Privacy Policy for OwnerLock®

Updated 28/09/2025

This notice contains important information about how we collect and process your personal data:

  • through your use of our website or our digital applications (Apps), including the OwnerLock® service;
  • by signing up for newsletters, competitions, and other marketing activities either in-store or online;
  • as an individual customer; or
  • as a staff member or other representative of one of our business customers or suppliers.

It also contains information about your rights as a person whose information we process, and how you can complain if you have any concerns about what we are doing with your information. Any changes we make to this notice in the future will be posted on this page and, if appropriate, notified to you by email so please check this page regularly.

Information About Us

OwnerLock® is an online information management system owned and managed by attaché x ltd, a UK-registered company.

Attaché X ltd (further in text Attaché X®) is the controller responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). If you have any questions about this privacy notice, the use of your personal information, or your dealings with our website or our Apps, you can contact us via our web site at attachex.com/contact.

For the purposes of data protection law, Attaché X Ltd is the controller. As we process data of individuals in the European Union, we comply with the EU General Data Protection Regulation (EU GDPR) in addition to the UK Data Protection Act 2018 (UK GDPR).

Your Personal Data

Information provided to us by you or about you

You will provide some or all of the following information to us when you contact us, purchase goods from us, request services offered by us, register a customer account with us, use one of our Apps and/or sign up for newsletters and other marketing activities:

  • Your Identity and Contact Details – includes your name, email address, home postal address/billing address, delivery address (if different), and your contact telephone number;
  • Your Payment Details – your bank details and payment card details, however, your payment transactions will be encrypted by the acquiring bank so we will not retain any payment card details submitted by you;
  • Your Profile Data – if you register a customer account online, this includes the profile you create to identify yourself when connecting to our website and Apps (including your username and password) and other data about purchases and your personal preferences;
  • Additional Personal Details – At your option, you can also provide additional personal information to us such as your date of birth, gender, product preferences, and interests. We may also leverage the information you have chosen to make publicly available on social media platforms.
  • OwnerLock® Ownership and Product Data – When you register a product using the OwnerLock® service, you create a digital link between your identity and a specific physical item. This includes:
    • The unique identifier of the OwnerLock® tag (QR or NFC).
    • Information about the product you have registered (e.g., model, serial number).
    • Data you choose to add to the product’s record, such as date of purchase, purchase location, warranty documents, or personal notes.

Please Note: It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

In the case that you are an employee or other representative of any of our business customers or suppliers, the same categories of information might be provided to us by you or about you by the business you represent. This notice applies to our processing of that information in the same way that it applies to the processing of information supplied to us directly. We do not knowingly collect data relating to children.

Information We Collect When You Interact With Us

As you interact with our website, our communications and our Apps, we also automatically collect usage and technical data. Specifically for the OwnerLock® service, this interaction includes the physical act of scanning or tapping a tag. We collect this data by using cookies, server logs, and other similar technologies.

  • Usage Data – includes details of products and services you have purchased, information about how you use our website, and records of your interactions with OwnerLock® tags, such as when and how you access a product’s digital record.
  • Technical Data – includes your IP address, browser type, and location. When an OwnerLock® tag is scanned, we may also collect technical data about the device used for the scan to ensure service security and functionality.
  • Preference Data – includes information about your preferred methods of communication and other information you share with us.
  • Other – We may also receive information from third parties we work closely with such as online fashion retail platforms, delivery services, credit reference agencies, and fraud prevention agencies.

What We Use Your Personal Data For

Data protection law in the UK allows us to collect and use personal information if we have a legitimate reason to do so. Below are the ways we will use your personal data for our legitimate interests and/or to fulfill a contract with you:

  • processing your order, including taking payment and after-sales services;
  • identity verification and credit checking;
  • keeping you updated on the progress of your order;
  • processing and administering your account;
  • making sure that whatever information we hold about you is accurate and up to date;
  • analysing sales to help us understand and improve our business;
  • and as part of our efforts to keep our website and our Apps safe and secure.

In addition, for the OwnerLock® service, we use your data to:

  • Establish and maintain proof of ownership, linking your account to the unique digital identity of your physical products.
  • Facilitate the transfer of ownership from one user to another if you sell or give away a registered item.
  • Provide owner-specific services, such as access to warranty information, customer support, and exclusive content provided by our business partners.
  • Enable the “lost and found” feature. If your item is lost and the tag is scanned, we act as an intermediary to facilitate communication between you and the finder without disclosing your personal contact details to them.
  • Allow our business partners (the product manufacturers/retailers) to send important, non-promotional service messages directly to you, such as product recall notices or critical safety information related to a product you own.
  • Provide general, non-personal product information to any individual who scans a tag but is not the registered owner.

Direct Marketing

We need your consent for direct marketing communications. If you have expressly given your consent, we may use the information you have given us for marketing purposes.

For the OwnerLock® service, please note that the original manufacturer or retailer of your registered product may use the platform to send you marketing offers related to your ownership. This is separate from our own direct marketing. Their ability to do so is governed by the consent you provide to them, and you can manage these preferences through your OwnerLock® account settings or directly with that business.

At any time you can opt out of direct marketing or change your preferences.

Who We Share Your Personal Data With

We may share your information with our selected third parties for the purposes referred to above. For example:

  • Payment Acquiring Services, Delivery Companies, and Credit Reference Agencies.
  • Analytics, search engine, and hosting service providers.
  • Where you opted in to direct marketing, third-party advertisers and affiliate marketing agencies.

Specifically for the OwnerLock® service:

  • With Business Partners: We share data about product registrations with the business partner (i.e., the manufacturer or retailer) who originally sold the product. This enables them to manage their customer relationships, validate warranties, and communicate with you through the platform.
  • During a Lost & Found Event: If a finder scans your lost item, we DO NOT share your name, email, or phone number with them. We facilitate anonymous communication through our secure platform to protect your privacy.
  • During Ownership Transfer: When you transfer ownership of a product, we share the necessary product data (but not your personal account history) with the new owner to allow them to register the item.

We require all third parties engaged by us to respect the security of your personal data and to treat it in accordance with the law.

How Long Do We Keep Your Personal Data For

  • If you are a recipient of newsletters or other communications: we will keep your data until you inform us you no longer wish to receive our communications.
  • If you are an OwnerLock® user: We will keep your ownership and product data for as long as you are the registered owner of a product on our system. If you transfer ownership, we will update the record but may retain a historical log of the transfer for a limited period to resolve disputes and for legal and security reasons. If you delete your account, your personal data will be disassociated from any products you own.
  • In all cases: we may retain some data after the periods identified above where necessary to satisfy legal, accounting, or reporting requirements.

Your Rights

You have rights under data protection laws in relation to your personal data. You can exercise these rights within your account settings or by emailing us at intelligence@attachex.com:

  • Request access to your personal data.
  • Request correction of the personal data that we hold about you.
  • Request the erasure of your personal data. Please note that erasing your OwnerLock® account will result in you losing the digital ownership records for all registered products and access to related services.
  • Object to processing of your personal data.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time if we are relying on your consent to process your personal data.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to deal with any concerns you may have before you approach the ICO so please contact us in the first instance.

For Users in the European Union: In addition to the rights listed above, if you are a resident of the European Union, you have the right to make a complaint at any time to the data protection supervisory authority in your EU member state of residence, work, or where the alleged infringement took place.