This Privacy Policy (“Privacy Policy” or “Statement”) explains how Sun Locke (“Sun Locke,” “we,” “us,” or “our”) collects, processes, and uses Personal Data (as defined below) about individuals (“you” or “your”) who access or use our websites, services, applications, or otherwise interact with us (collectively, the “Services”).
Your use of the Services is also governed by our Terms & Conditions (the “Terms”), available at
https://www.sunlocke.com/terms. By accessing or using the Services, you acknowledge that you have read, understood, and agree to this Privacy Policy and the Terms. If you do not agree, you must immediately cease using the Services.
2. Who is Sun Locke
For the purposes of applicable data protection laws, the entity acting as the data controller of your Personal Data is Sun Locke LLC (and, where applicable, its subsidiaries, affiliates, or related entities). Sun Locke’s principal place of business is located at 510 Manhattan Ave. New York, NY, 10027. Sun Locke determines the purposes and means of processing your Personal Data and is responsible for ensuring that your Personal Data is processed in compliance with this Privacy Policy and applicable laws.
2.1 Relationship to our Terms & Conditions
This Privacy Policy forms part of the Terms & Conditions that govern your use of the Services. Any capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the Terms. In the event of a conflict between this Privacy Policy and the Terms, the Terms govern your contractual relationship with Sun Locke, and this Privacy Policy governs how we collect, use, and disclose Personal Data.
3. Why we collect Personal Data and from what sources
We collect and collate Personal Data that you either directly provide to us or that we obtain or infer through your use of the Services, as well as from third parties. The categories and amount of Personal Data we collect depend on the Services and the nature of your interactions with us.
Directly from you: When you register for an account, use our Services, contact us for support, respond to surveys, participate in promotions or events, subscribe to marketing communications, or otherwise provide Personal Data.
From your device and usage: We may automatically collect technical data such as IP addresses, browser types, device identifiers, operating systems, access times, and referring URLs. We also track how you interact with the Services (e.g., pages visited, features used, emails opened).
From third parties: We may obtain Personal Data from public and commercial sources, including business websites, online directories, social media and professional networking platforms, and reputable third party data providers. This may include business contact information, such as your name, job title, company, business email address, and business phone number, which we use for B2B outreach and marketing. We may also receive Personal Data from analytics providers, advertising networks, internet service providers, payment processors and other service providers that help us operate, secure and improve the Services.
We may also infer data about you based on the information you provide or make available to us, such as personalizing your experience, suggesting additional Services, or drawing other inferences. In addition, we may use aggregated, deidentified, or anonymized data for any lawful business purpose.
We will indicate where any requested Personal Data is mandatory or optional. If you choose not to provide certain mandatory Personal Data, we may not be able to provide certain Services to you.
Our Services may contain links to third-party websites. Any access to and use of such linked websites is governed by the privacy policies of those third-party websites, and we are not responsible for the privacy practices of such third parties.
4. How we use your Personal Data
Primary use:
We process Personal Data for a variety of legitimate business purposes, including but not limited to:
- Providing, maintaining, and improving the Services and related functionality;
- Managing your account, handling inquiries, responding to support requests, and communicating with you about the Services;
- Processing payments, providing quotes, and fulfilling our contractual obligations;
- Complying with legal obligations, detecting and preventing fraud or illegal activities, auditing compliance, identifying and repairing errors, and protecting the security and integrity of the Services.
We combine data about you across our different Services to provide you with a more seamless and efficient experience. We do not use solely automated decision-making processes that produce legal or similarly significant effects without human involvement, unless required or permitted by law.
Our legal basis for processing Personal Data includes our legitimate interests in operating our business, fulfilling our contractual obligations to you, complying with applicable laws, and—where required—obtaining your consent (e.g., for certain marketing communications or cookies).
Secondary use:
We may also use your Personal Data for:
- Communicating with you regarding updates, new features, industry insights, or requesting feedback;
- Sending marketing communications about products, services, or offers from us or our affiliates, as permitted by law. You may opt out of receiving marketing emails at any time by following the instructions provided in the email. However, you cannot opt out of receiving transactional or service-related messages from us;
- Improving our website, products, and communication strategies;
- Conducting research and development to enhance user experiences and performance.
5. How long we keep your Personal Data
We retain your Personal Data for as long as is necessary to provide the Services and for legitimate and essential business purposes, such as maintaining the security of our systems, complying with legal obligations, resolving disputes, and enforcing our agreements. If you request that we delete your Personal Data, we will do so unless we are legally required or otherwise permitted by law to retain the data. Once we no longer need your Personal Data, we will securely delete, deidentify, or anonymize it.
7. How we protect your Personal Data
Secure servers:
We implement appropriate technical and organizational measures to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction. We use industry-standard encryption, access controls, and other security safeguards.
Usage restrictions:
We prohibit our employees, affiliates, and third-party service providers from using your Personal Data in a manner inconsistent with this Privacy Policy or applicable law. For example, they are not permitted to:
- - Target or profile you based on sensitive categories of Personal Data (e.g., health, sexual orientation, political beliefs) without proper authorization;
- - Use your Personal Data for unlawful or discriminatory purposes;
- - Engage in any processing activities that violate applicable data protection laws.
We ensure that any third parties who process your Personal Data are bound by robust contractual obligations that uphold data protection standards and safeguard your rights.
10. Your privacy choices and rights
Your choices:
Where we rely on your consent to process Personal Data, you may withdraw that consent at any time, subject to any legal or contractual restrictions. You may manage your marketing communication preferences by following the opt-out instructions in our emails. You can also manage browser or device settings to control cookies and other tracking technologies.
Your rights:
Depending on your jurisdiction, you may have certain rights regarding your Personal Data, which may include:
- Requesting access to the Personal Data we hold about you;
- Asking us to update, rectify, or delete your Personal Data;
- Objecting to or requesting the restriction of certain processing;
- Opting out of the sale of Personal Data where applicable;
- Requesting the disclosure of categories of Personal Data shared with third parties;
- Lodging a complaint with a data privacy authority;
- Exercising your right not to be discriminated against for exercising your privacy rights.
Certain requests may be subject to limitations or denials as permitted by applicable law. To exercise these rights, submit a verifiable request to us at legalnotices@sunlocke.com. If you appoint an authorized agent, the agent must present signed written permission to act on your behalf, and we may require additional verification of your identity.
If we cannot verify your identity, we may not be able to fulfill your request. If we deny your request, you may have the right to appeal our decision as permitted by applicable law.