Privacy Policy

1. Who we are

1.1 This Privacy Policy (the "Policy") explains how Lock Logistics LLC, a Tennessee limited liability company ("Holdout", "we", "us", "our"), handles personal information when you use the Holdout mobile apps, our websites at locklogistics.net and its subdomains, and our backend services (together, the "Services"). Capitalised words that are not defined here have the meaning given in our Terms of Service at https://holdout.locklogistics.net/terms.

1.2 We are the party responsible for (the "controller" of) the personal information described in Section 3. The third parties described in Section 5 are independently responsible for the information they collect from you under their own privacy policies.

1.3 Contact. For any privacy question or request, email support@locklogistics.net with the subject "Privacy request", or write to Lock Logistics LLC, Rogersville, Tennessee, United States. Our mailing address is available on request: email support@locklogistics.net with the subject "Mailing address" and we will reply within 5 business days.

2. How Holdout is built, and why that matters for privacy

2.1 Holdout is a self-custodial app. You sign in with a passkey, which lives on your device and in your Apple or Google account, not with us. We never receive your passkey, your biometric data (Face ID, fingerprint), or any private key.

2.2 We do not keep a customer account database. The only stable identifier we have for you is the public address of your Smart Account (your "wallet address"). Most of what our backend stores is a copy of public blockchain data, organised by wallet address, so that the app can load quickly and send you reminders.

2.3 A wallet address is a pseudonym, not a name. But it can become linked to you, for example when a provider that knows your identity sends funds to it. We therefore treat wallet addresses, and the data we hold against them, as personal information.

3. Information we collect

3.1 Information our backend stores

3.2 Information we process but do not keep

3.3 Information that stays on your device

The following is stored only on your device, in the operating system's secure storage. It is never sent to us, is not backed up by us, and is lost if you delete the app or lose the device:

• target amounts you set for your goals;
• which empty goals you have chosen to hide;
• a cached copy of recent activity, so the app opens quickly;
• your appearance setting (light, dark or automatic);
• which version of the Terms of Service you agreed to on that device, and when;
• the email address you used for Stripe Link, to save retyping it; and
• your passkey and sign-in session, which are managed by your operating system and by Privy.

3.4 Device permissions

The app may ask for these permissions. Each is optional, and you can change them in your device settings.

3.5 Information you give us directly

If you email us, join a community space we run, or send feedback or a bug report, we receive whatever you choose to send, such as your email address, your username on that platform, and the content of your message.

3.6 Information we do not collect

We do not collect your legal name, date of birth, postal address, phone number, government ID, Social Security or tax number, card number, bank account number, precise location, contacts, photos, or advertising identifier. We do not use cookies or similar technologies in the app. The app contains no analytics, crash-reporting, advertising or tracking SDK. If that changes, we will update this Policy before it takes effect.

4. How we use information

We use the information in Section 3 only to:

• (a) run the Services: show your balances, goals, rules, timers and activity; prepare transactions for you to sign; fetch swap quotes; and start purchases and cash-outs with the relevant provider;
• (b) send reminders you have opted into, for example that a lock is about to end or a notice period has elapsed, and avoid sending the same one twice;
• (c) keep your Stripe Link connection working so you don't have to sign in to Stripe for every purchase;
• (d) keep the Services secure and working: debug errors, prevent abuse and fraud, and enforce our Terms;
• (e) respond to you when you contact us;
• (f) understand the Services in aggregate, for example the total number of goals or total value saved across all users; and
• (g) comply with the law and respond to lawful requests.

We do not use your information for advertising, for profiling, for automated decisions that have legal or similarly significant effects on you, or to train AI models. We do not sell it.

Legal bases (EEA, UK and Switzerland). Where that law applies, we rely on: performance of our contract with you for (a) and (c); your consent for (b), which you can withdraw at any time in your device settings; our legitimate interests in running a secure, reliable service and in understanding it in aggregate for (d), (e) and (f); and legal obligation for (g).

5. Third parties that receive or collect information

The Services are assembled from specialist providers. Some act on our behalf (as our "processors" or "service providers"). Others deal with you directly under their own terms and privacy policies and are independently responsible for what they collect. We encourage you to read their policies.

5.1 Providers with their own relationship with you

5.2 Providers acting on our behalf

5.3 The public blockchain

When you sign a transaction, it is broadcast to the Base network and recorded permanently on a public ledger that no one controls. See Section 6.

5.4 Other disclosures

We may also disclose information:

• (a) to comply with the law, a court order, subpoena or other lawful request from a government authority, and to meet sanctions and anti-money-laundering obligations that apply to us or to our providers;
• (b) to protect the rights, property or safety of Holdout, our users or the public, including to investigate fraud, security incidents or breaches of our Terms;
• (c) to professional advisers, such as lawyers, accountants and insurers, under duties of confidentiality;
• (d) in a business transfer, such as a merger, acquisition, financing, reorganisation or sale of assets, in which case the recipient must honour this Policy or give you notice of any change; and
• (e) with your consent or at your direction.

Because we hold so little, what we could disclose in response to a legal request is essentially what is listed in Section 3.1. We cannot disclose identity documents, because we do not have them, and we cannot freeze or hand over funds, because we do not control them.

5.5 No sale, no sharing for advertising

We do not sell personal information, and we do not share it for cross-context behavioural advertising, as those terms are defined in US state privacy laws. We have not done so in the preceding 12 months.

6. Public blockchain data. Please read this

6.1 On-chain data is public. Your wallet address, the assets and balances it holds, every transaction it makes, and for each savings goal its name, its balance, its rules, and every deposit, withdrawal request and withdrawal are recorded on a public blockchain. Anyone in the world can read, copy and analyse this, using free tools, without asking us or you. Blockchain-analytics companies routinely do so.

6.2 On-chain data is permanent. It cannot be edited or erased by you, by us or by anyone else. Rights to deletion or correction (Section 8) cannot be applied to data on the blockchain. Hiding a goal in the app only hides it on your device.

6.3 Goal names. A goal's name is written to the blockchain exactly as you type it. Do not include your name, anyone else's name, account numbers, health information, or anything else you would not want to be public forever. "Holiday" is fine. "Jane Smith's surgery fund" is not.

6.4 Pseudonymous is not anonymous. A wallet address does not contain your name, but it can be linked to you: by a provider that verified your identity and then sent funds to the address, by someone you gave the address to, or by analysis of transaction patterns. Once an address is linked to you, its entire history is too.

6.5 Our copy of public data. Our indexer stores a copy of the on-chain data about Holdout goals, and our API makes activity for a given wallet address available to the app. Because this information is already public on the blockchain, you should assume that anyone who knows your wallet address can see the activity associated with it, whether through a block explorer or otherwise.

7. How long we keep information

We may keep information longer where the law requires it or where we need it to establish, exercise or defend legal claims. Information held by third parties is kept according to their own policies; regulated providers such as Stripe and Bridge are typically required by law to keep identity and transaction records for five years or more.

8. Your rights and choices

8.1 Choices available to everyone

• Notifications: turn them off at any time in your device settings.
• Permissions: revoke camera, photo, microphone or biometric access in your device settings.
• Stripe Link: you can disconnect Link, or simply not use it.
• On-device data: deleting the app removes everything in Section 3.3.
• Access, correction, deletion: regardless of where you live, you can ask us for a copy of the personal information we hold about you, ask us to correct it, or ask us to delete it, by emailing support@locklogistics.net. We will respond within 45 days. We do not charge for this, and we will not treat you differently for exercising any privacy right.

8.2 How we verify requests

We have no names or passwords to check against. To protect you from someone else requesting your data, we may ask you to prove control of the wallet address, for example by replying from the email address linked to your Stripe Link connection, or by signing a message with your wallet. If we cannot verify a request, we will tell you and explain why.

8.3 Limits

We cannot access, correct or delete (a) data on the blockchain, or (b) information held by third parties such as Privy, Stripe, Bridge, Apple or Google. For those, contact the provider directly. We may decline a request, in whole or part, where the law allows, for example where we must keep information to comply with a legal obligation or to defend a legal claim.

8.4 US state privacy laws

Depending on where you live (including California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Tennessee and other states with comprehensive privacy laws), you may have the right to: know what personal information we collect, use and disclose; access it and receive a portable copy; correct it; delete it; opt out of sale, of sharing for targeted advertising, and of certain profiling; and appeal a refusal. We may fall below the size thresholds at which some of these laws apply, but we honour these requests from everyone anyway.

• We do not sell or share personal information, do not do targeted advertising, and do not profile, so there is nothing to opt out of.
• Sensitive information. We do not collect sensitive personal information as those laws define it, other than what may be inferred from account credentials for Stripe Link. We use that only to provide the service you asked for.
• Categories (California). In the last 12 months we collected: identifiers (wallet address, push token, IP address, email address if you connected Link); commercial and financial information (on-chain transaction and savings data); internet or network activity (API request data); and inferences, none. Sources, purposes and recipients are described in Sections 3 to 5.
• Appeals. If we refuse your request, you may appeal by replying to our decision email with the subject "Privacy appeal". We will respond within 60 days. If the appeal is refused, you may contact your state Attorney General. Tennessee residents can reach the Tennessee Attorney General's Division of Consumer Affairs at tn.gov/attorneygeneral.
• Authorised agents may submit requests on your behalf with written proof of authority. We may still verify your identity directly.
• "Shine the Light" (California Civil Code §1798.83). We do not disclose personal information to third parties for their direct-marketing purposes.
• Do Not Track / Global Privacy Control. The app does not track you across other apps or websites, so these signals have nothing to switch off. We treat a GPC signal on our website as a valid opt-out request.

8.5 EEA, UK and Switzerland

If the GDPR, UK GDPR or Swiss FADP applies to you, you have the right to: access your personal data; have it corrected; have it erased; restrict or object to our processing (including any processing based on legitimate interests); receive it in a portable format; and withdraw consent at any time, without affecting processing before withdrawal. You also have the right to complain to your local data-protection authority (in the UK, the Information Commissioner's Office at ico.org.uk). We would appreciate the chance to address your concern first.

9. Deleting your account

9.1 You can request deletion from the Account tab in the app or by emailing support@locklogistics.net. We will delete your push tokens, notification log, any Stripe Link email and tokens, and any support correspondence we are not required to keep, and we will ask Privy to delete your user record.

9.2 Withdraw your funds first. As explained in the Terms, access to your Smart Account currently depends on your passkey and on Privy's record of it. Deleting your account while assets remain in your Smart Account or in any savings goal may make them permanently inaccessible. Deletion does not unlock a goal or withdraw anything for you. If funds are still locked under a goal's rules, wait until you have withdrawn them before requesting deletion. We may ask you to confirm that you understand this before we act.

9.3 What deletion cannot do. It cannot remove anything from the blockchain (Section 6), and it cannot remove information held by Stripe, Bridge, Apple, Google or other third parties. Contact them directly for that.

10. Security

10.1 The strongest protection in Holdout is structural: we do not hold your keys, your funds, your identity documents or your payment details, so they cannot be taken from us.

10.2 For what we do hold, we use reasonable technical and organisational measures, including encrypted connections (TLS) for all traffic, a database hosted with a provider that encrypts stored data, access restricted to the people who need it, administrator access protected by hashed credentials and short sessions, and keeping Stripe Link tokens on the server only.

10.3 No system is perfectly secure, and we cannot guarantee security. You are responsible for securing your own device, screen lock, and Apple or Google account, which protect your passkey. We will never ask you for a seed phrase, private key, passkey or one-time code.

10.4 If we become aware of a security incident that affects your personal information, we will notify you and the relevant authorities as required by law, including the Tennessee Identity Theft Deterrence Act. Because we may not have an email address for you, notice may be given in the app, by push notification or on our website.

11. Children

The Services are for adults. You must be at least 18 to use them. We do not knowingly collect personal information from anyone under 18, and the Services are not directed to children under 13. If you believe a minor has used the Services, contact support@locklogistics.net and we will delete what we hold.

12. International users

We are based in Tennessee, United States, and our servers and most of our providers are in the United States. If you use the Services from elsewhere, your information will be transferred to, stored and processed in the United States, where data-protection laws may differ from those where you live. Where the law requires a transfer mechanism, we rely on the European Commission's Standard Contractual Clauses and the UK addendum, or on a provider's certification under the EU-US Data Privacy Framework, as applicable. Blockchain data is replicated on computers around the world.

13. Changes to this Policy

We may update this Policy from time to time. We will post the new version with a new "Last updated" date, and for material changes we will give reasonable advance notice in the app or on our website. If a change would let us use information you have already given us in a materially different way, we will ask for your consent where the law requires it. If we ever add analytics, crash reporting, advertising or any new category of data collection, we will update this Policy before it goes live.

14. Contact

Lock Logistics LLC
Rogersville, Tennessee 37857
United States
Mailing address: available on request. Email support@locklogistics.net with the subject "Mailing address"

Privacy requests and questions: support@locklogistics.net (subject "Privacy request")
Security reports: security@locklogistics.net