Privacy policy

Effective date: 11 November 2026

This Privacy Policy explains how MB Unlockt ("Unlockt", "we", "us") collects and uses your personal data when you visit unlockt.store, buy our ebooks, trackers or bundles, use our tracker app at trackers.unlockt.store, sign up for our emails, leave a review or contact us (together, the "Store").

Who is responsible for your data. The data controller is MB Unlockt, company code 308180731, V. Putvinskio st. 60, Kaunas, Lithuania. Email: info@unlockt.store, phone: +370 699 89645. We process personal data under the EU General Data Protection Regulation ("GDPR") and Lithuanian law.

This policy works together with our Terms of Service and Cookie Policy.

1. What personal data we collect

Data you give us

  • Order data – name, email address, billing country and address, items bought, order number, amounts paid and discount codes. Payment card details are entered directly with Shopify's payment providers; we never see or store your full card number.
  • Tracker account data – email address, encrypted password, the trackers you have unlocked, and the access codes you used.
  • Data you enter in the trackers – for example training sessions, nutrition, recovery notes and goals. Some of this may reveal information about your health (see section 2).
  • Newsletter data – your email address and your consent, if you sign up for our emails.
  • Reviews – your name, email address, rating and review text.
  • Messages – what you send us by email, through our contact or review forms, or via social media.
  • Confirmations – your confirmation at checkout that you are 18+ (or have parental permission), agree to our Terms and want immediate delivery.

Data collected automatically

  • Device and usage data – IP address, browser and device type, approximate location (country or city, from your IP address), pages visited, items viewed or added to cart, and how you reached the Store.
  • Email data – whether our emails were delivered and, for marketing emails, whether they were opened or clicked.
  • Security logs – login times and technical logs needed to protect the Store and your account.

Some of this is collected with cookies and similar technologies; see section 6 and our Cookie Policy.

Data from others

  • Payment and fraud checks – Shopify and its payment partners tell us whether a payment succeeded and may flag possible fraud.
  • Advertising platforms – if you interact with our ads on Meta (Facebook, Instagram) or Google, these platforms may give us aggregated reports on ad performance.

We only use your data for the purposes below, each with a legal basis under Article 6 GDPR.

Purpose

Data used

Legal basis

Process your order, take payment and email you your ebooks and access codes

Order data, confirmations

Contract (Art. 6(1)(b))

Create and run your tracker account and save your tracker entries

Account data, tracker data

Contract (Art. 6(1)(b)); explicit consent for health-related entries (Art. 9(2)(a))

Send service emails (order confirmations, password resets, important account or Terms changes)

Email address, order and account data

Contract; legal obligation

Answer your questions, complaints and refund or privacy requests

Messages, order data

Contract; legal obligation; legitimate interest in good customer service

Keep invoices and accounting records

Order and payment data

Legal obligation (Lithuanian accounting and tax law) (Art. 6(1)(c))

Check and publish reviews

Review data, order data

Legitimate interest in showing genuine reviews (Art. 6(1)(f))

Send newsletters and offers by email

Email address, email engagement data

Consent (Art. 6(1)(a))

Measure and show ads on Meta and Google, and analytics cookies

Device and usage data

Consent (Art. 6(1)(a))

Keep the Store secure, prevent fraud and misuse

Device data, security logs, order data

Legitimate interest in protecting the Store and customers

Establish or defend legal claims

Relevant order, account and message data

Legitimate interest

Health-related tracker data. Entries in our training, nutrition and recovery trackers (for example weight, meals, injuries or recovery notes) may count as health data, a special category under the GDPR. We process such entries only to show them to you in your tracker, only with your explicit consent given when you create your account, and never for advertising. You can withdraw consent at any time by deleting the entries or your account.

What happens if you do not give us data. Your email address is needed to deliver your order and to create an account; without it we cannot sell to you. Everything marked optional, such as signing up for the newsletter, is up to you.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects, and we do not sell your personal data.

3. Who we share your data with

We share personal data only with service providers that help us run the Store, under contracts that require them to protect it and use it only on our instructions (data processing agreements), and with others where the law requires.

Recipient

What they do for us

Where data may be processed

Shopify and its payment partners

Online store, checkout, payments, fraud checks, order emails

EU (Ireland), Canada, USA

Supabase

Database and login for the tracker app

EU (Ireland)

Cloudflare

Hosting of trackers.unlockt.store, storage of ebook files, security

Global network, incl. USA

Google (Workspace)

Our email inbox and business documents

EU and USA

Resend

Sending order and account emails

USA

Klaviyo

Newsletter and marketing emails (only if you sign up)

USA

Zapier and our own UNLOCKT sheets app

Automating order processing and code delivery

USA

Meta and Google Ads

Showing and measuring our ads (only with your cookie consent)

EU and USA

We also use these Shopify apps, which only get the store data they need for their task: Digital Products (ebook delivery), Shopify Messaging (store emails), Translate & Adapt (translations), SEOWILL (search-engine optimisation) and Instastore AI (store design).

We may also share data:

  • with our accountants, legal advisers and bank, where needed;
  • with the State Tax Inspectorate (VMI) and other authorities, courts or law enforcement when the law requires it, or to establish or defend legal claims;
  • with a buyer or successor if our business is sold or reorganised, under the same protections.

4. Transfers outside the EU/EEA

Some of our providers are based in, or use servers in, countries outside the EU/EEA, such as the USA and Canada. When your data is transferred there, we make sure it stays protected by:

  • an adequacy decision of the European Commission (for example for Canada, and for US companies certified under the EU–US Data Privacy Framework); or
  • the European Commission's Standard Contractual Clauses, with additional safeguards where needed.

You can ask us for more information about these safeguards at info@unlockt.store.

5. How long we keep your data

We keep personal data only as long as we need it for the purposes above, then delete or anonymise it.

Data

How long we keep it

Orders, invoices and payment records

10 years after the end of the year of purchase, as required by Lithuanian accounting and tax law

Tracker account and tracker entries

Until you delete your account, or we close the tracker service (section 11 of the Terms)

Messages, complaints and refund requests

3 years after the matter is closed

Reviews

While the review is published, and for 3 years after for verification records

Newsletter data

Until you unsubscribe or withdraw consent

Cookie and ad data

As set out in our Cookie Policy, at most 13 months

Security logs

Up to 12 months

If we need data longer to establish or defend a legal claim, we keep it until the claim is resolved. Deleted data may stay in encrypted backups for a short time before it is overwritten.

6. Cookies, marketing emails and ads

Cookies. We use cookies that are strictly necessary for the Store to work (for example your cart, checkout and login) without asking. Analytics and advertising cookies, including the Meta Pixel and Google tags, are used only if you accept them in our cookie banner. You can change your choice at any time through the cookie settings link at the bottom of the Store. See our Cookie Policy for details.

Marketing emails. We send newsletters and offers only if you sign up. Every email has an unsubscribe link, or you can email info@unlockt.store. You will still receive service emails about your orders and account.

Ads. If you accept advertising cookies, Meta and Google may use data about your visit to show you our ads and to measure how they perform. These platforms also process data as independent controllers under their own privacy policies, linked in section 3. You can also manage ad preferences in your Meta and Google account settings.

7. Your rights

Under the GDPR you have the right to:

  • access the personal data we hold about you and get a copy;
  • correct inaccurate or incomplete data;
  • delete your data, unless we must keep it, for example invoices for tax purposes;
  • restrict our use of your data in certain cases;
  • data portability – receive data you gave us in a common machine-readable format, including your tracker entries;
  • object to our use of your data based on legitimate interests, and at any time to direct marketing;
  • withdraw consent at any time, without affecting what we did before you withdrew it.

How to use your rights. Email info@unlockt.store. To protect your data, we may ask you to confirm your identity, usually by writing from the email address linked to your order or account. We reply within one month; if a request is complex we may extend this by up to two more months and will tell you why. Requests are free unless they are clearly unfounded or excessive.

Complaints. If you think we have handled your data unlawfully, please contact us first so we can try to fix it. You also have the right to complain to the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), L. Sapiegos g. 17, 10312 Vilnius, Lithuania, vdai.lrv.lt, or to the data protection authority in the EU country where you live or work.

8. Children, security, changes and contact

Children. The Store is intended for adults (18+), or younger users with a parent's or guardian's permission. We do not knowingly collect personal data from children under 14 without parental consent. If you are a parent or guardian and believe your child has given us personal data, email info@unlockt.store and we will delete it.

Security. We protect your data with measures such as encrypted connections (HTTPS), encrypted password storage, access limited to the people who need it, and reputable providers with strong security standards. No system is completely secure; if a data breach is likely to put your rights at high risk, we will inform you and the supervisory authority as the law requires.

Links to other sites. The Store links to other websites and social media (for example Instagram and TikTok). Their own privacy policies apply when you use them.

Changes to this policy. We may update this policy when our services or the law change. The effective date at the top shows the latest version. If a change is important, we will tell you by email or on the Store before it applies.

Contact us. For any question about your data or this policy:

MB Unlockt V. Putvinskio st. 60, Kaunas, Lithuania Email: info@unlockt.store Phone: +370 699 89645