Privacy & Cookie Policy

wishLockr: Privacy & Cookie Policy

  1. Introduction
    1. The wishLockr website and any associated mobile application (wishLockr) are owned and operated by KIC (Holdings) Limited of Sovereign House, 14-16 Nelson Street, Douglas, Isle of Man IN1 2AL (trading as WishLockr we, us). By using wishLockr, you agree to be bound by this privacy & cookie policy (the Privacy & Cookie Policy). This Privacy & Cookie Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy & Cookie Policy, do not use wishLockr. If you have any questions, you can contact us at

    2. We reserve the right to update this Privacy & Cookie Policy from time to time at our discretion. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, the updated version will be effective as soon as it is accessible. You are responsible for regularly reviewing this Privacy & Cookie Policy so that you are aware of any changes to it.

    3. This Privacy & Cookie Policy applies to all registered users of wishLockr and anyone else who provides information to us, including any wishUnlockr nominated by a registered user.

    4. We are the controller of the personal data we hold and process for you.

  2. Collecting Your Data
    1. We will collect your as name, birth date, email address and telephone number when you register. You have to provide this personal data to us if you wish to use wishLockr. We may also collect any other personal data that you choose to provided to us either directly or through wishLockr. All personal data that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal data. You must not register under someone else’s name or with an incorrect date of birth. As part of your membership of wishLockr, you are entitled to appoint up to 3 wishUnLockrs. You must obtain the wishUnlockr’s prior consent before giving us their personal data and therefore appointing them to your wishLockr account. If a wishUnLockr subsequently notifies us that they no longer want wishLockr to process their personal data, you agree that we shall delete their personal data from your account; and in such circumstances we shall notify you accordingly.

    2. You must keep your log-in details confidential. You are responsible for all activity under your wishLockr account.

    3. When you use wishLockr, we automatically collect and store information about your device and your activities. This information could include (a) your computer or other device’s unique ID number; (b) your mobile device’s geographic location; (c) your IP address; (d) technical information about your device such as type of device, web browser or operating system; (e) your preferences and settings such as time zone and language; (f) how long you used the system and which services and features you used. We will use this information on an anonymous basis to customise, measure and improve our services, content and advertising, to better understand our users, diagnose and fix problems and for research purposes and for our general business purposes.

    4. We also allow advertisers and advertising networks to collect information about your computer or mobile device, activities, and geographic location to enable them to display targeted ads to you.

  3. Use of your personal data
    1. We will only use your personal data where we have a lawful basis to do so.

    2. We will use your personal data to comply with our contractual obligations to you under our Terms of Use including to (a) manage your wishLockr account and to tell you about our services.

    3. For our legitimate interests, we may share your personal data with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.

    4. In order to comply with our legal obligations, under certain circumstances we may have to disclose your personal data under applicable laws and/or regulations, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.

    5. For our legitimate interests, we may also share your personal data; in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company

    6. Again for our legitimate interests, if you register with wishLockr ,we may end you marketing email messages. You can choose to no longer receive marketing emails from us contacting us at or clicking unsubscribe from a marketing email. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer want to receive marketing emails from us.

    7. Some or all of your personal data may be stored or transferred outside of the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the EEA or if any of our service providers are based outside of the EEA. If we do store or transfer your personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under applicable laws.

    8. From time to time, we may offer you the opportunity of engaging third parties who offer services that we think may be useful to users of wishLockr, including for example, will writing services. However, we shall provide your personal data to identified third parties only where you have provided us with your express, unambiguous consent to do so.

  4. Cookies
    1. A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites to identify when users revisit that website.

    2. The wishLockr website uses cookies so that we can recognise you when you return and personalise your settings and preferences. Most browsers are initially set up to accept cookies. You can change your browser settings either to notify you when you have received a cookie, or to refuse to accept cookies. Please note that the wishLockr website may not operate efficiently if you refuse to accept cookies.

    3. We also use Google Analytics to monitor how the wishLockr website is used. Google Analytics collects information anonymously and generates reports detailing information such as the number of visits to the system, where visitors generally came from, how long they stayed on the system, and which pages they visited. Google Analytics places several persistent cookies on your computer’s hard drive. These do not collect any personal data. If you do not agree to this you can disable persistent cookies in your browser. This will prevent Google Analytics from logging your visits.

  5. Security
    1. We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal data from unauthorised access and disclosure. The technology that we use and the security policies which we have implemented are intended to safeguard your information from unauthorised access and improper use. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise that your personal data or other content that you upload to the wishLockr website will always remain secure.

  6. Your rights
    1. You have the right to obtain from us a copy of the personal data that we hold for you, and to require us to correct errors in the personal data that we process for you if it is inaccurate or incomplete. You also have the right at any time to require that we delete your personal data or to ask us to procure that any third party who has received your personal data from us shall delete your personal data. To exercise these rights, or any other rights you may have under applicable laws, please contact us at

    2. Please note, we reserve the right to charge an administrative fee if your request is manifestly unfounded or excessive.

    3. If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please contact us, or you can contact the Information Commissioner, see If you are outside of the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

    4. We retain your personal data in accordance with applicable laws. Therefore, if you register with us, we shall retain your personal data until you close your account except where we are required to retain your personal data for longer to comply with accounting and taxation requirements. We shall retain your personal data in our records for marketing purposes until you notify us that you no longer want to receive marketing emails from us. If you have otherwise contacted us with a question or comment, we shall retain your personal data for 6 months following such contact to respond to any further queries you might have.

  7. General
    1. If any provision of this Privacy & Cookie Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

    2. This Privacy & Cookie Policy shall be governed by and construed in accordance with the law of England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.

Last updated: May 2018