Privacy Policy

Effective Date: 28 October 2026

1. Controller Details

Red Hammer Limited trading as Locker ("Locker", "we", "us", "our") is the controller of personal data processed in connection with the website and the Services, except where we act as a processor on behalf of business customers (see DPA).

Registered in England and Wales: company number 16968888
Registered office: Willowbank, Main Street, Hanwell, Banbury, Oxfordshire, OX17 1HP, UK
Contact: support@getlocker.co
Website: www.getlocker.co

2. Categories of Personal Data

We may collect and process the following categories of personal data:

2.1 Account and identity data

Email address, display name, authentication identifiers, and related account information. Passwords are stored hashed and are not stored in plain text.

2.2 Content and collaboration data

Content you upload or create (including audio files), associated metadata, and communications/messages within the Services, as well as sharing and collaboration activity. Messages in Chats are stored encrypted, with a key kept apart from them, and only the people in a chat can open it. Our team does not read chats, and sees a message only if someone reports it. Chats are not end-to-end encrypted.

2.3 Usage, device, and technical data

Service usage analytics, device/browser information, and diagnostic data including error and performance logs (e.g., via Sentry). Website visits are counted without cookies (Vercel Analytics and Speed Insights). For signed-out visitors we also note the time zone, a random identifier kept for one browser tab, and any campaign tag in the link, kept for 90 days; this respects Global Privacy Control and Do Not Track (see our Cookies page).

To stop abuse, we briefly keep the IP address of requests that send share replies, submissions and sign-in codes, and we keep the IP address and browser type of newsletter sign-ups as a record of consent.

2.4 Share recipient data

When someone opens a link that a Locker user has shared with them, we record that the link was opened, played or downloaded, along with the time and a randomly generated identifier stored in that person's own browser so repeat visits from the same device can be recognised. We also record the type of device used (for example iPhone or Mac) and the approximate country of the connection, both derived at the time of the visit. We do not store the IP address of share visitors for this purpose, and we do not use device fingerprinting.

If the person who created the link turned on the option to ask who is listening, the recipient is asked to give a name before playing or downloading, and that name is stored alongside those same records and shown to the sender. Recipients are told on the page, before they play anything, that the sender can see when they open, play and download the content. The name is self-declared and we do not verify it. Where the name matches a contact already saved by the sender, we associate the activity with that contact so the sender can see it in one place.

2.5 Billing and transaction data

Subscription status, invoices, and payment confirmations (payment card data is processed by our payment provider and not stored by us in full). If you subscribe in the iPhone app, Apple handles the payment and tells us the subscription status.

2.6 Connected services

You can choose to sign in with Apple or Google, and to connect other services to Locker. Each one is off until you connect it, and you can disconnect it at any time in Settings:

Sign in with Apple or Google: we receive your name and email address (or Apple’s private relay address) to create your account.
Google Drive and Dropbox: we read the files and folders you choose to bring into Locker, with read-only access. We never change or delete anything in your Drive or Dropbox.
Google Calendar: we read your calendars and the events in them to show them in Locker, and add or change events only when you ask.
AI apps connected to Locker: if you connect an AI app (such as Claude or ChatGPT) to your Locker, that app can read and change what you allow it to, acting as you.
iPhone notifications: if you allow them, Apple delivers our push notifications to your device.

Locker’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. We use Google data only to provide the features you turned on, we do not use it for advertising, we do not sell it, and no person at Locker reads it unless you ask us to for support, it is needed for security, or the law requires it. File names from Google Drive and Dropbox are sorted by our AI provider as described in Section 6, which does not use them to train its models.

3. Purposes of Processing

We process personal data to:

provide, operate, secure, and maintain the Services;
create and administer accounts;
process subscriptions and payments;
provide customer support and troubleshooting;
monitor performance, prevent abuse, and ensure security;
tell a user who has opened, played, or downloaded content they shared, where they have enabled that;
send account holders occasional news about Locker by email, which you can unsubscribe from at any time; and
develop and improve the Services, including analytics.

4. Legal Bases

We rely on the following legal bases (as applicable):

Contract: to provide the Services and perform our obligations to you.
Legitimate interests: to secure the Services, prevent fraud/abuse, ensure reliability, conduct proportionate analytics and improvement, and send account holders news about Locker (every email has an unsubscribe link, and once you unsubscribe we do not email you news again).
Consent: for newsletter sign-ups from people without an account, and for connected services you choose to turn on.
Legal obligation: to comply with applicable laws (e.g., tax/accounting).

5. Disclosures; Processors

We may disclose personal data to vendors and service providers acting as processors, including:

Supabase, London, United Kingdom (Database, authentication, and file storage)
Vercel, Global edge network (Website and application hosting, and cookieless visit statistics)
Google Cloud, London, United Kingdom, and Belgium, European Union (Audio analysis (tempo, key, and audio characteristics), transcription, and the nightly off-site backup of your files. Splitting a track into parts runs on graphics hardware in Belgium)
OpenAI, United States (Kii and meaning search: lyric text, attached images and documents, Kii conversations, and file names from connected Dropbox or Google Drive. Audio files are never sent, and nothing is used to train their models)
Anthropic, United States (Kii assistant (text only, audio files are never sent, and nothing is used to train their models))
Resend, United States (Transactional and notification email)
Stripe, United States and European Union (Subscription payments and billing)
Sentry, United States (Error and performance monitoring)

The current list is always published on our Subprocessor List page.

We do not sell personal data.

6. AI Processing

Locker uses AI providers (OpenAI and Anthropic, listed in Section 5) for Kii and for search. We send them text and pictures, never audio files. What we send:

Lyrics: the words of lyric sheets attached to your tracks are read automatically in the background, so you and Kii can find tracks by what the words are about. The text is sent to OpenAI; your sheets themselves stay in Locker.
Kii: what you type to Kii, the parts of your catalogue Kii needs to answer (such as titles, credits, details and lyrics), and any images or documents you attach to a Kii message. Kii also writes short summaries of your past conversations so it can remember them.
File names: names of files you bring in from Google Drive or Dropbox, so they can be sorted into tracks and versions.

These providers process this data only to give you the answer or result, and do not use it to train their models.

We do not use your music to train AI models. We do not provide your audio recordings, lyrics or catalogue content to any third party for the purpose of training, fine-tuning or improving their models, and we do not train models of our own on your content. Audio analysis (such as tempo, key and audio characteristics) is performed to describe your own recordings back to you within your own account, and its results are not pooled into any shared or public model.

How Locker gets better at reading file names

Locker reads your file names to fill in titles, versions and credits for you. To get better at this for everyone, we look at the patterns in how people name their files, never the names themselves. Before a pattern is kept, every person's name and track title in it is swapped for a made-up word, so ‘Midnight Drive v2 (Sam Lee x Ana Ruiz) 120bpm’ becomes something like ‘Kodara Lemvi v2 (Bam Tee x Uno Wiz) 120bpm’. Only these anonymous patterns are kept, with no link to you or your account. We use them to check and improve Locker’s own naming rules. We never listen to your audio for this. We never use your file names, audio, lyrics or catalogue to train AI models, and we never share them with anyone.

7. International Transfers

Your audio files, catalogue database and account records are stored in the United Kingdom, and audio analysis is performed in the United Kingdom. When you split a track into its parts, that one job runs on Google Cloud in Belgium (European Union), because it needs graphics hardware not offered in London; the results come straight back to the United Kingdom.

Some supporting services (payments, email delivery, error monitoring and AI text) are provided by processors located outside the UK, as identified in Section 5. Where personal data is transferred outside the UK, we use appropriate safeguards (e.g., standard contractual clauses or UK transfer instruments) and other measures required by law.

8. Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Notice, including legal, regulatory, security, and operational requirements. Where no fixed period is stated, we determine retention based on criteria such as data sensitivity, legal obligations, security needs, and dispute risk.

Baseline (current):

Kii conversations and the record of what Kii did: kept while your account is open, so Kii can remember earlier conversations, and deleted with your account. Ask us at any time to delete them sooner
Admin audit logs: 2 years
Active account data: for the duration of the account
Share open/play/download records, including any name a recipient gave: retained with the share they belong to, and deleted when that share is deleted
Backups: your catalogue database is backed up daily and each backup is kept for 7 days, so it can be restored to the previous day. A copy of the database is also kept nightly in a private off-site backup in the United Kingdom for 30 days. Your files are also copied nightly to a private off-site backup in the United Kingdom. When a file is permanently deleted, including when you delete your account, its backup copy is removed within about 45 days, and your account’s data leaves the off-site database copies within the same time

9. Security

We implement technical and organisational measures designed to protect personal data, including encryption, access controls, monitoring, and audit logging. Additional information is available on our Security page.

10. Your Rights

Subject to applicable law, you may have rights including access, rectification, erasure, restriction, objection, and portability. Requests may be submitted to support@getlocker.co.

11. Complaints

Where applicable, you may lodge a complaint with your supervisory authority. In the UK, this is the ICO.

12. Contact

support@getlocker.co