any interactions you undertake or services you request or source through Unlockator or by corresponding with us by phone, e-mail or otherwise.  It will be clear at the time what personal information we are requesting from you. If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide Unlockator services to you, we will not be able to provide these services to you.  You don't have to provide data and can simply choose to stop using the App at any time.


2.      Information we collect about you and your device.

Each time you use Unlockator we automatically collect the following information:

  1. technical information, including the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, and time zone setting;
  2. information either accessed through your device or stored on your device which you have explicitly consented to sharing, and the providence of that data including the device used to collect that data, time, date; and
  3. details of your use of Unlockator.

How does Unlockator use your personal information?

We DO NOT use your data for marketing purposes.

Any personal information you submit through Unlockator or that is accessed by Unlockator is generally required for providing the services to you. However, we may rely on other lawful basis for using your personal information. Specifically, we use information held about you in the following ways:

  1. To provide services to you or where we have a contract with you
  1. To provide you with the Unlockator App and Services and to ensure that Unlockator presents the correct version and data for your device.
  2. To update you on any developments or information about the Unlockator App and Services. These are strictly service emails and do not include marketing.
  3. To allow us to investigate and address queries, questions and complaints that affect your use of the Unlockator App and Services.
  1. Where we have a legal obligation

To make disclosures as required by or in compliance with reasonable requests by regulatory bodies including the General Medical Council or Care Quality Commission, or as otherwise required by law or regulation.

  1. Where it is in our legitimate interest
  1. To review and enhance the quality of our services and products through details of your use of the Unlockator App and Services. This is in our legitimate interest to ensure we continue to improve the services we provide to customers.
  2. To allow us respond to general enquiries and feedback from you. This is in our legitimate interest in providing a responsive service to customers.
  3. For internal operations, including troubleshooting, detection of fraud, log data analysis, testing, security, audit and statistical purposes. This is in our legitimate interest to protect our business interests and assess our business effectiveness.

Where we rely on legitimate interest as a ground for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests. You have a right to the information contained in these balancing tests on request and can find out more by contacting us using the details below.

When will Unlockator share your personal information?

We will not sell your personal information and there are no additional processors we share your personal information with.

We may disclose your personal information:

  1. To use ad system or other service in the course of providing the Services to you;
  2. If we are under a duty to disclose or share your personal information to comply with any legal or regulatory obligation; or
  3. To enforce or apply our Terms and other agreements or to investigate potential breaches of such Terms; or
  4. To protect the rights, property or safety of Unlockator, our customers, or others.

How does Unlockator store your personal information?

We will store your personal information at secure data centre provided by Google - Firebase. This is third-party Service (more information about third-party Services is available at the section ‘What about third party sites?‘) All data will be encrypted when being transferred to and from your device to Unlockator or to our data centre. It is your responsibility to keep any passwords or pin codes used to access Unlockator confidential. More information about the privacy of Google Firebase is available on the web page:

We take all steps reasonably necessary to ensure that your data is treated securely through strict procedures and security features to prevent unauthorised access to your personal information. However, we cannot guarantee the secure transmission of information via the internet due to security threats outside our control and as such, any transmission of information is at your own risk.

How long does Unlockator store your personal information?

We will retain your personal information for as long as needed to fulfil the purposes outlined in the ‘How does Unlockator use your personal information?’ section above or for a period specifically required by applicable regulations or laws. For example, we generally keep your personal information for as long as you remain a registered user of the App.

When determining the relevant retention periods, we will take into account factors including:

  1. our contractual obligations and rights in relation to the information involved;
  2. legal obligation(s) under applicable law to retain data for a certain period of time;
  3. statute of limitations under applicable law(s);
  4. our legitimate interests where we have carried out balancing tests (see section on ‘How do we use your information above);
  5. (potential) disputes; and
  6. guidelines issued by relevant data protection authorities.

Otherwise, when requested we securely erase or anonymise your personal information where you cease to be a user of the App and we no longer require your information for the purposes collected.

What about third party sites?

Unlockator or any other Service we offer may contain links to other independent third-party websites or mobile applications ("Third-party Sites").

These Third-party Sites are not under our control, and we are not responsible for and do not endorse their content or their privacy policies (if any). You will need to make your own independent judgement regarding your interaction with any Third-party Sites, including the purchase and use of any products or services accessible through them.

What rights do you have?

By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the data protection regulator in your country (ICO). You can exercise any of these rights by contacting us through our details below.



What does this mean?

The right to object to processing

You have the right to object to certain types of processing, including processing where we rely on our legitimate interest as a ground for processing.

The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.

The right of access

You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy).

This is so you’re aware and can check that we’re using your information in accordance with data protection law.

The right to rectification

You are entitled to have your information corrected if it is inaccurate or incomplete.

The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions.

The right to restrict processing

You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

The right to data portability

You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

The right to withdraw consent

If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). Note that such withdrawal in certain circumstance may mean we can no longer continue to provide the Services to you.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.

Changes to this App Privacy Policy

We update our privacy policy from time to time and any changes we may make to our privacy policy in the future will be posted online and, where appropriate, notified to you when you next open Unlockator. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of Unlockator.

Contact Us

If you have any questions, comments and requests regarding this Policy, please get in touch with us:

David Krulich


Data Protection Officer contact details:

David Krulich