Gaea Operations GmbH — Global Privacy Policy

Effective Date: June 10, 2026

This Privacy Policy explains how "Lockr", Lockr.net, Gaea Operations GmbH (“Gaea”, “we”, “our”, “us”) collects, uses, and protects personal data in connection with its platforms and services.

1. Data Controller

Gaea Operations GmbH
Neuer Wall 10
20354 Hamburg, Germany
Email: [email protected]

2. Scope of this Policy

This policy applies to all online services operated by Gaea Operations GmbH, including platforms, websites, mobile apps, and APIs. It describes how we handle data from visitors, registered users, and business partners worldwide.

3. Data We Collect

We collect data necessary to provide, secure, and improve our services. Depending on your interaction, this may include:

Account data: email address, username, payment details, and login credentials.
Payment data: processed securely by our payment partners (e.g., Stripe). We do not store full card information.
Usage data: IP address, browser type, language settings, operating system, and referral URLs.
Analytics data: anonymized or pseudonymized metrics for performance, conversions, and security.
Communication data: messages or requests you send to our support or legal teams.

4. Purpose and Legal Basis of Processing

We process personal data under Art. 6 GDPR for the following purposes:

Contract performance: to provide and maintain user accounts, premium access, and payouts.
Legal obligations: to comply with tax, billing, and record-keeping laws.
Legitimate interests: to protect against fraud, abuse, or unauthorized activity.
Consent: for analytics, cookies, or marketing communications, where applicable.

5. Payments

Payments are processed via third-party providers such as Stripe (Stripe Payments Europe, Ltd., Dublin). Stripe acts as an independent controller under GDPR for payment data. For details, see stripe.com/privacy.

6. Data Sharing

We only share personal data when necessary to operate the service:

With infrastructure and analytics providers (e.g., AWS, Cloudflare, PostHog) under strict data processing agreements.
With payment processors for billing and refunds.
With legal authorities where required by law or court order.

7. International Transfers

Where data is transferred outside the European Economic Area (EEA), it is protected through the use of standard contractual clauses approved by the European Commission or equivalent safeguards.

8. Retention

We store data only as long as necessary for the purpose of processing or as required by law. Account and payment data are retained according to statutory retention periods under German and EU commercial law.

9. User Rights

Under the GDPR, you have the right to:

Access and receive a copy of your personal data.
Request correction or deletion (“right to be forgotten”).
Restrict or object to processing.
Request data portability.
Withdraw consent where processing is based on consent.

To exercise these rights, contact us at [email protected].

10. Security

We use SSL encryption, access controls, and server-level security to protect your data. While we apply industry best practices, no system is fully immune to risk, and users share responsibility for maintaining account confidentiality.

11. Cookies and Analytics

Our services may use cookies or similar technologies for authentication, analytics, and performance. You can disable cookies in your browser settings, though this may limit functionality.

12. Children’s Privacy

Our services are not intended for individuals under 16 years of age. We do not knowingly collect or process data from minors.

13. Updates to this Policy

We may update this Privacy Policy from time to time to reflect legal, technical, or operational changes. The latest version is always available at: gaeaoperations.com/legal/privacy.

14. Contact

Gaea Operations GmbH
Neuer Wall 10
20354 Hamburg, Germany
Email: [email protected]