Privacy Policy

Legal privacy terms for platform users.

This Privacy Policy explains how LCN PROCESSING LTD("LockN" or "we"), a company registered in England and Wales with company number 17187457, registered office at 128 City Road, London EC1V 2NX, United Kingdom, processes your personal data when you contact us, make purchases, or use this website.

LCN PROCESSING LTD complies with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR), and — where it applies to data of EU/EEA residents — Regulation (EU) 2016/679 (EU GDPR).

1. Principles for Processing Personal Data

When processing personal data, LockN:

Complies with current applicable laws, including GDPR
Processes data lawfully, fairly, and transparently
Collects data for specified, explicit, legitimate purposes
Ensures accuracy and promptly rectifies inaccurate or incomplete data
Retains data only as long as necessary for stated purposes
Does not disclose data to third parties except as provided in this policy or by law
Implements appropriate technical and organizational security measures

2. Processing of Your Personal Data

Account Creation and Management

Data categories:

Identification and contact data
Account and profile data
Transaction data
Order and delivery data
Payment and financial data
Billing data
Device and technical data
Fraud prevention data
Identity verification data
Communication and support data
Marketing and preference data
Compliance and legal data
Technical and usage data
Analytics and tracking data

Legal basis: Processing is necessary for the performance of a contract to which you are a party (Article 6(1)(b) GDPR).

Retention period: Account data retained while account remains active. After closure, data retained for 90 days for technical and administrative purposes, then deleted or anonymized. Longer retention applies if required for legal compliance or legal claims (up to 5 years).

Data sources: Provided directly by you and generated during platform use.

Data recipients: Hosting providers, anti-fraud tools, customer support systems.

Purchase and Sale Transactions

Data categories:

Transaction details
Payment status
Delivery details
User ID
Contact details

Legal basis: Processing is necessary for the performance of a contract to which you are a party (Article 6(1)(b) GDPR); processing is necessary for compliance with legal obligations (Article 6(1)(c) GDPR – accounting and taxation).

Retention period: Transaction and accounting-related payment records are retained in accordance with applicable accounting and taxation laws (typically 5–10 years depending on jurisdiction).

Data sources: Provided directly by you and generated during platform use.

Data recipients: Payment service providers, accounting service providers, auditors.

Payment Processing and Fraud Prevention

Data categories:

Payment details (masked identifiers)
IP address
Device data
Fraud signals

Legal basis:Processing is necessary for the performance of a contract (Article 6(1)(b) GDPR); processing is necessary for the purposes of LockN's legitimate interests in ensuring the security of transactions and preventing fraud (Article 6(1)(f) GDPR).

Retention period: Data retained for up to 3 years for dispute resolution and fraud-prevention purposes.

Data sources: Provided by you, received from payment providers and fraud-prevention tools.

Data recipients: Payment providers (controllers), fraud-prevention service providers (processors), authorities if required.

Identity Verification for Sellers and Buyers

Data categories:

Identity document copy
Selfie/photo
Name
Date of birth
Address
Account ID

Legal basis:Processing is necessary for the purposes of LockN's legitimate interests in protecting marketplace integrity, preventing fraud and ensuring user trust (Article 6(1)(f) GDPR).

Retention period: Data retained for up to 90 days for dispute resolution and fraud-prevention purposes; accounting-related payment records are retained in accordance with applicable accounting and taxation laws.

Data sources: Provided directly by you.

Data recipients: Third-party identity verification service provider (acting as processor).

Important Notice: Identity verification is performed through a third-party service provider integrated into our platform. When you complete the verification process, your data (such as identity document details and photo for liveness check) are transmitted directly to the service provider, who processes this information solely on our behalf and only for the purpose of verification. LockN does not have access to biometric templates or raw biometric data — we only receive information about the verification outcome (e.g., whether the verification was successful).

Customer Support and Communications

Data categories:

Name
Email
User ID
Contents of inquiries and correspondence
Dispute resolution history

Legal basis:Processing is necessary for the performance of a contract (Article 6(1)(b) GDPR); processing is necessary for the purposes of LockN's legitimate interests in resolving disputes and providing effective support (Article 6(1)(f) GDPR).

Retention period: Correspondence retained no longer than 6 months following the end of communication.

Data sources: Provided by you.

Data recipients: Customer support service providers (processors), legal advisors, courts, or competent authorities for dispute resolution.

Marketing Communications

Data categories:

Name
Email
Marketing preferences
In-app identifiers

Legal basis:Processing is based on your consent (Article 6(1)(a) GDPR); processing is necessary for the purposes of LockN's legitimate interests in informing existing customers about similar services (Article 6(1)(f) GDPR), where applicable.

Retention period: Retained until consent is withdrawn or for no longer than 5 years in line with account data retention.

Data sources: Provided when opting in; inferred from service use.

Data recipients: Customer support service providers (processors), legal advisors, courts, or competent authorities.

Legal Compliance and Legal Claims Defense

Data categories:

Any relevant personal data necessary for compliance
Investigations
Audits
Disputes

Legal basis:Processing is necessary for compliance with a legal obligation (Article 6(1)(c) GDPR); processing is necessary for the purposes of LockN's legitimate interests in establishing, exercising or defending legal claims (Article 6(1)(f) GDPR).

Retention period: As long as required to comply with legal obligations or statutory limitation periods.

Data sources: Provided by you, authorities, or third parties.

Data recipients: Authorities, regulators, courts, auditors, legal advisors.

Website Functionality, Analytics, and Personalization

Data categories:

Online identifiers
Type of browser
Number of visits
Pages viewed
Time spent on the website
Referral source
Device information
Language
Country
ISP

Legal basis:Processing is necessary for the purposes of LockN's legitimate interests in ensuring the proper functioning and security of the website (Article 6(1)(f) GDPR); processing is based on your consent for analytics and advertising cookies (Article 6(1)(a) GDPR).

Retention period: Personal data retained as long as the specific cookie remains valid, unless consent is withdrawn earlier.

Data sources: Collected via cookies directly from you when using the website.

Data recipients: IT service providers, hosting providers, cloud infrastructure services.

3. Data Transfers to Third Parties

LockN does not transfer or disclose personal data to third parties except in these cases:

With your consent
To employees, agents, and authorized service providers who need access for purposes outlined in this policy
To data processors (IT infrastructure providers, identity verification providers, payment processors, marketing and analytics providers, customer support systems)
To law enforcement bodies and other recipients required by law or to defend rights and interests

For data processor transfers, LockN requires processors handle data solely according to LockN's instructions, for LockN-defined purposes, and in compliance with this policy, applicable laws, and data processing agreements.

LockN may transfer personal data outside the European Economic Area on a lawful basis for legitimate purposes. Where countries lack adequate data protection recognition, LockN implements appropriate safeguards, such as standard contractual clauses approved by the European Commission.

4. Data Subject Rights

As a data subject, you have these rights:

Right to be informed

You have the right to obtain information about the processing of your personal data, including data sources, processing purposes, legal basis, storage duration, and recipients.

Right of access

You have the right to have access to and obtain a copy of the personal data processed about you.

Right to correction

You have the right to request the rectification of inaccurate or erroneous personal data processed by LockN.

Right to withdraw consent

You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on your consent prior to the withdrawal of your consent.

Right to erasure

You have the right to request deletion of personal data if:

It is no longer necessary for stated purposes
You withdraw consent (where processing was consent-based)
LockN processes based on legitimate interest and you object with no overriding grounds
Legal obligation requires deletion
Data was processed unlawfully

Right to restrict processing

You may restrict processing if:

You dispute data accuracy during LockN's review
Data was processed unlawfully, but you don't consent to erasure
Data is no longer necessary but is needed for legal claims
You object to processing, pending verification of LockN's overriding grounds

Right to object

You have the right to object to the processing of your personal data by LockN for direct marketing purposes, the right to object to the processing of your personal data in the public interest or in the legitimate interests of LockN, unless these interests override the grounds for your objection.

Right to data portability

You have the right to receive the personal data that you have provided to us or to request the transfer of such data to another controller in a structured, commonly used and computer-readable format, provided that the processing of your personal data is based on your consent or on an agreement between us and that your personal data is processed by automated means.

Right to lodge a complaint

If you believe your rights have been violated, you can contact LockN at [email protected] and/or file a complaint with the supervisory authority in your jurisdiction. In the United Kingdom this is the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF — https://ico.org.uk/make-a-complaint/. EU/EEA residents can find their national authority at: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

Exercise of Rights: Contact LockN at [email protected] to exercise rights. LockN may request proof of identity. Upon receipt of your request, LockN undertakes to exercise your right as soon as possible, but in any event within one month of receipt of your request, or to refuse to do so in a reasoned written decision. LockN may charge a reasonable fee if requests are manifestly unfounded, repetitive or excessive.

5. Ensuring Personal Data Security

LockN processes personal data responsibly and securely, implementing technical and organizational measures against accidental or unlawful destruction, damage, alteration, loss, disclosure, or unauthorized processing.

Security measures account for processing risks. LockN employees who have access to personal data are made aware of the requirements for the protection of personal data and ensure the complete confidentiality of the personal data processed.

6. Cookies

What Are Cookies?

Cookies are small text files sent to and temporarily stored on visitor devices. They help identify visitors, store history, and tailor content for convenient browsing, attractive offers, and visitor behavior analysis.

Cookie Consent

When visiting the website, you may actively choose to accept cookies. If you don't consent, non-essential and non-technical cookies will not be placed on your device.

Managing Cookies

You can manage and delete cookies using the website's cookie management tool or your browser settings (Microsoft Edge, Safari, Firefox, Chrome, etc.).

Important Note: If you choose to delete cookies, any options you have set will also be removed and the website may not function properly. For these reasons, we do not recommend that you disable cookies when you use the website.

For more information, visit: www.allaboutcookies.org

Cookie Categories

The website uses cookies in the following categories:

Required/Essential Cookies — Authentication tokens, CSRF protection, session management, and fraud prevention (e.g., XSRF token, authentication tokens, payment SDK identifiers, bot management cookies).
Functional Cookies — A/B testing assignments, currency preferences, language preferences, promo code application, and chat session presence.
Analytical/Performance Cookies — Google Analytics, Hotjar, Microsoft Clarity, and similar services used to measure unique visitors, pages viewed, and session data.
Marketing/Campaign Cookies — Facebook, Google Ads, Snapchat, Twitter, Amazon Ads, and similar advertising cookies used for ad delivery, attribution, and measurement.
Security/Fraud Prevention Cookies — Cloudflare bot management and Google security cookies used to detect and mitigate automated traffic and malicious bots.
Preference/Consent Cookies — Cookies storing your privacy and consent choices (e.g., U.S. Privacy consent string per IAB CCPA/CPRA framework).

A complete and current list of cookies, including names, types (first/third-party), and specific purposes, is available through the cookie management tool on the website.

7. Changes to the Privacy Policy

LockN has the right to change the terms and conditions set forth in this Privacy Policy. If we change the terms of this Privacy Policy, we will post an updated version of this Privacy Policy on the Website.