Policies & terms

1. Introduction

These Terms of Service ("Terms") govern your access to and use of the Lockii platform ("Lockii", "we", "our" or "us"), based in Australia. Lockii provides an online service allowing users to sign up and create rental stores that can be embedded or linked on their websites. These stores allow customers to rent equipment, tools, or other items and access them via automatically generated smart lock codes.

By using Lockii, you agree to be bound by these Terms and our Privacy Policy. If you do not agree, you may not access or use our services.

2. Eligibility

You must be at least 18 years of age to use our services. By registering an account, you confirm you meet this requirement and have the authority to enter into these Terms.

3. Account Registration

You are responsible for all activities under your account. Keep your password secure. You agree not to share account credentials or allow others to access your account.

4. Platform Use and Conduct

Subject to these Terms, Lockii grants you a limited, non-exclusive, revocable, and personal license to access and use the platform solely for business and informational purposes related to rentals.

Unless otherwise expressly indicated by Lockii, all content displayed or made available on the platform, including without limitation, text, images, illustrations, designs, logos, domain names, service marks, software, scripts, and the selection, compilation and arrangement of any of the foregoing is owned by Lockii, its affiliates, licensors and/or other third parties (“Platform Content”). The platform and all Platform Content are protected by copyright, trade dress, trademark, moral rights, and other intellectual property laws in Australia and international jurisdictions. All such rights are reserved.

All registered and unregistered trademarks, logos, and service marks are the property of Lockii and/or their respective owners. Nothing displayed or accessed in connection with the platform shall be construed as granting by implication, estoppel, or otherwise, any license or right to use any trademark, logo, or service mark displayed without the owner’s prior written permission, except as otherwise described herein.

Prohibited Uses

You are fully responsible for your activities while using the platform. You agree to comply with all applicable federal, state, and local laws and regulations. You must not:

• Violate these Terms or other applicable policies;
• Include sensitive personal information about yourself or others in any submission fields;
• Upload any harmful code or malware;
• Attempt to interfere with, disable or gain unauthorised access to Lockii’s infrastructure;
• Use automated scraping tools or similar mechanisms without express permission;
• Reverse engineer, decompile, or attempt to derive source code from the platform, except to the extent that right cannot legally be excluded;
• Circumvent technical, security, or access controls;
• Copy proprietary user interface, assets, or code except as needed to use the platform;
• Impersonate another person or falsely represent affiliation with any entity;
• Use the platform for harassment, illegal activities, or fraud;
• Use Lockii to send spam, bulk unsolicited emails, or any other form of abusive electronic communication;
• Collect or harvest user data for unsolicited marketing or phishing purposes;
• Attempt to do any of the above.

We reserve the right to monitor use of the platform, take legal action for violations, and suspend or terminate access as needed.

You are fully responsible for your activities while using the platform. You agree to comply with all applicable federal, state, and local laws and regulations. You must not:

• Violate these Terms or other applicable policies;
• Include sensitive personal information about yourself or others in any submission fields;
• Upload any harmful code or malware;
• Attempt to interfere with, disable or gain unauthorised access to Lockii’s infrastructure;
• Use automated scraping tools or similar mechanisms without express permission;
• Impersonate another person or falsely represent affiliation with any entity;
• Use the platform for harassment, illegal activities, or fraud;
• Attempt to do any of the above.

We reserve the right to monitor use of the platform, take legal action for violations, and suspend or terminate access as needed.

5. Item Access and Lock Code Generation

Lockii provides automated smart lock code generation for compatible hardware. You acknowledge and accept responsibility for verifying the functionality and safety of your locks. Lockii is not liable for loss, theft, or damage due to improper lock use.

6. Payments and Fees

Users may be charged a monthly subscription or transaction-based fees. All payments are handled through secure third-party payment processors. Fees are non-refundable unless required by law.

Lockii enforces the use of PCI-certified payment providers (e.g., Stripe) for all financial transactions. Any user who bypasses these mechanisms, including but not limited to using manual entry or Mail Order / Telephone Order (MOTO) payments that do not comply with PCI DSS standards, assumes full responsibility and liability for any breach, loss, claim, or regulatory penalty that may arise.

Lockii explicitly disclaims all liability in relation to any user conduct that violates PCI compliance, including MOTO use, and reserves the right to suspend or terminate accounts that fail to adhere to these payment security standards.

You agree to pay all applicable fees for your use of Lockii services in a timely manner. Failure to make timely payments may result in suspension or termination of your access to the platform, and Lockii reserves the right to recover any outstanding debts through appropriate means, including collection agencies or legal action. You are solely responsible for any charges incurred through your account and any applicable taxes, duties, or other governmental charges.

Lockii may update pricing at any time. Users will be notified of any changes that affect their current subscriptions before the renewal date.

Users may be charged a monthly subscription or transaction-based fees. All payments are handled through secure third-party payment processors. Fees are non-refundable unless required by law.

Lockii enforces the use of PCI-certified payment providers (e.g., Stripe) for all financial transactions. Any user who bypasses these mechanisms, including but not limited to using manual entry or Mail Order / Telephone Order (MOTO) payments that do not comply with PCI DSS standards, assumes full responsibility and liability for any breach, loss, claim, or regulatory penalty that may arise.

Lockii explicitly disclaims all liability in relation to any user conduct that violates PCI compliance, including MOTO use, and reserves the right to suspend or terminate accounts that fail to adhere to these payment security standards.

Lockii may update pricing at any time. Users will be notified of any changes that affect their current subscriptions before the renewal date.Users may be charged a monthly subscription or transaction-based fees. All payments are handled through secure third-party payment processors. Fees are non-refundable unless required by law.

Lockii may update pricing at any time. Users will be notified of any changes that affect their current subscriptions before the renewal date.

7. Termination

We may suspend or terminate your access to Lockii at our sole discretion for violation of these Terms or misuse of the platform. You may cancel your account at any time through your account dashboard.

8. Intellectual Property

All content, branding, and software related to Lockii remain our property. You retain ownership of your uploaded content but grant Lockii a worldwide, non-exclusive license to use it for providing and improving our services. Lockii's non-public functionality, documentation, interfaces, and other confidential information remain Lockii's.

A Direct Competitor of Lockii may not access or use the Services without Lockii's prior written consent. A Direct Competitor is an entity whose principal business includes developing or supplying commercial rental-management software substantially similar to the Services. You must not access or use the Services for the primary purpose of benchmarking, monitoring, copying or replicating the Services, or developing a competing software product using Lockii's non-public functionality, documentation, interfaces or confidential information. Lockii may suspend or terminate any account used primarily for that purpose. This is not an exclusivity obligation and does not restrain you from operating a rental business or using other software.

8A. Data Processing Responsibilities

In cases where Lockii acts as a data processor on behalf of another entity, such as a rental store operator who collects customer data through the Lockii platform, that entity is the data controller. As such, the store operator assumes full responsibility for ensuring compliance with all applicable privacy laws, including the Australian Privacy Act and international frameworks such as the GDPR.

It is the responsibility of the data controller to:

• Ensure that appropriate consent has been obtained for the collection and use of personal data;
• Respond to data subject access requests, including deletion, correction, and portability;
• Determine lawful bases for data processing;
• Handle and respond to any data breach or privacy concern arising from their store’s operation.

Lockii does not independently determine the purposes or means of processing personal data collected by store operators and therefore is not liable for any misuse, non-compliance, or unlawful handling of customer data by those parties.

Store operators are required to use the secure identity integrations provided by Lockii for storing sensitive documents or PII, and may not store such data directly within the platform. Any user who circumvents these protections assumes full legal and financial liability for the handling and protection of that data.

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8B. Data Processing Agreement (DPA)

Where Lockii processes personal data on your behalf as a processor (for example, renter booking data), that processing is governed by the Data Processing Agreement on this page, which forms part of these Terms. Use of the Lockii platform as a controller engaging Lockii as a processor constitutes acceptance of that DPA. If you need a countersigned copy, contact privacy@lockii.app.

You remain the controller of your customers' personal data and are responsible for lawful collection, privacy notices, and responding to data subject requests (we assist as described in the DPA). Store operators must use Lockii's approved identity integrations for sensitive documents and must not store identity documents in free-text or unapproved fields.

All content, branding, and software related to Lockii remain our property. You retain ownership of your uploaded content but grant Lockii a worldwide, non-exclusive license to use it for providing and improving our services.

9. Limitation of Liability

To the fullest extent permitted by law, Lockii shall not be liable for any indirect, incidental, special, consequential or punitive damages, or for any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses resulting from:

• Your access to or use of or inability to access or use the platform;
• Any conduct or content of any third party on the platform;
• Any content obtained from the platform; or
• Unauthorised access, use or alteration of your transmissions or content.

In no event shall Lockii’s aggregate liability for all claims exceed AUD $500.

10. Indemnification

You agree to indemnify and hold harmless Lockii and its employees, officers, and affiliates from any claims, damages, liabilities, costs, or expenses arising from your use of the platform or your violation of these Terms.

This includes, but is not limited to, any claims arising from:

• The inaccurate or unintended distribution of smart lock codes,
• Loss, theft, or damage to physical items due to misuse of the lock code feature,
• Any failure on your part to secure or verify the correct usage of access credentials for your rented items,
• Any communication, arrangement, or transaction between you and your customers,
• Any damages or disputes arising from customer actions while using Lockii services,
• Any breach of privacy or data sharing obligations involving PII due to your failure to follow best practices.

Lockii provides the lock code generation system and platform tools as a convenience, but final responsibility for their secure and lawful use lies with you.

Lockii assumes no liability for communications between store owners and their customers. Users of the Lockii platform are fully and solely responsible for any and all actions, content, or outcomes related to their use of the platform.You agree to indemnify and hold harmless Lockii and its employees, officers, and affiliates from any claims, damages, liabilities, costs, or expenses arising from your use of the platform or your violation of these Terms.

This includes, but is not limited to, any claims arising from:

• The inaccurate or unintended distribution of smart lock codes,
• Loss, theft, or damage to physical items due to misuse of the lock code feature,
• Any failure on your part to secure or verify the correct usage of access credentials for your rented items.

Lockii provides the lock code generation system as a convenience, but final responsibility for the secure distribution and use of access credentials lies with you.You agree to indemnify and hold harmless Lockii and its employees, officers, and affiliates from any claims, damages, liabilities, costs, or expenses arising from your use of the platform or your violation of these Terms.

11. Governing Law, Disputes, and Arbitration

These Terms are governed by the laws of Victoria, Australia. Any dispute, controversy, or claim arising out of or in connection with these Terms, including any question regarding their existence, validity or termination, shall be resolved by binding arbitration administered by the Australian Centre for International Commercial Arbitration (ACICA), in accordance with the ACICA Arbitration Rules. The seat of arbitration shall be Melbourne, Victoria. The language of the arbitration shall be English.

You and Lockii agree to waive any right to a trial by jury or to participate in any class action or representative proceeding. The arbitrator shall have the authority to award monetary and injunctive relief only in favour of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party’s individual claim.

Nothing in this section shall prevent either party from seeking urgent equitable relief before a court of competent jurisdiction. If a dispute arises, you agree to first attempt to resolve the matter by contacting Lockii support at support@Lockii.com before initiating arbitration or other proceedings.

These Terms are governed by the laws of Victoria, Australia. Any dispute arising from or relating to these Terms shall be subject to the exclusive jurisdiction of the courts in Melbourne, Victoria. You waive any right to a trial by jury or to participate in a class action.

12. Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable, that provision will be read down to the minimum extent necessary to make it valid and enforceable. If it cannot be read down, it will be severed from these Terms. The remaining provisions will continue in full force and effect.

This Privacy Policy explains how Hazey Creative Pty Ltd trading as Lockii ("Lockii", "we", "us", or "our") collects, uses, shares, and protects personal data when you use Lockii as a merchant: that is, when you create or manage a Lockii account to run a rental business, invite team members, configure stores and booking pages, or otherwise use our platform, website, apps, or related services (the "Services").

Lockii is a self-service rental software platform operated by Hazey Creative Pty Ltd of 55 Collins Street, Melbourne, Victoria, Australia. We provide tools for rental businesses to take bookings, payments, identity checks, messaging, smart-lock access, and related operations on www.lockii.app.

This policy is for merchants and their staff. End customers (renters) should refer to the privacy notice shown at your checkout (or your own privacy policy). Questions for Lockii: privacy@lockii.app or support@lockii.app.

This notice is intended to meet transparency requirements under the Australian Privacy Principles and, where applicable, the EU General Data Protection Regulation (GDPR) and UK GDPR.

1. Who this policy covers

This notice covers personal data about:

• Merchants and account owners: individuals and businesses who sign up for Lockii and operate rental stores on the platform;
• Team members and invited users: staff who access a merchant account with permissions you grant; and
• Website and sales visitors: people who visit Lockii marketing or product pages, request demos, join a referral or partner programme, or contact sales or support.

When your customers book with you, you are typically the organisation responsible for that customer relationship. Lockii processes customer rental data on your behalf as a processor (service provider) so you can run bookings on Lockii. Your obligations to your customers — including providing an appropriate privacy notice at checkout and having a lawful basis — remain yours.

2. Data controller and processor roles

Under the GDPR and UK GDPR, Lockii's role depends on the data:

• Lockii as controller: for merchant account and billing data, team login details, Lockii subscription payments, marketing-site analytics and advertising we operate, referral attribution we operate, support tickets you send to Lockii, and platform security or diagnostic logs we create for our own purposes.
• You as controller; Lockii as processor: for your customers' personal data processed to provide your rental service (bookings, contact details, payment status, verification status, messages, access codes, return photos, GPS or lock events you enable, and related rental records). You decide why that data is collected for the rental; we process it on your documented instructions to operate the Services.

Customer data processing is also governed by our Terms of Service, including the Data Processing Agreement (DPA) in those Terms. You are responsible for having a lawful basis to collect customer data and for the content of privacy notices you show to renters.

For controller processing covered by this policy, Hazey Creative Pty Ltd trading as Lockii is the data controller. Contact: privacy@lockii.app, 55 Collins Street, Melbourne, Victoria, Australia. See also our Data Processing Agreement and Subprocessors.

3. Categories of personal data we collect

Depending on how you use the Services, we may process the following categories:

• Identity and contact data: name, email, phone, business name, company details, and addresses;
• Account and authentication data: invited user emails, roles and permissions, credentials or session tokens, IP address, device and browser information, and security logs;
• Billing and commercial data: plan, invoices, payment status, tax or billing information, and Stripe (or other processor) customer or payment references. Card numbers are handled by our payment provider and are not stored by Lockii;
• Business configuration data: locations, catalogue, pricing, messaging templates, integrations (locks, GPS, identity, analytics tags), and similar settings you enter;
• Usage, diagnostics, and support data: how you and your team use the dashboard and features, performance logs, crash or error reports (including via error-monitoring tools), and content of emails, chats, or call notes you share with Lockii;
• Marketing and attribution data: pages viewed, referrer, campaign or referral identifiers (for example Dub click IDs), approximate location derived from network headers, and cookies or similar technologies on lockii.app; and
• Communications preferences: marketing opt-in or opt-out status and related preferences.

We do not intentionally collect special-category data (such as health or biometric data) about merchants for Lockii's own purposes. If a merchant enables identity verification for renters, facial images or identity documents may be processed solely as processor on that merchant's instructions through approved verification flows — see section 4.

4. Customer data you process through Lockii

To run your rentals, Lockii will process personal data about your customers that you or they provide through your booking pages, widgets, portals, and integrations. That commonly includes contact details, booking and payment metadata, optional identity or insurance verification status, messaging content, pickup/return content (including photos), and location or access-related signals you enable.

Payment card data is handled by Stripe (or another PCI-oriented provider you connect). Identity documents and face-matching, where enabled, are handled through approved verification providers and secure platform flows (for example Stripe Identity or Lockii's verification tooling backed by specialised cloud services). You should not store identity documents in free-text or unapproved Lockii fields.

Where such verification involves biometric data or other special categories under the GDPR, you (as controller) are responsible for ensuring you have a valid lawful basis and any required consent or exception before enabling those features for your renters. Lockii processes that data only as your processor to deliver the feature you configured.

You control retention and deletion of customer records in your account, subject to platform limits and legal holds. Customer privacy requests about a rental should usually be handled by you; we will assist as processor where we hold the relevant data, consistent with our DPA.

5. How we collect information

• Directly from you and your team: signup, settings, billing, support, demo or sales forms, and partner or referral programme participation;
• Automatically: cookies, logs, analytics, attribution technologies, and security signals when you use the Services or visit our marketing sites;
• From your customers and integrations: when bookings, payments, verifications, lock events, GPS updates, or messages flow through Lockii for your store; and
• From service providers: for example Stripe returning billing or Connect account status, or referral platforms confirming attribution events.

6. Purposes of processing

We use personal data to:

• Provide, maintain, host, and improve the Lockii platform for your business;
• Create and manage merchant accounts, team access, and permissions;
• Process Lockii subscription billing and related accounting;
• Host and operate your stores, bookings, payment flows, messaging, access codes, and integrations you enable;
• Provide merchant support (including AI-assisted support tools where enabled, which may process conversation content to generate responses);
• Secure the platform, prevent fraud and abuse, monitor errors, and troubleshoot issues;
• Analyse product and marketing-site usage to improve reliability, features, and our own acquisition funnels;
• Attribute referrals and measure marketing effectiveness (for example via Dub);
• Send product, onboarding, and marketing communications where permitted (you can opt out of marketing emails at any time); and
• Comply with law, enforce our terms, and protect Lockii, merchants, and users.

7. Legal bases for processing (GDPR / UK GDPR)

Where the GDPR or UK GDPR applies to Lockii as controller, we rely on the following lawful bases (Article 6 GDPR):

• Contract (Art. 6(1)(b)): creating and managing your account, providing platform features you request, subscription billing, and authenticating team members so we can perform our agreement with you;
• Legitimate interests (Art. 6(1)(f)): securing and improving the platform, preventing fraud and abuse, error monitoring, understanding aggregated product usage, B2B product communications about the Services you use, and measuring marketing performance in ways that do not override individuals' rights. You may object to processing based on legitimate interests (see section 14);
• Consent (Art. 6(1)(a)): where required — for example certain marketing emails, and non-essential cookies or advertising / analytics technologies on our marketing site in the EEA/UK. You may withdraw consent at any time without affecting prior processing;
• Legal obligation (Art. 6(1)(c)): tax, accounting, regulatory, or other legal requirements we must meet; and
• Processor instructions: when we act as processor for your customer rental data, we process that data under our DPA and your instructions; you remain responsible for the lawful basis applicable to your renters.

We do not use merchant personal data for automated decision-making that produces legal or similarly significant effects about you without human involvement (Article 22 GDPR). AI-assisted support tools help our team respond to requests; they do not solely determine access to Lockii or your contractual rights.

8. How we share information

We share personal data only as needed to run the Services, and with:

• Infrastructure and platform providers: cloud hosting and related AWS services; error monitoring (for example Better Stack);
• Payments: Stripe for Lockii subscription billing and, where you use Connect / customer checkout, for customer payments on your behalf;
• Communications: email delivery (for example Resend), SMS providers for codes and booking notifications you or we send, and in-product support tooling (for example Productlane);
• Analytics, attribution, and advertising: tools we operate on Lockii properties, which may include Datafast (product / marketing analytics), Dub (referral and conversion attribution), and Meta Pixel (advertising measurement on our marketing site). Where these tools are non-essential under applicable law, we rely on consent in the EEA/UK;
• AI model providers: where AI-assisted support or similar features are enabled, conversation content needed to generate a response may be sent to our AI providers under appropriate contractual protections;
• Hardware and verification partners you enable: smart-lock, GPS, identity, or insurance partners configured for your store;
• Your team members according to the permissions on your account;
• Professional advisers and authorities where required by law or to protect rights and safety; and
• A buyer or successor if Lockii is involved in a merger, acquisition, or asset sale, subject to appropriate confidentiality and continued protection of the data.

We do not sell your personal data, and we do not share it with third parties for their own independent marketing. If you install third-party tags (for example Google Analytics or Meta Pixel) on your booking pages, those tools are subject to your configuration and those vendors' policies — you are responsible for using them lawfully and for any consent requirements that apply to your renters.

Mobile information and text messaging. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties. Information shared with service providers acting on our behalf (for example our SMS delivery provider) is used only to deliver the messages you have requested, such as sign-in codes and booking notifications.

9. Cookies and similar technologies

We use cookies and similar technologies on lockii.app and in the product. Broadly:

• Strictly necessary: sign-in, security, session continuity, load balancing, and fraud prevention. These are required for the Services to work;
• Preferences: remembering settings such as language or UI choices where offered; and
• Analytics, attribution, and advertising: understanding how our marketing site and product are used, attributing referrals (including Dub click-id cookies where present), and measuring ads (including Meta Pixel on our marketing site).

Visitors in the EEA and UK see a cookie banner on this marketing site. Analytics, referral attribution (Dub), and advertising (Meta Pixel) load only after Accept. You can change your choice later via Cookie settings in the footer. You can also control cookies in your browser. Blocking essential cookies may prevent sign-in or dashboard features from working.

10. International storage and transfers

Lockii is based in Australia. Personal data may be stored or processed in Australia and in other countries, including the United States and other locations where our providers operate (for example AWS regions, Stripe, Resend, analytics and AI providers).

Where overseas transfers occur, we take steps consistent with the Australian Privacy Principles, including contractual commitments where appropriate. Where the GDPR or UK GDPR applies to a transfer of personal data from the EEA, UK, or Switzerland to a country without an adequacy decision, we use appropriate safeguards — typically the European Commission's Standard Contractual Clauses (and UK International Data Transfer Agreement / Addendum or Swiss equivalents where required), supplemented by transfer risk assessments as needed.

You may request more information about the safeguards that apply to a particular transfer by emailing privacy@lockii.app.

11. Retention

We keep personal data only as long as needed for the purposes described in this policy, including:

• Merchant account data: while your account is active, and for a reasonable period afterwards to support reactivation, disputes, and account closure;
• Billing and tax records: typically up to seven (7) years (or longer if a legal claim or investigation requires it), consistent with Australian accounting and tax practice;
• Security, access, and application logs: for shorter operational periods needed for security, debugging, and abuse prevention (generally months rather than years, unless needed for an investigation);
• Support communications: for as long as needed to resolve your request and maintain a support history; and
• Marketing and attribution identifiers: for the duration of the relevant cookie or campaign window (for example referral click IDs may persist for up to about 90 days), or until you withdraw consent / opt out where that applies.

Customer rental records are retained to provide the Services to you and according to your use of the platform and our DPA. When information is no longer required, we take reasonable steps to delete, anonymise, or de-identify it.

12. Security

We use administrative, technical, and organisational measures designed to protect personal data, including encrypted connections (HTTPS/TLS), access controls and authentication, least-privilege access for staff, monitoring, and payment processing through PCI-oriented providers such as Stripe. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If we become aware of a personal data breach that is likely to result in a risk to individuals, we will assess and notify affected parties and relevant authorities as required by applicable law (including the Australian NDB scheme and, where GDPR applies, Articles 33 and 34).

13. Your rights under Australian law

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you may request access to the personal information we hold about you and request correction of inaccurate information, subject to limited exceptions. Email privacy@lockii.app. We may need to verify your identity before responding.

14. Your rights under the GDPR / UK GDPR

Where the GDPR or UK GDPR applies to our processing of your personal data as controller (for example if you are a merchant, team member, or website visitor in the EEA or UK), you have the right to:

• Access — obtain confirmation of whether we process your data and a copy of it;
• Rectification — correct inaccurate or incomplete data;
• Erasure — ask us to delete your data in certain circumstances ("right to be forgotten");
• Restriction — ask us to limit processing in certain circumstances;
• Portability — receive data you provided to us in a structured, commonly used, machine-readable format, and request that we transmit it to another controller where technically feasible;
• Object — object to processing based on legitimate interests, and to processing for direct marketing (including related profiling);
• Withdraw consent — where processing is based on consent, withdraw it at any time; and
• Lodge a complaint — with your local supervisory authority (see section 16).

To exercise these rights, email privacy@lockii.app. We will respond without undue delay and within one month of receipt (extendable by up to two further months for complex or numerous requests, in which case we will tell you why). We may need to verify your identity and, where someone submits a request on your behalf, their authority.

Some rights are not absolute — for example we may retain data where we have a legal obligation or need it to establish, exercise, or defend legal claims. If we refuse a request, we will explain why and tell you about your complaint options.

If a request relates to your customers' rental data, we will typically redirect or coordinate with you as the controller, unless we must handle it directly under law.

15. Children

Lockii merchant Services are directed to businesses and adults. We do not knowingly collect personal data from children under 16 in connection with merchant accounts. If you believe a child has provided personal data to us, contact privacy@lockii.app and we will take appropriate steps to delete it.

16. Complaints

Privacy complaints: privacy@lockii.app. Complaints are reviewed by Lockii (including Bodhi Hawken or a delegated team member). If you are not satisfied with our response, you may contact:

• In Australia: the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au; or
• In the EEA/UK: your local data protection supervisory authority (for example in the UK, the Information Commissioner's Office at ico.org.uk). A list of EEA authorities is available from the European Data Protection Board.

17. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date above will change when we do. Material updates may be communicated by email or in-product where appropriate. Where a change requires consent under applicable law, we will ask for that consent before the new use applies.

18. Contact us

Privacy requests and complaints:
Controller: Hazey Creative Pty Ltd (trading as Lockii)
Address: 55 Collins Street, Melbourne, Victoria, Australia
Email: privacy@lockii.app
Support: support@lockii.app
Web: www.lockii.app

Subprocessors: lockii.app/subprocessors. Data Processing Agreement: see section below.

If you are in the EEA/UK and have questions about how we handle GDPR rights, email privacy@lockii.app. We will confirm whether an EU/UK representative has been appointed and provide those details on request.

This Data Processing Agreement ("DPA") forms part of the Lockii Terms of Service between Hazey Creative Pty Ltd trading as Lockii ("Lockii", "Processor") of 55 Collins Street, Melbourne, Victoria, Australia, and the merchant customer that accepts the Terms ("Controller", "you").

This DPA applies only where Lockii processes personal data on your behalf as a processor in connection with the Services (for example, personal data about your renters and end customers). It does not apply where Lockii acts as an independent controller (for example, merchant account, billing, or Lockii marketing data) — see our Privacy Policy.

This DPA is intended to satisfy Article 28 GDPR / UK GDPR where those laws apply. It is not legal advice; have counsel review before relying on it for your compliance programme.

1. Definitions

"Applicable Data Protection Law" means the GDPR, UK GDPR, Australian Privacy Act 1988 (Cth) to the extent it applies to the processing, and any other data protection law that applies to the processing under this DPA. Terms such as "personal data", "processing", "controller", "processor", "data subject", and "personal data breach" have the meanings given in the GDPR (or nearest equivalent under Applicable Data Protection Law). "Customer Personal Data" means personal data processed by Lockii on your behalf as processor under this DPA.

2. Roles and scope

You are the controller (or a processor instructing Lockii as a subprocessor) of Customer Personal Data. Lockii is the processor. Lockii will process Customer Personal Data only to provide the Services, as described in the Terms, your configuration of the platform, and your documented instructions (including via the product UI and APIs), and as required by law.

Typical categories of data subjects: your renters, booking contacts, and other individuals whose data you or they submit through booking pages, widgets, portals, messaging, verification, access, GPS, or related features.

Typical types of Customer Personal Data: identity and contact details; booking and payment metadata (not full card numbers, which are handled by payment providers); messaging content; verification status and related metadata; pickup/return content (including photos); access codes and lock/GPS events you enable; and technical logs generated in delivering those features.

Duration: for the term of your Lockii subscription and any post-termination retention required by the Terms, this DPA, or law.

3. Instructions

Lockii will process Customer Personal Data only on documented instructions from you, unless required to do so by Applicable Data Protection Law (in which case Lockii will inform you before processing, unless the law prohibits notice). The Terms, this DPA, and your use of the Services constitute your complete instructions. Additional written instructions require Lockii agreement and may require a change order. Lockii will promptly inform you if, in its opinion, an instruction infringes Applicable Data Protection Law.

4. Confidentiality and personnel

Lockii ensures that persons authorised to process Customer Personal Data are bound by confidentiality obligations and receive appropriate privacy and security training.

5. Security

Taking into account the state of the art, costs, and the nature, scope, context, and risks of processing, Lockii implements appropriate technical and organisational measures to protect Customer Personal Data, including encryption in transit (HTTPS/TLS), access controls, authentication, least-privilege access, monitoring, and use of PCI-oriented payment providers for card data. Details may be provided on request to privacy@lockii.app.

6. Subprocessors

You authorise Lockii to use subprocessors to process Customer Personal Data to deliver the Services. The current list is at lockii.app/subprocessors#customer-data. Lockii will require those subprocessors to meet protections at least as strong as this DPA.

Lockii will update the customer data subprocessors list when it adds or replaces a subprocessor. If you object to a new subprocessor on reasonable data-protection grounds within 15 days of notice (or publication, where notice is given by updating that page and/or email), the parties will discuss in good faith. If unresolved, you may terminate the affected Services as your sole remedy. You are deemed to authorise the customer data subprocessors listed as of the date you accept the Terms or continue using the Services after an update.

7. International transfers

You acknowledge that Customer Personal Data may be processed in Australia, the United States, and other countries where Lockii or its subprocessors operate. Where a transfer from the EEA, UK, or Switzerland requires a transfer mechanism, Lockii will use appropriate safeguards such as Standard Contractual Clauses (and UK / Swiss addenda where required), or an applicable adequacy decision.

8. Assistance with data subject rights

Taking into account the nature of the processing, Lockii will assist you by appropriate technical and organisational measures, insofar as possible, to respond to requests from data subjects exercising rights under Applicable Data Protection Law. If Lockii receives a request relating to Customer Personal Data, it will (unless prohibited by law) redirect the requester to you and/or notify you promptly.

9. Breach notification

Lockii will notify you without undue delay after becoming aware of a personal data breach affecting Customer Personal Data, and will provide information reasonably available to Lockii to help you meet your notification obligations. Lockii's notification is not an acknowledgement of fault or liability.

10. DPIAs and consultations

Lockii will provide reasonable assistance to you with data protection impact assessments and prior consultations with supervisory authorities, insofar as required by Applicable Data Protection Law and relating to Lockii's processing of Customer Personal Data, taking into account the information available to Lockii.

11. Audits

Lockii will make available information reasonably necessary to demonstrate compliance with this DPA. On at least 30 days' written notice, no more than once per 12-month period (unless a competent authority or confirmed breach requires more), you may audit Lockii's relevant controls, or accept a third-party audit report / questionnaire response Lockii provides, provided audits are scoped reasonably, conducted during business hours, subject to confidentiality, and do not unreasonably disrupt Lockii's operations or the security of other customers.

12. Return or deletion

On termination of the Services, at your choice Lockii will delete or return Customer Personal Data (to the extent retained in the Services and reasonably retrievable), unless Applicable Data Protection Law or the Terms require retention (for example, legal holds, billing records Lockii holds as controller, or backups that expire on a rolling schedule). Deletion from active systems will occur within a commercially reasonable period after account closure instructions are completed.

13. Controller responsibilities

You warrant that you have a lawful basis to process Customer Personal Data and to instruct Lockii; that you will not instruct Lockii to process special-category or biometric data unless you have a valid basis under Applicable Data Protection Law and have configured only approved Lockii verification flows; and that your privacy notices to renters accurately describe the processing.

14. Liability

Liability under this DPA is subject to the limitations and exclusions in the Terms, except to the extent Applicable Data Protection Law prohibits limitation of liability for a party's infringement of data protection obligations.

15. Order of precedence and changes

If there is a conflict between this DPA and the Terms regarding processing of Customer Personal Data, this DPA prevails. Lockii may update this DPA to reflect legal or operational changes; material adverse changes will be notified as described in the Terms / Privacy Policy. Continued use after the effective date constitutes acceptance, unless you terminate as permitted under the Terms.

16. Governing law

This DPA is governed by the laws of Victoria, Australia, unless Applicable Data Protection Law requires otherwise for a specific mandatory provision. Contact: privacy@lockii.app.

These Referral Program Terms & Conditions ("Terms") govern participation in the Lockii Referral Program ("Program"). The Program enables approved referrers ("Referrers", "you") to earn referral fees by referring new customers to Lockii using tracked referral links and related tools provided by Lockii or its third-party referral platform, Dub.

By accessing, promoting, or participating in the Program, you agree to be bound by these Terms, as updated from time to time.

1. About Lockii

Lockii is an automated rental software platform operated by:

Hazey Creative Pty Ltd (trading as Lockii)
55 Collins Street, Melbourne, Victoria, Australia
Email:hello@lockii.appWebsite:https://www.lockii.app

2. Definitions

In these Terms, unless the context requires otherwise:

• Dub means the third-party referral tracking and attribution platform used by Lockii to administer the Program.
• Referred User means a person or business that has not previously engaged Lockii and who signs up through a valid referral.
• Referral Link means a unique, trackable link generated through Dub and assigned to a Referrer.
• Referral Fee means the commission payable to a Referrer for qualifying referrals.
• Referral Event means the successful completion of payment by a Referred User in accordance with these Terms.

3. Eligibility & Enrollment

3.1 Participation in the Program is open to individuals and businesses approved by Lockii.

3.2 Lockii may approve or reject any application to participate in the Program at its sole discretion.

3.3 Referrers must ensure that all information provided to Lockii and/or Dub is accurate and kept up to date.

3.4 The Program is non-exclusive. Both Lockii and Referrers may engage in similar arrangements with third parties.

4. Referral Relationship

4.1 Referrers may promote Lockii for the purpose of introducing new users to Lockii’s automated rental software.

4.2 A referral will only be considered valid where:

• the Referred User clicks a Referral Link or is otherwise tracked by Dub;
• the Referred User creates an account with Lockii within 60 days of the referral interaction; and
• the Referred User completes payment for their Lockii account.

4.3 Lockii is not obligated to accept any Referred User and may reject or terminate accounts at its discretion.

5. Permitted Referral Methods

5.1 Referrals must primarily be made using Referral Links provided through Dub.

5.2 Permitted referral methods include:

• Referral links embedded on websites, blogs, or landing pages;
• Referral links shared via email to recipients who have expressly consented to receive such communications;
• Referral links shared on social media, forums, or online communities where the content represents a genuine recommendation and not misleading advertising;
• Direct messaging where lawful and consent-based.

5.3 All referral activity must be transparent, honest, and compliant with applicable advertising, consumer protection, and spam laws.

6. Prohibited Conduct & Traffic Sources

Referrers must not:

• Use spam, unsolicited bulk messages, or purchased email lists;
• Use banner networks, hit farms, traffic exchanges, or similar schemes;
• Use desktop or mobile adware, forced redirects, or pop-ups;
• Display Lockii content or open merchant windows without a direct, user-initiated click;
• Engage in misleading, deceptive, or false representations;
• Impersonate Lockii or suggest an official partnership beyond participation in the Program.

6.1 Paid Advertising Restrictions

• Referrers may not send paid Google Ads or Bing Ads traffic directly to a Referral Link.
• Paid traffic from other platforms may be permitted provided it complies with these Terms and uses approved creative.

6.2 Keyword Restrictions

Referrers must not bid on, or use in paid search, any keywords including or similar to:

• Lockii
• Contactless Rental
• Self-Service Rental Software
• Self-Service Rental
• Rental Software
• Self Service
• Automated Rental Software

7. Fraud & Abuse

7.1 Fraud is strictly prohibited.

7.2 Fraud includes, but is not limited to:

• Artificially generated traffic;
• Bots, scripts, iframes, or automated clicks;
• Manual page refreshing for commission generation;
• Self-referrals or circular referrals;
• Any attempt to manipulate Dub’s tracking system.

7.3 Any suspected fraud may result in immediate termination from the Program and forfeiture of all unpaid Referral Fees.

8. Referral Fees & Commission Structure

8.1 Subject to these Terms, Referrers are eligible to earn:

25% of revenue generated by each Referred User for Lockii’s automated rental software, for a maximum period of two (2) years from the Referred User’s first successful payment.

8.2 Referral Fees are calculated and tracked automatically via Dub.

8.3 Only revenue actually received by Lockii (excluding refunds, chargebacks, taxes, or fees) is commissionable.

9. Payments

9.1 Referral Fees are payable only upon the occurrence of a valid Referral Event.

9.2 Payments will be processed based on Dub’s tracking and reporting data.

9.3 Lockii may require Referrers to submit tax or payment details through Dub or another designated system before payments are released.

9.4 Payment timing, thresholds, and methods may be governed by Dub’s platform rules in addition to these Terms.

10. Changes to the Program

10.1 Lockii reserves the right to:

• modify Referral Fee rates;
• change permitted referral methods;
• update Program rules or eligibility requirements.

10.2 Changes will apply prospectively and may be communicated via the website, Dub dashboard, or email.

11. No Agency or Partnership

11.1 Participation in the Program does not create any partnership, joint venture, employment, agency, or fiduciary relationship.

11.2 Referrers have no authority to bind Lockii or make representations on its behalf.

12. Privacy & Data

12.1 Lockii handles personal information in accordance with its Privacy Policy, available at:
https://www.lockii.app/licenses

12.2 Referrers must comply with all applicable privacy and data protection laws.

13. Indemnity

You agree to indemnify and hold harmless Lockii from any loss, damage, liability, or expense arising from:

• your breach of these Terms;
• your referral activities;
• any unlawful, misleading, or negligent conduct by you.

14. Term & Termination

14.1 Participation in the Program commences upon acceptance and continues until terminated.

14.2 Either party may terminate participation at any time, with or without notice.

14.3 Upon termination:

• no Referral Fees will accrue for Referral Events occurring after termination;
• Referral Fees earned prior to termination will be honoured, subject to compliance with these Terms.

15. Severability

If any provision of these Terms is held invalid or unenforceable, that provision will be severed and the remainder will continue in full force.

16. Governing Law

These Terms are governed by the laws of Victoria, Australia, and you submit to the exclusive jurisdiction of its courts.

By participating in the Lockii Referral Program, you acknowledge that you have read, understood, and agreed to these Terms.