Code of Conduct

The Privatlocker Code of Conduct (“Code”) is one of the ways we put Privatlocker’s values into practice. It’s built around the recognition that everything we do in connection with our work at Privatlocker is measured against the highest possible standards of ethical business conduct. Our commitment to the highest standards helps us hire great people, build great products, and attract loyal users. Respect for our users, for the opportunity, and for each other are fundamental to our success, and are something we need to support every day.

Privatlocker relies on its employees’ good judgment to uphold a high standard of integrity. We expect all Privatlocker employees to be guided by both the letter and the spirit of this Code. If you have a question or think that one of your fellow Privatlocker colleagues or the company may be falling short of our commitment we want to hear from you.

Who Must Follow Our Code?

We expect all of our employees and Board members to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for Privatlocker employees and Board members, we expect members of our extended workforce (temps, vendors, and independent contractors) and others who may be temporarily assigned to perform work or services for Privatlocker to follow the Code in connection with their work for us. Failure of a member of our extended workforce or other service provider to follow the Code can result in termination of their relationship with Privatlocker.

Whistle-Blowing Policy

Privatlocker prohibits retaliation against any worker at Privatlocker who reports or participates in an investigation of a possible violation of our Code, policies or the law. If you believe you are being retaliated against, please email privacy@privatlocker.com.

Serve Our Users

Our users value Privatlocker not only because we deliver great products and services, but because we hold ourselves to a high standard in how we treat users and how we operate generally.

Integrity

Our reputation as a company that our users can trust is our most valuable asset and it is up to all of us to make sure that we continually earn that trust. All our communications and other interactions with our users should be courteous, open and honest and serve to increase their trust in us.

Usefulness

Our products, features, and services should make Privatlocker very useful for all our users. We have many different types of users, from individuals to large businesses and our guiding principle is “what we are offering is very useful”.

Privacy, Security, and Freedom of Expression

We are asking users to trust us with their personal information. Preserving that trust requires that each of us respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of the personal information of our users and require that each of us take measures to protect user data from unauthorised access. Know your responsibilities under these procedures, and collect, use, and access user personal information only as authorised by our Privacy Policy and applicable data protection laws.

Privatlocker is committed to advancing privacy and freedom of expression for our users around the world. Where user privacy and freedom of expression face government challenges, we seek to implement internationally recognised standards that respect those rights as we develop products, do business in diverse markets, and respond to government requests to access user information or remove user content. Email privacy@privatlocker.com if you have questions on implementing these standards in connection with what you do at Privatlocker.

Responsiveness

We recognise relevant user feedback when we see it, and we do something about it. We take pride in responding to communications from our users, whether questions, problems, or compliments. If something is broken, fix it.

If at any time you feel our users are not being well-served, let someone in the company know about it. Continually improving our products and services is the responsibility of us all and we are proud that Privatlocker employees take the initiative to step forward when the interests of our users are at stake.

Support and Respect Each Other

Privatlocker has an unwavering commitment to prohibiting and effectively responding to harassment and discrimination, misconduct, abusive conduct, and retaliation. To that end, Privatlocker adheres to these Guiding Principles:

Commitment: Privatlocker is committed to a respectful, safe, and inclusive working environment for all employees and members of the extended workforce.

Care: Privatlocker creates an environment with an emphasis on respect for each individual at all levels of the organisation, including offering assistance and showing empathy to employees and members of the extended workforce throughout and after the complaint process.

Transparency: Privatlocker is open and transparent as an organisation regarding the frequency with which complaints arise regarding harassment, discrimination, misconduct, abusive conduct, and retaliation, and the Privatlocker’s approach to investigating and responding to those allegations.

Fairness & Consistency: Privatlocker ensures that individuals are treated respectfully, fairly, and compassionately in all interactions and applies policies, procedures, and outcomes consistently regardless of who is involved.

Accountability: Privatlocker holds all individuals responsible for their actions, and ensures that where appropriate, those individuals hold others accountable too.

Our Practice

Privatlocker employees are expected to do their utmost to create a supportive work environment, where everyone has the opportunity to reach their fullest potential, and be free from harassment, intimidation, bias, and unlawful discrimination.

Equal Opportunity Employment

Employment at Privatlocker is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, age, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

Harassment, Discrimination, and Bullying

Privatlocker prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual. If you believe you’ve been bullied, harassed, or discriminated against by anyone at Privatlocker, or by a Privatlocker partner or vendor, we strongly encourage you to immediately report the incident to your manger or a Board Director. Similarly, managers who learn of any such incident should immediately report it to a Board Director. The matter will be promptly and thoroughly investigated and take appropriate action.

Drugs and Alcohol

Consumption of alcohol is not banned at our offices but good judgment is required and never in a way that leads to impaired performance or inappropriate behavior, endangers the safety of others, or violates the law. Illegal drugs in our offices or at sponsored events are strictly prohibited.  If a there is reasonable suspicion to believe that an employee is using drugs or alcohol in a way that may adversely affect the employee’s job performance or the safety of the employee or others in the workplace an alcohol and/or drug screening may be requested. A reasonable suspicion may be based on objective symptoms such as the employee’s appearance, behavior, or speech.

Safe and Healthy Workplace

We are committed to a safe, healthy, and violence-free work environment. Behaviour that poses risk to the safety, health, or security of Privatlocker employees, our extended workforce, or visitors is prohibited. If you become aware of a risk to the safety, health, or security of our workplace you should report it to a Privatlocker Board Director immediately. If it is life-threatening or an emergency, call your local police, fire, or other emergency responders first.

Avoid Conflicts of Interest

A conflict of interest may occur when you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of Privatlocker or our users. Always avoid conflicts of interest and circumstances that could present the appearance of a conflict.  When considering a course of action, ask yourself whether the action you are considering could create an incentive or appear to create an incentive for you, to benefit yourself, your friends or family, or another business at the expense of Privatlocker. If the answer is “maybe” you must seek guidance, register the matter in our Conflicts of Interest register and obtain written approval of a Board Director before proceeding.

Inventions

Developing or helping to develop inventions that a) relate to Privatlocker’s existing or reasonably anticipated products and services, b) relate to your position at Privatlocker, or c) are developed using Privatlocker corporate resources are the property of Privatlocker and are subject to the provisions of Privatlocker’s employment contracts. If you have any questions about potential conflicts or intellectual property ownership involving an invention or other intellectual property, consult a Board Director.

Personal Relationships at Work

Certain relationships within Privatlocker may compromise or be seen to compromise your ability to perform your job responsibilities, may create uncomfortable or conflicted positions, and may raise issues of fairness, favoritism, or harassment. Therefore, be mindful of how your relationships within Privatlocker could impact or be perceived by others.

Romantic, physical or familial relationships are not permitted between Privatlocker employees or member of the extended workforce where one individual is in a position to exercise authority or supervision over the other.

Accepting Gifts, Entertainment, and Other Business Courtesies

Acceptance of inexpensive “token” non-cash gifts is permissible. Accepting gifts, entertainment, and other business courtesies from a Privatlocker competitor or business partner create the appearance of a conflict of interest, especially if the value of the item is significant and not permissible. Before accepting any gift or courtesy, consult your manager for approval.

Use of Privatlocker Products and Services

Avoiding potential conflicts of interest also means that you should not use Privatlocker products, services, internal tools, or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over users outside Privatlocker.

Preserve Confidentiality

Certain kinds of company information, if leaked prematurely into the press or to competitors, can hurt our product launches, eliminate our competitive advantage and prove costly in other ways. You must not reveal confidential Privatlocker material to anyone outside Privatlocker. You must also properly secure confidential Privatlocker material, safeguard confidential information that Privatlocker receives from others under non-disclosure agreements, and take steps to keep our trade secrets and other confidential intellectual property secret

Confidential Information

Make sure that information that is classified as “Confidential” is handled in accordance with Privatlocker’s data security requirements within its Privacy Policy. Disclosure of confidential information must be under a non-disclosure agreement approved by Privatlocker Legal and approved by a Board Director.

Some of us will find ourselves having family or other personal relationships with people employed by our competitors or business partners. Do not tell your significant other or family members anything confidential, and do not solicit any confidential information from them about their company.

Privatlocker Partners

Do not disclose any confidential information received from our partners. Do not accept confidential information from other companies without first having all parties sign an appropriate non-disclosure agreement approved by Privatlocker Legal.

Competitors/Former Employers

We respect our competitors and want to compete with them fairly so we do not want their confidential information. The same goes for confidential information belonging to any Privatlocker employees’ former employers. Should you happen to come into possession of a competitor’s confidential information, contact a Board Director immediately.

Outside Communications

You should ensure your outside communications (including online and social media posts) do not disclose confidential or proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of Privatlocker unless you are authorised to do so by Privatlocker. The same applies to communications with the press. Check with a Board Director before accepting any public speaking engagement on behalf of Privatlocker. Before making any external communication or disclosure, you should consult a Board Director.

Protect Privatlocker’s Assets

Privatlocker’s intellectual property rights (our trademarks, logos, copyrights, trade secrets, “know- how”, and patents) are among our most valuable assets. Unauthorised use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws. You must never use Privatlocker’s logos, trademarks, or other protected information or property for any unauthorised purpose. In addition, inappropriate use of others’ intellectual property may expose Privatlocker and you to criminal and civil fines and penalties.

Obey the Law

Privatlocker takes its responsibilities to comply with laws and regulations very seriously and each of us must comply with applicable legal requirements and prohibitions.