Privacy Policy
Effective Date: September 15th, 2025
Last Updated: September 15th, 2025
1. Information We Collect
1.1 Information You Provide: Account registration details (name, email, company, payment info).
1.2 Customer Data: Files, folders, and other content uploaded into a LockRoom data room. LockRoom processes this information on behalf of the Customer as part of the Services.
1.3 Usage & Log Data: Metadata such as user actions, timestamps, truncated IP addresses, device/browser type, and outcome of access attempts. These logs are maintained to support audit, security, and compliance requirements (e.g., FINRA Rule 4511, SEC Rule 17a-4).
1.4 Automatically Collected Data: Cookies, analytics, and session data used to improve site performance and security.
2. How We Use Information
2.1 To provide and secure the Services (including encryption in transit and at rest)
2.2 To maintain audit trails, WORM-style retention, and archiving features designed to support compliance with applicable regulatory frameworks.
2.3 To monitor, detect, and prevent fraud, abuse, or misuse of the Services.
2.4 To improve and develop the Services through aggregated, de-identified usage data (never disclosing Customer-identifying data).
2.5 To communicate with you about your account, billing, or support requests.
3. Data Retention
3.1 Active Data Rooms: Customer Data is stored for the duration of the subscription term.
3.2 Archived Data Rooms: Archived exports may be stored in WORM format for seven (7) years or as otherwise required by law or agreement.
3.3 Audit Logs: Retained in append-only format for at least seven (7) years to support compliance with applicable retention obligations.
3.4 Customers may request deletion/export of their data subject to contractual terms.
5. International Data Transfers
5.1 If you access the Services from outside the United States, your information may be transferred to and processed in the U.S.
5.2 LockRoom relies on appropriate safeguards (such as Standard Contractual Clauses) for such transfers where required.
6. Your Rights
6.1 Depending on your jurisdiction (e.g., CCPA, GDPR), you may have rights to:
6.2 Access, correct, or delete your personal information.
6.3 Request a copy of your data in a portable format.
6.4 Object to or restrict processing.
6.5 Withdraw consent for certain uses.
6.6 Requests can be submitted to support@lockroom.com.
7. Security
7.1 We implement administrative, technical, and organizational safeguards including:
7.2 Encryption at rest (AES-256) and in transit (TLS 1.2+).
7.3 Role-based access controls and MFA.
7.4 Append-only audit logs.
7.5 Business continuity and disaster recovery procedures.
7.6 No system is 100% secure. Customers remain responsible for managing their own credentials, user permissions, and backups outside LockRoom's system archives.
8. Prohibited Data
8.1 You may not upload or process the following without LockRoom's prior written agreement:
8.2 Payment card data (PCI).
8.3 Protected health information (PHI) under HIPAA.
8.4 Export-controlled or defense-related information (ITAR, EAR).
9. Legal & Compliance
9.1 LockRoom is designed to support SEC Rule 17a-4 and FINRA Rule 4511 compliance requirements (audit logs, WORM storage, retention).
9.2 LockRoom does not provide legal or compliance advice. Customers are responsible for their own regulatory obligations.
9.3 We may disclose personal information where required by law, regulation, subpoena, or court order.
10. Changes to This Policy
10.1 We may update this Privacy Policy from time to time.
10.2 We will notify users of material changes through the Services or by email.
11. Contact Us
For questions or privacy requests, contact:
- LockRoom LLC: https://lockroom.com/contact-us
- Support: support@lockroom.com
- Phone: +1 (855) 303-4333
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