Privacy Policy

Effective date: 5 March 2026

Signoff: J. Hinson

At eLocker we offer solutions for businesses to manage their locker inventory and to allocate those lockers across their workforce and network securely. We take pride in the quality of our products and services and our high business standards; this extends to privacy and safeguarding your personal data. This policy describes the information we collect or you shared with us when you visit our website (regardless of where you visit it from), or use any of our services, as well as how that data is used, stored and safeguarded, and your choices regarding this information.

Scope

This policy outlines how we at eLocker collect and process your personal data through your use of our website (the “Website”), as well as the eLocker Manager Platform and associated services (collectively the “Services”), including any data you may provide us when you create an account, use the eLocker Manager Platform, our services or interact with us in any way.

eLocker provides end-to-end electronic locker solutions to businesses active in a wide range of sectors. Our Website and Services are not intended for personal use or for use by children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other policy on data processing or other notices we may provide on specific occasions so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Data controller and contact details

In all instances where we act as the data controller, for the purposes of this privacy policy “eLocker”, “we”, “us” or “our” refers to eLocker Limited. Our details are as follows: eLocker Limited, Nene House, Sopwith Way, Daventry, NN11 8EA, United Kingdom.

In most cases we will act as a data processor, in particular, where your information has been provided to us by your employer (or another third-party) as a customer of eLocker.

How to contact us about your rights and data

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us by email at compliance@elocker.com.

We are regulated by the Information Commissioner’s Office and you have the right to make a complaint at any time to them. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Third-party links

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our Website, we encourage you to read the privacy policy of every website you visit, connect with, or are referred to.

Information collected about you

We have set out below the personal data about you we may collect, use, store and transfer when you interact with us through eLocker. Personal data means any information from which you can be identified; it does not include information we collected on an anonymous basis.

• Identity & Contact Data: includes first name, last name, email address, company name, job title and telephone.
• Financial & Transaction Data: includes, where you opt to pay using a company payment card, your payment card details, billing address and purchase history — we do not knowingly collect or process personal card details.
• Profile Data: includes your username and password, details of your eLocker Manager account, your company name, job title, and, if you are issued one by your employer, the unique identification number (card ID) of your access card.
• Usage Data: includes information created about you through your use of our Services, in particular eLocker Manager, such as unique identifiers and activity logs.
• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website or Services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties, other interactions with us, such as feedback to surveys or with our technical support or customer services teams, as well as your communication preferences.

We also collect, use and share aggregated data about you. This includes statistical or demographic data, which could be derived from your personal data but is not considered personal data in its own right as this data on its own would not allow anyone to directly or indirectly reveal your identity. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How your data is collected

We use different methods to collect data from and about you, including:

Direct interactions. You may give us your Identity, Contact, Financial, Profile, Marketing and Communications Data by interacting with us through our Website or Services, filling in forms or completing any registration process, or by corresponding with us. This includes personal data you provide when you create an account on eLocker Manager; purchase any of our products and Services; subscribe to any of our mailing lists or request marketing; select your marketing and communications preferences; complete a survey; or give us feedback or contact us.

When using the Services. Through your use of our Services, in particular eLocker Manager, we will collect, process and store your Usage Data. Where your employer has registered you to our Service through eLocker Manager, we may also receive your Profile Data when you use the Service (such as when you use your unique access card to access an eLocker).

Automated technologies or interactions. As you interact with both our Website and Services, we automatically collect various information about you, such as the device you use, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. We will receive Technical Data from analytics providers such as Google, advertising networks and search information providers; and Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as our third-party payment processors, or social media platforms such as LinkedIn where you sign up to eLocker through referral from these platforms.

How we use your information

We collect, process, store and disclose personal data for a variety of different reasons, but in all cases when the law allows us to. Whether you are subject to the General Data Protection Regulation (“GDPR”) or the UK Data Protection Act 2018, the law requires that companies processing personal data set out the specific lawful basis on which they process that data. For the personal data identified in this policy where we act as the data controller, we rely on the following lawful bases:

• Consent: we use your consent as a legal basis for processing your personal data for the purposes of marketing communications, in particular where you register your interest with us through our Website or otherwise. You have the right to withdraw consent at any time.
• Contractual obligations: where we need to perform the contract we are about to enter into or have entered into with your employer.
• Regulatory or legal obligations: where we need to comply with a legal obligation.
• Legitimate interests: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, including marketing activities, communicating with you, verifying the accuracy of data, network and information security, fraud prevention, improving our Website and Services, the management of queries and claims, and the establishment and defence of our legal rights.

Where we act as a data processor on behalf of our customers, we will predominantly rely on contractual obligations, legitimate interests and legal obligations as justification for processing your data.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Consent

When you register your interest on our Website, you are invited to consent to receiving marketing and other promotional information from us. You may withdraw this consent at any time by contacting us. Withdrawing consent will not prevent us from sending service messaging about eLocker Manager (such as planned downtime, upgrades, patches or changes to our terms and policies).

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what may be of interest to you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased a subscription and you have not opted out.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message or by contacting us. Where you opt out, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration, product or service experience, or other transactions.

Cookies and other technologies

Cookies are small data files used to collect and store information about you. We use them on eLocker or on our website for the smooth and safe operation of eLocker and our website; to manage your preferences and remember you for future visits; and to analyse how you use eLocker and our website in order to continually make improvements.

The majority of these cookies are linked to your browser session (session cookies) and disappear once you close your browser; others remain on your device for a longer period (persistent cookies). For further information about the cookies we use, please see our Cookie Policy.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioural metrics, heatmaps and session replay to improve and market our products and services. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Information sharing and disclosure

Sharing with our partners

We use a number of external third parties who help us provide eLocker and our services. Currently, we use the following trusted partners:

• AWS: our cloud provider.
• Office 365 and Google Drive: for our working environments.
• ActiveCampaign: to help us send targeted marketing and advertising and to manage your consent preferences.
• Google Analytics: to help us analyse how users interact with eLocker, which we use to improve our products and services.

International transfers

Unless identified, your data is hosted and processed within the UK or the EEA. Where we use a third party located outside the UK or the EEA, we ensure that any transfers are done on the basis of compliant transfer mechanisms.

How we safeguard your data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know; they will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your data, your rights

As a citizen of the UK, or a country within the EEA, you have a wide range of rights with regards to your data under the GDPR or the UK Data Protection Act 2018. You can enforce your rights by contacting us, or in most cases by deleting your account and/or by ending your use of our Website, products or Services. Where we are acting as a data processor, you should enforce your rights through your employer.

• Right to correction: if you believe any of the information on your profile is inaccurate, you have a right to request that we correct it.
• Right to copies of your data: you have a right to request a copy of the information we hold about you, along with an explanation of why we process it. We provide this free of charge for a first request, but may charge reasonable administrative costs for further requests.
• Right to erasure: you have a right to request the deletion of your data at any time. We will consider the request carefully and reply with an explanation of any data we are required to retain by law or for our own legitimate reasons.
• Right to object or complain: you have a right to complain about how we process your data to our principal Data Protection Authority, the Information Commissioner’s Office (Wycliffe House, Water Lane, Wilmslow, SK9 5AF). Should you have any concerns, we invite you to first submit those questions to compliance@elocker.com.

Updates to our policy

As we further enhance our Website, our Services and your eLocker experience, we may make changes to this policy from time to time. If we make any major changes, or any changes which directly affect the services provided to you or the data collected or processed by us, we will notify you by a prominent banner on our website or within eLocker Manager. We encourage you to periodically review this policy for the most up to date version.