Terms, Privacy &
Confidentiality.

Terms & Conditions

1. Acceptance and scope

By accessing, browsing, installing, creating an account on, searching, creating a Lock, ordering a report, activating Monitor, requesting or completing verification, accepting a mutual verification request, making a payment, or otherwise using Lockily, you confirm that you have read, understood and agreed to these Terms, the Privacy Statement and the NDA / Confidentiality Agreement.

If you do not agree, do not use Lockily. Where an in-product checkbox or consent control is presented, selecting it constitutes an electronic acceptance of the documents linked to that control. Continued use after an effective update constitutes acceptance to the extent permitted by applicable law.

2. Lockily operators and contracting entity

References in these Terms to “Lockily”, “Lockily App”, “we”, “us” or “our” mean the applicable regional operator and, where the context requires, its affiliates, licensors, contractors, service providers, personnel, directors, officers, agents and technology partners. For jurisdictions not expressly identified above, the applicable operator is the entity identified within the service, transaction record, payment page or other jurisdiction-specific notice presented to the user.

3. Eligibility and adult-only use

Lockily is intended only for persons aged 18 years or older who have legal capacity to enter into a binding agreement. By using Lockily, you represent that you are at least 18 and legally competent to agree to these Terms. Lockily may restrict, suspend or terminate an account where age, identity, capacity, safety or legal compliance is in doubt.

4. Definitions

• “Lock” or “Lock-in” means a user-submitted personal relationship claim, status declaration or relationship-stage assertion associated with a phone number.
• “Subject” means the person or phone number about whom a search, Lock, Monitor, verification or report relates.
• “Relationship Signal” means information generated from activity such as searches, Locks, verification events, monitoring events, timing patterns and other service activity.
• “Full Report” means a paid or otherwise authorized compilation of Lockily relationship signals and contextual information.
• “Monitor” means a feature that checks for relevant changes and may generate alerts. Monitor is not a guaranteed real-time surveillance service.
• “Verified” means only that the particular verification procedure expressly described by Lockily was completed. A verification badge does not independently prove that a relationship exists, is exclusive, is truthful in every respect, or that any person has acted wrongly.
• “User Content” means information, claims, selections, notes, relationship details, verification responses, complaints or other information submitted by a user.

5. Nature of the service

Lockily is a relationship-status intelligence and user-signal platform. It organizes and presents user activity and user-submitted claims associated with phone numbers. Lockily is not a government registry, marriage registry, credit bureau, licensed private investigator, law-enforcement database, dating agency, background-check provider, fidelity-testing service, medical service, legal service or professional counselling service.

A Lock is a claim made by a user. Search volume is activity, not proof. A verified phone indicates completion of the stated phone-control verification method, not proof of the underlying relationship claim. A mutually confirmed relationship indicates that both sides completed the applicable confirmation flow; it does not establish exclusivity, duration, legal marriage, monogamy, fidelity or the absence of other relationships.

6. No guarantee of truth, completeness or outcome

Lockily does not warrant that any report, Lock, search count, relationship stage, signal, notification, verification, monitor event, historical entry or user-submitted statement is complete, current, accurate, exclusive, genuine, legally admissible or sufficient for any personal decision. Data can be incomplete, delayed, disputed, duplicated, inaccurate, maliciously submitted, affected by number reassignment, affected by user error, or changed after a report is generated.

You remain solely responsible for evaluating the context of any information obtained through Lockily and for independently verifying information before acting on it. You agree not to treat a Lockily signal as a definitive finding of cheating, marriage, fraud, abuse, criminal conduct, sexual activity, exclusivity or any other wrongdoing.

7. Truthful use and user warranties

When you create a Lock, submit relationship information, request mutual verification, make a correction request or otherwise provide information about another person, you represent and warrant that:

• the submission is made honestly and in good faith;
• you are personally connected to the relationship claim you submit and are not creating fictional or proxy claims;
• you are not impersonating another person;
• you are legally entitled to provide the information;
• the information is not knowingly false, fabricated or materially misleading;
• your purpose is lawful and not harassment, stalking, intimidation, retaliation, extortion, discrimination, blackmail, public shaming or coercive control.

You are responsible for User Content you submit and for consequences arising from unlawful or false submissions. Lockily may preserve relevant records, restrict access, annotate data, remove content, cooperate with lawful requests or take protective action when misuse is suspected.

8. Prohibited conduct

You may not use Lockily to:

• harass, stalk, threaten, intimidate, blackmail, extort, shame, dox or endanger any person;
• submit false Locks, manipulate counts, coordinate fake activity, repeatedly search for the purpose of manufacturing a signal, or create accounts to distort the service;
• impersonate another person or falsely claim control of another person's phone number;
• use Lockily in employment, housing, lending, insurance, immigration, education, law-enforcement, eligibility, credit or other high-impact decision making;
• scrape, crawl, index, copy, harvest, resell, mirror, reverse engineer or systematically extract Lockily data except as expressly authorized in writing;
• attempt to discover the identity of a private claimant, Monitor subscriber or other user;
• circumvent access controls, rate limits, payment controls, verification controls or security measures;
• upload malware, attack infrastructure, probe vulnerabilities without authorization or interfere with the operation of the service;
• use Lockily in violation of any applicable law, court order, regulation or third-party right.

9. Account security and credentials

You are responsible for keeping passwords, recovery codes, device sessions and other credentials secure. You accept responsibility for actions taken through your account unless applicable law provides otherwise. Notify Lockily promptly through the available support channel if you believe an account or recovery credential has been compromised.

Lockily may require renewed verification, device confirmation, password reset or other security steps. Lockily may invalidate sessions, rotate credentials, suspend access or restrict functionality where compromise, automated abuse, payment fraud or unusual activity is detected.

10. Verification

Verification methods may include device verification, inbound or outbound SMS, WhatsApp verification, carrier or number-control checks, partner confirmation, document review, manual review, payment verification or other methods. The meaning of a verification badge is limited to the verification process expressly described next to that badge.

Lockily may change, withdraw or require re-verification of a verification method where technology, fraud risk, phone-number reassignment, provider rules or legal requirements change. No verification process is guaranteed to prevent impersonation or fraud.

11. Search, reports and signal strength

Lockily may use automated logic to aggregate activity and assign descriptors such as low, active, elevated, strong, verified, conflicting or similar signal labels. Such labels are informational summaries, not factual findings or legal determinations. Search counts can reflect curiosity, repeated activity, mistaken identity, number recycling, popularity, harassment attempts or other benign or adverse causes.

Lockily may change weighting, de-duplication rules, time windows, anti-manipulation controls and reporting logic without notice when needed to improve integrity, security, reliability or legal compliance.

12. Monitor and notifications

Monitor is an alerting feature, not continuous surveillance and not an emergency service. Notifications can be delayed, duplicated, suppressed, missed or unavailable because of network conditions, device settings, browser restrictions, provider outages, account status, data delays or technical error. Lockily does not guarantee that every event will be detected or that every alert will be delivered before a user independently learns of an event.

13. Payments, pricing and digital products

Paid features may include Full Reports, Monitor, verification-related products and other digital services displayed in the application. Prices, currencies, promotional prices and payment methods appear before purchase. Payment processing may be provided by third-party processors including Stripe, Stanbic IBTC and, when enabled, Paystack or other providers.

Lockily does not receive or store full card numbers when card details are entered directly into a hosted payment processor. Payment processors operate under their own terms and privacy practices. Lockily may receive transaction identifiers, status, amount, currency, limited payment-method metadata, risk information and settlement information required to fulfil or reconcile an order.

Digital access may be delivered immediately after confirmed payment. Except where applicable law requires otherwise, a completed digital product that has been delivered, unlocked, generated or activated is non-refundable. Lockily may issue refunds, credits or reversals in its discretion for confirmed duplicate billing, technical non-delivery or other circumstances it determines appropriate. Chargebacks, reversed payments, payment fraud or unpaid balances may result in suspension or revocation of the associated entitlement.

Where Monitor is sold as a one-time activation, it is not a recurring subscription. A recurring subscription exists only where the checkout clearly states recurring billing, billing interval, renewal terms and cancellation method.

14. Taxes, bank charges and third-party fees

You are responsible for taxes, bank charges, foreign-exchange charges, card-issuer charges, telecommunications charges, data charges and other third-party costs imposed on you, except where applicable law assigns such costs to Lockily. A statement that Lockily does not add a payment fee does not mean your bank, card issuer, mobile operator or payment provider will not impose its own charge.

15. User Content licence

You retain ownership of rights you lawfully hold in User Content. By submitting User Content, you grant the applicable Lockily operator a non-exclusive, worldwide, royalty-free, transferable and sublicensable licence, for the period reasonably required to operate the service and meet legal obligations, to host, store, reproduce, normalize, format, analyze, aggregate, de-identify, display in permitted form, moderate and otherwise process that content for service delivery, fraud prevention, safety, dispute handling, legal compliance, product improvement and enforcement of these Terms.

This licence does not authorize Lockily to publicly reveal a private claimant's identity merely because another user searches the same number. Any disclosure remains subject to the Privacy Statement and applicable law.

16. Intellectual property

Lockily's software, branding, design, interfaces, databases, report layouts, scoring methods, documentation, graphics, trademarks, logos, trade dress and proprietary technology are owned by or licensed to the applicable Lockily operator and are protected by intellectual-property laws. Except for the limited right to use the service in accordance with these Terms, no ownership or licence is granted.

You may not copy, modify, distribute, sell, license, create derivative products from, reverse engineer, decompile or commercially exploit Lockily technology or proprietary report structures except where such restriction is prohibited by applicable law.

17. Third-party services and availability

Lockily depends on telecommunications providers, cloud hosts, database providers, payment processors, browser vendors, app platforms, domain providers, analytics, security systems and other third parties. Lockily is not responsible for third-party outages, acts, omissions, terms, decisions, delays, security incidents or service changes outside Lockily's reasonable control.

Lockily may add, modify, suspend or remove features and may perform maintenance without prior notice. Access is provided on an “as available” basis.

18. Moderation, complaints, corrections and subject requests

Lockily may investigate reports of false, abusive, misleading, unlawful or improperly submitted information. Available remedies can include annotation, restriction, temporary suppression, deletion, account suspension, preservation of records, request for verification, or other action. Lockily is not required to resolve a personal relationship dispute or determine which person is telling the truth.

A person whose phone number appears in Lockily may request review, correction, restriction or other action through the legal/privacy support channel. Lockily may require reasonable proof of identity or control of the relevant phone number before acting. Requests can be limited where disclosure would infringe another person's privacy, expose a private claimant, compromise security, interfere with a legal obligation, prejudice fraud prevention or conflict with lawful retention requirements.

19. Suspension and termination

Lockily may suspend, restrict or terminate an account, Lock, Monitor, report access, payment entitlement or verification status where Lockily reasonably believes there is fraud, abuse, legal risk, false information, payment reversal, security compromise, violation of these Terms or danger to another person. Lockily may preserve information after termination where reasonably necessary for fraud prevention, legal compliance, accounting, disputes, enforcement, security and protection of rights.

20. Emergency and safety disclaimer

Lockily is not an emergency, domestic-violence, mental-health, medical, law-enforcement or crisis-response service. If you believe someone is in immediate danger, contact the appropriate emergency service, law-enforcement authority, medical provider or qualified support organization. Do not rely on Lockily to prevent harm or deliver emergency warnings.

21. Disclaimer of warranties

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, LOCKILY, THE LOCKILY APP, PEYGO INTEGRATED SERVICES LTD, INGLE MEET AND THEIR AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, CONTRACTORS, AGENTS, LICENSORS AND SERVICE PROVIDERS PROVIDE THE SERVICE, REPORTS, SIGNALS, CONTENT, MONITORING, VERIFICATION AND SOFTWARE “AS IS” AND “AS AVAILABLE”, WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED OR STATUTORY.

WITHOUT LIMITING THE FOREGOING, NO WARRANTY IS GIVEN AS TO ACCURACY, COMPLETENESS, TIMELINESS, EXCLUSIVITY, IDENTITY, TITLE, NON-INFRINGEMENT, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, CONTINUOUS AVAILABILITY, SECURITY, ERROR-FREE OPERATION, DELIVERY OF ALERTS, SUCCESSFUL PAYMENT PROCESSING, OR THE TRUTH OF USER-SUBMITTED CLAIMS.

22. Limitation of liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, LOCKILY, THE LOCKILY APP, PEYGO INTEGRATED SERVICES LTD, INGLE MEET AND THEIR RELATED PERSONS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE, CONSEQUENTIAL OR ENHANCED DAMAGES; LOSS OF PROFITS, REVENUE, BUSINESS, OPPORTUNITY, GOODWILL OR DATA; REPUTATIONAL HARM; EMOTIONAL DISTRESS; RELATIONSHIP LOSS; PERSONAL DISPUTES; THIRD-PARTY CONDUCT; OR DECISIONS MADE IN RELIANCE ON A LOCK, REPORT, SEARCH, SIGNAL, VERIFICATION OR NOTIFICATION.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE TOTAL AGGREGATE LIABILITY OF THE APPLICABLE LOCKILY OPERATOR FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THE SERVICE SHALL NOT EXCEED THE GREATER OF (A) THE AMOUNT YOU ACTUALLY PAID TO LOCKILY FOR THE SPECIFIC PAID SERVICE GIVING RISE TO THE CLAIM DURING THE THREE MONTHS BEFORE THE EVENT, OR (B) THE EQUIVALENT OF US$25.

Nothing in these Terms excludes or limits liability that applicable law does not permit to be excluded or limited. Nothing in these Terms removes non-waivable statutory consumer rights.

23. Release relating to user disputes

To the maximum extent permitted by law, you release Lockily, Peygo Integrated Services LTD, Ingle Meet and their related persons from claims arising solely from disputes between you and another user, claimant, Subject, partner or third party, including disputes concerning the truth, interpretation, exclusivity or consequences of a relationship claim, except to the extent a claim cannot lawfully be released.

24. Indemnity

To the maximum extent permitted by law, you agree to defend, indemnify and hold harmless Lockily, Peygo Integrated Services LTD, Ingle Meet and their affiliates, officers, directors, employees, contractors, licensors, processors and agents from third-party claims, losses, liabilities, damages, judgments, penalties, costs and reasonable legal expenses arising from or relating to your User Content, your false or unlawful claim, your misuse of a report, your violation of another person's privacy or rights, your prohibited conduct, your breach of these Terms or NDA, or your violation of applicable law.

This indemnity does not apply to the extent a claim results from conduct for which applicable law does not permit indemnification.

25. Confidentiality obligations

Non-public Full Report data, private relationship intelligence, private claimant information and other account-only information are subject to the NDA / Confidentiality Agreement below. A violation may result in immediate suspension, termination and legal remedies available under applicable law.

26. Governing law and disputes

For users whose contracting operator is Peygo Integrated Services LTD in Nigeria, these Terms are governed by the laws of the Federal Republic of Nigeria, without prejudice to mandatory rights that apply by law. Subject to any mandatory consumer forum, disputes that cannot be resolved informally may be brought before a court of competent jurisdiction in Nigeria.

For users whose contracting operator is Ingle Meet in the United States, these Terms are governed by the laws applicable to Ingle Meet's United States operations, without prejudice to mandatory consumer rights and conflict-of-law rules that cannot lawfully be waived. Where legally permissible, disputes may be brought in a court of competent jurisdiction associated with the applicable U.S. operator.

Before filing a non-emergency civil claim, you agree to provide a written description of the dispute through Lockily's published legal/support channel and allow a reasonable opportunity for informal resolution. This does not prevent urgent applications, statutory complaints, regulatory reports or any right that cannot lawfully be restricted.

27. Electronic communications

You consent to receive service-related notices, legal updates, receipts, security notices, verification messages and account communications electronically through the app, web interface, phone, WhatsApp, SMS or other contact method you provide or initiate, subject to applicable law. Marketing communications, where used, remain subject to applicable consent and opt-out requirements.

28. Changes to the service and Terms

Lockily may update these Terms as the service, law, payment methods, verification systems or risk controls change. Material changes will be communicated through the service or another reasonable method when required. The effective date at the top of this document identifies the current version.

29. Assignment, severability, waiver and entire agreement

You may not transfer your account or assign these Terms without written consent. The applicable Lockily operator may assign these Terms in connection with a restructuring, financing, merger, acquisition, sale of assets or transfer of the Lockily business, subject to applicable law. If any provision is found unenforceable, it will be limited or severed to the minimum extent necessary and the remainder will continue in effect. Failure to enforce a provision is not a waiver. These Terms, the Privacy Statement, the NDA / Confidentiality Agreement and any transaction-specific terms constitute the entire agreement concerning the subject matter they cover.

30. No agency, fiduciary or professional relationship

Your use of Lockily does not create an employment, agency, partnership, joint venture, fiduciary, attorney-client, counsellor-client, investigator-client or other professional relationship between you and Lockily, Peygo Integrated Services LTD or Ingle Meet.

Privacy Statement

1. Who controls your information

For users located in Nigeria, Peygo Integrated Services LTD operates Lockily in Nigeria and acts as the primary Lockily entity responsible for the service relationship, subject to the allocation of responsibilities among service providers and applicable law. For users located in the United States, Ingle Meet operates Lockily in the United States and acts as the primary Lockily entity responsible for the service relationship, subject to applicable law.

Because Lockily uses shared technical infrastructure and third-party vendors, information may be processed by the applicable operator, affiliated operators and contracted service providers where necessary to provide, secure, support and administer the service.

2. Information Lockily collects or receives

Account and identity data

• first name or profile name;
• phone number and canonical country/dialling information;
• password-derived authentication data, session identifiers and recovery information;
• age confirmation and legal-consent records;
• verification status, verification method, timestamps and related verification metadata.

Relationship and claim data

• phone numbers searched, Locked, monitored or invited for mutual confirmation;
• relationship stage, relationship start date, age-range selection, gender selection and private nickname where provided;
• Lock status, verification state, mutual confirmation state and activity timestamps;
• claims, corrections, disputes, safety reports and related case information.

Search, report and activity data

• search events and timestamps;
• aggregate relationship signals and counts;
• report generation, purchase, access and entitlement records;
• Monitor activation and notification activity;
• interaction data used to prevent repeated manipulation, abuse or fraud.

Payment and transaction data

• order ID, product, amount, currency and payment status;
• payment provider and provider reference;
• limited payment-method or reconciliation metadata received from processors;
• virtual-account information where generated for bank transfer.

Card numbers and card security codes entered directly into a hosted payment page are processed by the payment provider, not stored by Lockily.

Device, technical and security data

• IP address, browser type, operating system, device and session information;
• timestamps, error logs, rate-limit data and security events;
• cookies, local storage, PWA/service-worker information and similar technologies used for authentication, preferences, reliability and security;
• fraud, bot, abuse and integrity signals.

Communications

Lockily may process communications sent to support, legal, privacy, dispute, WhatsApp, SMS or verification channels, together with contact details and metadata necessary to respond and maintain records.

3. Information about people who do not have a Lockily account

A Lockily user may search, Lock or monitor a phone number belonging to a person who has not created a Lockily account. Lockily may therefore process a phone identifier and related aggregate activity concerning a non-user Subject. Lockily does not treat the existence of a Lock as proof that the Subject has consented to or confirmed the underlying claim.

Lockily limits what other users receive to the product's permitted relationship signals and does not disclose a private claimant's name, password, private nickname, account credentials or direct identity merely because another person searches the same Subject number.

4. How Lockily uses information

Lockily processes information to:

• create and authenticate accounts;
• normalize phone numbers and maintain account identity;
• accept, store and manage Locks and mutual verification requests;
• perform searches and generate relationship-status signals and reports;
• operate Monitor and notifications;
• verify phone control, device control, payment status and relationship confirmations where those features are used;
• process, reconcile and fulfil paid orders;
• prevent duplicate activity, fraud, bots, account compromise and manipulation of public signals;
• investigate abuse, false claims, safety reports and disputes;
• improve product reliability, performance, integrity and user experience;
• maintain audit, accounting and transaction records;
• comply with legal obligations, lawful requests and enforcement requirements;
• establish, exercise or defend legal rights.

5. Lawful bases and sensitive information

Where applicable law requires a lawful basis, Lockily relies on one or more bases appropriate to the specific processing, which can include performance of a contract, consent, legitimate interests, compliance with legal obligations, protection of vital interests and establishment or defence of legal claims.

Lockily's legitimate interests can include providing requested relationship-intelligence functionality, protecting users and infrastructure, preventing fraud and manipulation, maintaining service integrity, resolving disputes and improving the service, balanced against the rights and interests of affected individuals.

Some information about relationships may be sensitive or capable of revealing sensitive inferences in certain jurisdictions. Where a law requires an additional condition, Lockily will rely on a legally available condition, obtain explicit consent where required, reduce the information processed, restrict the feature, or decline to process the information when no lawful condition is available.

6. What other users may see

Depending on the product state and entitlement, another user may see limited information such as:

• the existence or number of relationship claims;
• signal strength or activity level;
• time ranges or recency indicators;
• whether a claim has completed a stated phone-verification step;
• whether a relationship has been mutually confirmed;
• aggregate search or monitoring signals;
• other aggregate or de-identified indicators designed for the report.

Lockily does not intentionally reveal another claimant's direct identity, private nickname, password, recovery code, full account record, private communications or full payment information merely because users search the same Subject.

7. Automated aggregation and signal generation

Lockily uses software rules to normalize numbers, count or de-duplicate activity, classify verification states, detect conflicts and generate signal-strength descriptions. These are informational service outputs. They are not legal determinations and are not designed to produce decisions concerning employment, credit, housing, insurance, immigration, education or other high-impact eligibility matters.

Where applicable law gives a right relating to automated decision-making, a person may request human review through the legal/privacy channel. Lockily may require identity verification before disclosing or altering information.

8. Sharing with service providers

Lockily may disclose or make information available to service providers acting for the service, including cloud hosting, database, security, payment, communications, analytics, customer-support and software providers. Providers receive only the information reasonably necessary for the service they perform and are subject to contractual, technical or legal safeguards appropriate to their role.

Payment providers, banks, telecommunications providers and other third parties can also process information as independent controllers under their own legal terms when you interact directly with their services.

9. Legal, safety and corporate disclosures

Lockily may preserve, access or disclose information where reasonably necessary to comply with law, a court order, lawful regulatory request, tax or accounting obligations, payment disputes, fraud prevention, security investigations, protection of rights, or a credible threat to safety. Lockily may challenge or narrow a request where appropriate and legally permitted.

If the Lockily business or relevant assets are reorganized, financed, merged, acquired or transferred, information may be transferred as part of that transaction subject to applicable law and continued protection.

10. Cross-border processing

Lockily and its providers may process information in countries other than the country where a user or Subject is located. Cross-border processing can occur because of shared infrastructure, payment systems, cloud services, fraud tools, support and regional operations.

Where Nigerian law applies, Lockily will use a legally recognized transfer mechanism, condition or safeguard where required under the Nigeria Data Protection Act 2023 and applicable implementation guidance. Where another jurisdiction requires contractual safeguards, adequacy, consent or another transfer mechanism, Lockily will use an available lawful mechanism appropriate to the processing.

11. Retention

Lockily retains information for the period reasonably necessary for the purposes described in this Statement, including active account operation, report history, service integrity, fraud prevention, disputes, legal defence, payments, accounting and legal obligations. Different categories have different retention needs.

Deletion of an account does not necessarily require immediate deletion of every transaction, fraud, dispute, safety, audit or legal record. Lockily may retain limited information where permitted or required by law, while restricting its use to the permitted purpose.

12. Security

Lockily uses administrative, technical and organizational safeguards designed to reduce unauthorized access, misuse, loss, alteration or disclosure. Measures can include access controls, hashed credentials, restricted service credentials, transport encryption, logging, fraud controls and separation of payment-card entry from Lockily systems.

No internet, telecommunications, cloud or authentication system is perfectly secure. Lockily cannot guarantee that unauthorized access, service compromise or data loss will never occur. Users are responsible for securing their own devices and credentials.

13. Data breaches and security incidents

Lockily may investigate suspected security incidents, contain risks, preserve evidence and notify affected persons or regulators when notification is required by applicable law. Information in a security notice can be limited or delayed where law-enforcement, security or legal requirements permit or require it.

14. Your privacy rights

Depending on applicable law and your relationship to the data, you may have rights including the right to:

• receive information about processing;
• request access to personal information about you;
• request correction of inaccurate information;
• request deletion or erasure where legally available;
• object to or request restriction of certain processing;
• withdraw consent where processing relies on consent, without affecting prior lawful processing;
• request portability where applicable;
• request human review in relation to certain automated decisions where the law grants that right;
• complain to a competent data-protection or consumer authority.

Rights are not absolute. Lockily may decline or limit a request where necessary to protect another person's rights, prevent disclosure of a private claimant, preserve security, comply with law, prevent fraud, maintain legal claims or satisfy another lawful exemption.

15. Verification of privacy requests

Lockily may require proof that the requester controls the relevant phone number, account or other identifier before responding to a privacy request. Additional information may be requested where necessary to prevent unauthorized access to another person's information. Lockily may retain records of the request and response for compliance, fraud prevention and dispute purposes.

16. Nigeria-specific privacy rights

Where the Nigeria Data Protection Act 2023 applies, data subjects may exercise rights recognized under that law and applicable guidance. Complaints may be made to the Nigeria Data Protection Commission where the statutory conditions are met. Lockily may first request a reasonable opportunity to investigate and respond, but this does not remove a statutory right to complain to the Commission.

17. United States privacy rights

Residents of certain U.S. states may have additional rights under state privacy laws where those laws apply to the relevant operator and processing. These can include rights to access, correct, delete, obtain a copy of certain information, opt out of certain defined uses, or appeal a privacy decision. Lockily will honor applicable rights to the extent required by law.

18. Children

Lockily is for adults 18 and older. Lockily does not knowingly permit persons under 18 to create an account or submit relationship claims. If Lockily learns that an account belongs to a minor, it may suspend the account and take steps to remove or restrict information as required by law.

19. Cookies, local storage and similar technologies

Lockily may use essential cookies, browser storage, session storage, service workers and similar technologies to maintain sessions, preferences, PWA functionality, security and performance. Analytics or non-essential technologies, where used, are subject to consent or opt-out controls when required by applicable law.

20. De-identified and aggregate information

Lockily may create aggregate, statistical or de-identified information for analytics, product improvement, service integrity, capacity planning and business reporting. Lockily may retain and use information that no longer identifies an individual to the extent permitted by law and will not intentionally re-identify information represented as de-identified except for security testing, legal compliance or where otherwise permitted.

21. Changes to this Privacy Statement

Lockily may update this Statement to reflect changes in technology, features, operators, service providers or law. Material changes will be communicated where required. The effective date at the top identifies the current version.

NDA / Confidentiality Agreement

1. Parties and incorporation

This NDA / Confidentiality Agreement is between you and the applicable Lockily operator under the Terms. It forms part of the Terms and applies whenever you access non-public Lockily information, including a Full Report, Monitor alert, account-only signal, private verification information or other restricted content.

This is primarily a user confidentiality agreement. Lockily's obligations concerning personal information are governed by the Privacy Statement, applicable data-protection law and contractual obligations with service providers.

2. Confidential Information

“Confidential Information” includes, to the extent not lawfully public:

• Full Report contents and report identifiers;
• private Lock and Monitor intelligence;
• non-public counts, timing information, verification details and conflict signals;
• private claimant or account information;
• information that could reasonably assist in identifying a private claimant, Monitor subscriber or source;
• non-public fraud, anti-abuse or verification methods;
• non-public product, pricing, security, operational or technical information disclosed through restricted access;
• any information clearly marked confidential or that a reasonable person would understand to be confidential in context.

3. Exclusions

Confidential Information does not include information that you can demonstrate:

• became public through no breach of this Agreement;
• was lawfully known to you without a confidentiality duty before disclosure by Lockily;
• was independently developed without use of Lockily Confidential Information;
• was lawfully obtained from a third party entitled to disclose it;
• Lockily expressly authorized in writing for public disclosure.

4. Permitted personal use

You may use Confidential Information for your own legitimate personal decision-making relating to the Lockily service. You may privately disclose the minimum necessary information to a lawyer, regulated professional adviser, counsellor, medical professional, law-enforcement officer, court, regulator or trusted support person where reasonably necessary and where the recipient is informed that the information is private or is otherwise subject to a professional, legal or confidentiality obligation.

5. Restricted uses

You agree not to:

• publish or post a non-public Lockily report or substantial portion of it on social media, websites, forums, group chats or other public channels;
• sell, license, rent, trade or commercially redistribute Confidential Information;
• use Confidential Information to harass, threaten, blackmail, extort, intimidate, publicly shame, retaliate against or endanger another person;
• use the information to organize a campaign against a person, claimant or Subject;
• scrape, catalogue or create a competing database from Lockily reports;
• combine restricted Lockily information with other sources for the primary purpose of discovering the identity of a private claimant, Monitor subscriber or private source;
• circumvent technical restrictions, watermarking, access controls, report identifiers or anti-copy protections;
• misrepresent Lockily signals as independently verified facts, court findings, government records or proof of wrongdoing.

6. No reverse identification

Private claimant identities are protected. You agree not to conduct or commission reverse-identification efforts designed to determine who created a private Lock or Monitor based on timing, counts, report structure, leaked metadata, phone-book matching, social-media correlation or other methods. This restriction does not prohibit lawful investigation by competent authorities or professional advisers acting within the law.

7. Security of Confidential Information

You agree to use reasonable care to prevent unauthorized access to Confidential Information, including protecting your Lockily credentials and not leaving report content openly accessible on shared devices. If you intentionally share permitted Confidential Information with another person, you remain responsible for limiting the disclosure to what is reasonably necessary.

8. Compelled disclosure and protected reporting

Nothing in this Agreement prevents or penalizes:

• compliance with a valid court order, subpoena or lawful government requirement;
• a complaint to a regulator, data-protection authority, consumer authority or law-enforcement body;
• lawful reporting of suspected crime, fraud, abuse, domestic violence, exploitation or imminent harm;
• confidential communication with legal counsel or another professional adviser;
• exercise of a statutory right that cannot lawfully be waived.

Where legally permitted and safe, a person compelled to disclose Confidential Information may notify Lockily so that Lockily can seek protective measures or limit unnecessary disclosure.

9. Ownership and no licence

This Agreement does not transfer ownership of Lockily reports, databases, software, scoring methods, trademarks or other proprietary rights. Access to a report grants only the limited personal-use right expressly described in these documents.

10. Breach and remedies

Unauthorized disclosure or misuse of Confidential Information can cause harm that may be difficult to quantify. To the extent permitted by law, Lockily may suspend or terminate access, preserve evidence, seek injunctive or equitable relief, pursue damages, recover reasonable enforcement costs where legally available, and take other lawful measures to stop or remedy a breach.

You agree to indemnify the applicable Lockily operator and related persons against third-party claims resulting from your unlawful disclosure, public accusation, doxxing, harassment, blackmail, reverse identification or other breach of this Agreement, subject to the limitations imposed by applicable law.

11. No warranty concerning Confidential Information

Confidential status does not mean the information is independently verified or accurate. All Lockily report limitations, disclaimers and liability limitations in the Terms continue to apply to Confidential Information.

12. Duration and survival

Your confidentiality and restricted-use obligations continue for as long as the relevant information remains non-public and confidential, and survive account closure, termination, refund, expiration of Monitor, deletion of the app or end of the relationship to which a report relates. Obligations that by their nature are intended to survive will remain in effect to the maximum extent permitted by law.

13. Governing law, severability and priority

This Agreement follows the governing-law and dispute provisions of the Terms. If a provision is invalid or unenforceable, it will be limited or severed to the minimum extent required and the remainder will continue. Where this Agreement conflicts with a mandatory legal right, the mandatory legal right controls. Where it conflicts with the Terms on confidentiality of non-public report data, the provision providing greater lawful protection to confidential information will apply.

Legal, privacy and correction requests

Requests concerning account data, correction of information, review of an allegedly false or abusive Lock, privacy rights, legal notices or confidentiality concerns may be submitted through the legal/support contact channel published inside Lockily or on lockilyapp.com. Lockily may request reasonable identity or phone-control verification before disclosing, changing or deleting information.

Document interpretation. Headings are for convenience. “Including” means “including without limitation.” References to a law include amendments and replacement legislation where applicable. Any provision intended to protect Lockily, Peygo Integrated Services LTD, Ingle Meet, their affiliates, personnel or service providers is intended to benefit those persons to the extent permitted by law.