LOCKD legal

Privacy Policy

Effective date: August 19, 2026

LOCKD is designed so that sensitive fitness, TrueDepth camera, facial, motion, and Screen Time information stays on your device. This policy explains the limited circumstances in which information leaves your device.

At a glance: LOCKD has no user accounts, no advertising, and no cross-app tracking. TrueDepth and motion data are processed live on your device and are not recorded, stored, or transmitted. Purchase and entitlement data is processed by Apple and RevenueCat so LOCKD can provide and restore paid access.

1. Who is responsible for your data

LOCKD is published by Leandro Tolaini, an independent developer based in France, who is the data controller for the processing described in this policy.

Contact: hello@lockd.app.

2. Information handled by LOCKD

Category	What it includes	Where it is handled	Why
Plans, preferences, and workout history	Your goals, age entered during onboarding, estimated screen-time habits, target, routine, push-up capacity, exchange rate, completed workouts, push-up counts, earned time, and app settings.	Stored locally on your device and, where required for Screen Time extensions, in LOCKD's private App Group storage.	To personalize your plan, count workouts, display progress, and operate app restrictions.
Screen Time selections	Privacy-preserving app, category, and website selection tokens supplied by Apple's Family Controls framework, along with schedules and credit balances.	Processed and stored locally. LOCKD does not upload your selected-app list to its own servers.	To apply the restrictions you choose and unlock them according to your plan.
TrueDepth camera, Face Data, and motion	Live ARKit face-tracking signals from the front TrueDepth camera: whether a face is tracked, its three-dimensional position relative to the device, an approximate face-to-device distance calculated from that position, and brief face-tracking loss or occlusion timing. Device-motion measurements are also used to check device stability.	Collected and processed only in real time on your device while you run the push-up detector. These signals are held temporarily in memory and discarded when tracking stops. LOCKD does not record, store, or transmit camera images, video, depth maps, facial geometry, face meshes, facial landmarks, or raw motion data.	Only to determine push-up position, count repetitions, and provide live positioning or stability guidance.
Health data	With your permission, the latest body-weight sample may be read to estimate calories, and workout, push-count, and active-energy samples may be written to HealthKit.	Accessed through HealthKit and kept in Apple's Health data store under your control. LOCKD does not transmit HealthKit data to the developer, RevenueCat, or advertisers.	To save workouts and provide a calorie estimate.
Notifications	Your permission status and locally scheduled routine or credit reminders.	Handled on your device through Apple's notification system.	To send reminders you enable and status notifications needed by the app.
Purchases and entitlement status	A random RevenueCat identifier, device and app technical information, product identifiers, subscription or purchase status, transaction timestamps, Apple receipt data, and entitlement status. LOCKD does not receive your payment-card details.	Processed by Apple and RevenueCat and made available to the developer through RevenueCat's service.	To display products, process and validate purchases, restore access, prevent fraud, and provide support.
Support communications	Your email address and anything you choose to include when contacting support.	Processed by the email services used by you and LOCKD.	To answer your request and maintain necessary support records.
Diagnostics shared by Apple	Crash and performance information that Apple may provide to developers if you choose to share analytics with app developers in your device settings.	Processed through Apple's developer services.	To diagnose failures, secure the app, and improve reliability.

3. TrueDepth camera and Face Data

LOCKD uses Apple's ARKit face-tracking API and the front TrueDepth camera solely to operate the push-up detector. This section describes that processing in detail.

Data processed: When you start the detector, ARKit processes the TrueDepth camera input on the device. LOCKD reads only whether a face is currently tracked and the face anchor's three-dimensional position relative to the device. From those signals, LOCKD calculates an approximate face-to-device distance and tracks brief periods when the face is occluded or no longer detected. The app does not access facial geometry, face meshes, facial landmarks, blend shapes, expressions, or information used to identify a person.
Purpose: The distance, tracking state, and occlusion timing are used only to determine whether you move between the high and low push-up positions, count a repetition, and provide live positioning guidance. Face Data is not used to recognize or authenticate you, determine your identity, analyze emotions, build a user profile, or make decisions about you.
Collection and consent: Processing begins only after you choose to start the detector and grant LOCKD camera access through the iOS permission prompt. While the detector is active, iOS displays its camera-use indicator. LOCKD stops TrueDepth processing when the detector is paused or stopped.
Storage and retention: TrueDepth camera input and Face Data are processed in volatile memory for the active detector session only. LOCKD does not record or save camera images, video, depth information, Face Data, or templates derived from Face Data. The temporary signals are discarded when tracking stops and are never retained after the detector session. The resulting repetition count and workout summary may be stored locally as workout history, but they do not contain Face Data.
Sharing and disclosure: TrueDepth camera input and Face Data never leave your device. They are not uploaded to a server, transmitted to the developer, disclosed to RevenueCat or any other third party, sold, rented, used for advertising or marketing, used for analytics or data mining, or combined with other data for tracking.
Your control: You can stop processing at any time by leaving or pausing the detector, or revoke camera access in iOS Settings. Once access is revoked, LOCKD cannot process TrueDepth or Face Data unless you grant permission again. Because LOCKD does not retain Face Data, there is no stored Face Data to delete.

4. Legal bases for processing

Where the GDPR or similar law applies, LOCKD relies on the following legal bases:

Performance of a contract: to provide the app, validate purchases, restore access, and respond to service requests.
Your consent: when you grant access to camera, motion, Screen Time, HealthKit, or notifications. You may withdraw these permissions in iOS Settings.
Legitimate interests: to secure, troubleshoot, and improve the app, provided those interests are not overridden by your rights.
Legal obligations: where records must be retained or disclosed under applicable law.

5. Service providers and disclosure

LOCKD does not sell your personal data and does not use it for targeted advertising. Information is disclosed only as needed to operate the app, comply with law, protect rights and security, or complete a business transfer subject to appropriate safeguards.

Apple: distributes the app, processes App Store purchases and refunds, provides HealthKit, Family Controls, notifications, and optional developer diagnostics. See Apple's Privacy Policy.
RevenueCat: acts as a purchase-infrastructure provider and processes technical and transaction information on LOCKD's behalf. LOCKD configures RevenueCat without a name or email-based account, so RevenueCat creates a random anonymous App User ID. See RevenueCat's Privacy Policy.

Where either provider receives user data in connection with LOCKD, it is required to provide the same or equivalent protection described in this policy and required by applicable law. These providers may use their own subprocessors to provide their services. Neither Apple, RevenueCat, nor any other third party receives TrueDepth camera input or Face Data from LOCKD.

6. International transfers

RevenueCat and some Apple services may process information outside your country, including in the United States. Where required, transfers are protected by recognized legal mechanisms and contractual safeguards. RevenueCat states that customer data is hosted with Amazon Web Services in the United States.

7. Retention and deletion

Local app data remains on your device until you clear it through available app or system controls, or delete the app. Shared App Group data may remain until LOCKD and its extensions are removed.
HealthKit data remains in Apple Health until you delete it there. Removing LOCKD does not automatically delete records already written to HealthKit.
Purchase records are retained for as long as needed to provide and restore purchases, prevent fraud, meet accounting or legal obligations, resolve disputes, and enforce agreements. Apple and RevenueCat apply their own documented retention requirements.
Support messages are kept only as long as reasonably necessary to answer the request and meet legal or security obligations.

You may request deletion of personal data controlled by LOCKD by emailing hello@lockd.app. Because LOCKD has no account system, additional information may be required to locate a pseudonymous purchase record. Some transaction records may need to be retained where required by law or necessary to establish legal rights.

8. Your choices and rights

You can control camera, motion and fitness, Health, Screen Time, notification, and analytics permissions from iOS Settings. You can manage or cancel an Apple subscription in your Apple Account subscription settings. Cancelling a subscription does not itself delete related transaction records.

Depending on where you live, you may have rights to access, correct, delete, restrict, or object to processing; receive portable data; withdraw consent; and lodge a complaint. To exercise a right, contact hello@lockd.app. If you are in France, you may also contact the CNIL.

9. Children and minors

LOCKD is not intended for children under 13. If local law requires parental or guardian authorization for you to use the app, grant permissions, or make a purchase, you must obtain it. If you believe a child provided personal data contrary to applicable law, contact us so the request can be investigated.

10. Security

LOCKD minimizes transmission of sensitive data and relies on iOS protections for local storage and permissions. Purchase information transmitted to service providers is protected in transit. No method of storage or transmission is completely secure, but reasonable technical and organizational safeguards are used for the nature of the information involved.

11. These legal pages

These static pages do not intentionally set advertising cookies or run analytics. They are hosted by GitHub Pages, so GitHub may process technical request information needed to deliver and secure the site under GitHub's Privacy Statement.

12. Changes to this policy

This policy may be updated when LOCKD's features, providers, or legal obligations change. The effective date above will be revised, and material changes will be communicated in the app or through another appropriate channel when required.

13. Contact

Leandro Tolaini — LOCKD
hello@lockd.app
France