Privacy Policy
v1.0 - Last updated 11th February 2025
1. Introduction
1.1 Key Twelve Ltd t/a Locked Talk ("we", "us", "our") ("we", "our", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website ("Website") and our service ("Service"). We process personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1.2 By using our Website and/or Service, you agree to the collection and use of information as outlined in this Privacy Policy.
2. Information We Collect
We may collect and process the following types of personal data:
2.1 Information you provide directly:
- Your name, email address, postal address and phone number.
- The prison that the prisoner(s) reside in.
- Details related to your use of our Service, including the mobile numbers you register.
- Any correspondence you send to us, such as customer service inquiries.
2.2 Information we collect automatically.
When you visit our Website, we may collect:
- IP address, browser type and device information.
- Pages visited, time spent on pages, and referring web site.
- Cookies and tracking technologies (see Section 6).
2.3. Information we receive from or share with third parties
- Payment processors may share transaction details with us.
- Analytics processors may share Website visit details with us.
- Telecoms carriers will share call details and we will share neccessary information for the provision of the service.
- We may share information to law enforcement agencies if required by law.
3. How We Use Your Information
We use your information to:
- Provide, operate and maintain our Service.
- Process payments and manage subscriptions.
- Communicate important service-related updates.
- Respond to customer enquiries and support requests.
- Improve our Website functionality and user experience.
- Ensure security, fraud prevention and compliance with legal obligations.
4. Legal Basis for Processing
We process personal data under the following legal bases:
- Contractual necessity: Processing is necessary to provide you with our Service.
- Legitimate interests:For customer service, Website improvement and security measures.
- Legal obligation: Where processing is required to comply with UK laws.
- Consent: For marketing and non-essential cookies (see Section 6).
5. Data Sharing & Third Parties
We do not sell or rent personal data. However we may share information with:
- Payment processors for processing transactions.
- Service providers who help operate our business.
- Legal authorities if required for law enforcement, fraud prevention or regulatory compliance.
- Business partners where required for operational or contractual reasons.
All third parties are required to handle personal data securely and comply with UK data protection laws.
6. Cookies & Tracking Technologies
We use cookies and similar technologies to enhance website performance, analyse user activity and provide a better experience.
6.1 What Cookies We Use:
- Essential Cookies: Required for basic website functions (e.g. authentication or security).
- Analytics Cookies: Help us analyse website usage and improve functionality.
- Marketing Cookies: Used to personalise content and deliver relevant ads (only used with consent).
6.2 How to manage cookies.
You can control cookies through your browser settings. Disabling cookies may impact website functionality. For more details, see www.aboutcookies.org
7. Data Retention
We retain personal data for as long as necessary to:
- Provide the Service and support.
- Comply with legal obligations.
- Resolve disputes and enforce agreements.
When data is no longer required, it is securely deleted or anonymised.
8. Security Measures
We implement appropriate security measures to protect personal data from unauthorised access, alteration, disclosure, or destruction. However, no method of data transmission or storage is 100% secure, and we cannot guarantee absolute security.
9. Your Rights
Under UK GDPR, you have the right to:
- Access your personal data.
- Correct inaccurate or incomplete information.
- Request deletion of your data.
- Restrict or object to processing.
- Request data portability (where applicable).
- Withdraw consent for marketing communications.
To exercise your rights, please contact us at hello@lockedtalk.co.uk
10. Changes To This Privacy Policy
We may update this Privacy Policy periodically. Changes will be posted on this page with an updated "Last Updated" date. If significant changes occur, we will notify you via email or Website notice.
11. Governing Law & Complaints
This Privacy Policy is governed by the laws of England and Wales. If you believe we have not handled your data properly, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO):
