1. INTRODUCTION

1.1. Glue AB is a Swedish limited liability company with registration number 556944-8102, ("Glue", "we", "us", "our") with registered offices at Grev Turegatan 26, 114 38 Stockholm, Sweden. Glue provides this "Privacy Policy" to inform our users ("User", "you", "your") of our policies and procedures regarding the collection, use and disclosure of your "Personal Data" (i.e. all kinds of information that directly or indirectly may be connected to our Users) through:

(i) our website located at www.gluehome.com (the “Website” );
(ii) our software application (the “Application”);
(ii) Glue's hardware products; the Glue Smart Lock and/or the Glue Wi-Fi Hub (the "Device(s)"); or
(iv) third parties.

For ease of reading in this Privacy Policy, the Website, Application and Device(s) are collectively referred to as the “Services”.Glue is the data controller for processing your personal data in accordance with this Privacy Policy.

1.2. Please read this Privacy Policy carefully. By using our Services, you indicate that you have understood the contents of this Privacy Policy, including any transfer of your Personal Data to countries outside the EU/EEA

1.3. This Privacy Policy may change from time to time. Such amendments will be in English. If we make any material changes we will notify you by e-mail or through the Application.

2. PERSONAL DATA THAT WE COLLECT

2.1. Glue collects information in order to develop our Services, operate effectively and provide you the best products, services and experiences we can. We collect the following types of information when you access or use our Services or Device(s):

(i) Your name, phone number and e-mail address, when you register for an account with Glue or purchase our Device(s);
(ii) Mobile data and log data when you use certain features of the Services (such as IP address, zip code and GPS-based functionality on mobile devices used to access the Services, such as geolocation, the date and time you access or use the Services, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages);
(iii) Information you provide which may include, but is not limited to, your photo, credit card or other billing information and addresses;
(iv) User content that you provide via the Services;
(v) Communications between you and Glue;
(vi) Information related to your “Guests” (any person that is authorised by you to access your designated Device(s));
(vii) Information collected automatically, such as cookies (please see our Cookie Policy for more information);

2.2. We may combine the information listed above to help us develop and improve our Services and tailor our communications and advertisements to you. We may also anonymise your Personal Data or other information and use such anonymous information (i.e. not Personal Data) for developing and improving our Services. For the avoidance of doubt, the purposes set out in this section 2.3 are carried out solely with anonymised personal data.

2.3. Provision of any Personal Data or other information by you is voluntary. You may at any time refuse to provide personal information that we request. However, if you chose not to provide the requested Personal Data, some of the Services may be impaired and it may limit our ability to sell you products or to provide the Services to you.

3. HOW WE USE PERSONAL DATA
Glue uses the Personal Data that we collect to:
(i) provide and administer our Services;
(ii) better understand your interests and needs;
(iii) improve our Services;
(iv) communicate with you regarding the Services, as well as those of our partners and third-party services, that may be of interest to you including services that may be the subject of direct marketing and we may contact you to do so by post, telephone, mobile messaging (e.g. SMS, MMS, push notifications, in-app messaging, etc.) as well as by e-mail.
(v) communicate with you regarding the Services, as well as those of our partners and third party services which you opt for;
(vi) anonymise for statistics;
(vii) comply with our legal obligations;
(viii) resolve disputes with users, enforce our agreements and to protect, investigate and deter against fraudulent, harmful, unauthorised or illegal activity.

3.2 The legal grounds for Glue's processing of personal data in accordance with the above are the following. For the purpose mentioned in (i) above, the legal ground is that the processing is necessary in order for Glue to perform under an agreement with you. For the purposes mentioned in (ii) – (vi) and (viii) the legal ground is a balancing of interest where Glue has legitimate interests in being able to understand our customers, improve the Service and enhance your experience using the Service, communicate with you and others in order to provide the Service, produce statistics in order to evaluate and improve the Service and to establish, exercise and defend legal claims. For the purpose mentioned in (vii) above, the processing is necessary in order for Glue to comply with legal obligations, e.g. storing accounting information.

4. SHARING OF YOUR INFORMATION

4.1. We do not share or sell your Personal Data to third parties without your express consent. For the purposes set out in under this Privacy Policy, we share information under the following circumstances:

(i)We may employ third parties to administer and provide the Services on our behalf, (including, without limitation, bill and credit card payment processing, maintenance, administration, support, hosting and database management services). These third parties may have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purposes. We may share your Personal Data with third parties for the purposes described above, including to parties located outside the EU/EEA. In such case, we will ensure that the transfer is subject to adequate safeguards in order to protect the personal data transferred. You are entitled to receive a copy of such safeguards upon request.
(ii) If you access our Service through a third-party, or otherwise use a third party service provider in connection with the Services, or request or authorise us to give access or data to a third-party service provider (e.g. a delivery service, property management or rental service, in-house delivery service, or other service that you may use) we may provide Personal Data (about you and your Guests) and other information about the Services, the Device and their usage to such third-parties. You should only use trusted service providers, and only give your authorisation and information to trusted recipients. We have no obligation with respect to the functionality of such third-party services or the use of such information under control of these third parties.
(iii) If you invite Guests to access your Device(s), we may share certain elements of your information with them (name, lock location, picture, etc.) in order for them to access your designated Device. We may also similarly share their information with you. Any Guests who do not want to access the Services or do not want their Personal Data to be used or shared, must decline the invitation and not register an account with Glue or use the Services.
(iv) Glue cooperates with government and law enforcement officials or similar to enforce and comply with applicable laws. We will use, and disclose any information about you to such parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect the property and rights of Glue or a third party, to enforce our terms and conditions and this Privacy Policy, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical or inappropriate.

5. HOW WE STORE YOUR INFORMATION

We value the security of your Personal Data and the data relevant for your usage of our Services is of utmost importance for us. We follow industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. Your data is encrypted or hashed both while being transferred between our Services and your Device(s) and while being stored in our data centres. However, we cannot guarantee its absolute security. Encrypted data and access to encryption keys are handled with utmost care.


6. YOUR CHOICES ABOUT YOUR INFORMATION

6.1. Update your account with Glue at any time by logging in and changing your settings.
6.2. You are entitled to receive, free-of-charge, information on whether your personal data is being processed, and if so, which data is being processed, what is the purpose of the processing and who has access to your Personal Data. You are also entitled to receive a copy of the personal data processed by us.

6.3. You may also contact us to update and correct your personal information and to stop receiving our communications. When applicable data protections regulations so provide, you may also request restriction of the processing, data portability and to have your personal data deleted. Where the processing is based on our legitimate interest, you may object to the processing. If you have any questions about our Privacy Policy, please see our contact information under section 7. Glue makes good faith efforts to provide you with such access or correction if it is not otherwise restricted by applicable data protection regulations.

6.4. We are happy to help you if you have any inquiries or requests in relation to the processing of personal data. You may however always lodge complaints to Datainspektionen.

6.5. Glue will retain Personal Data for as long as needed to provide you with the Services. Following termination or deactivation of your account, Glue may retain and use your Personal Data as necessary to comply with our legal obligations, resolve any disputes, and enforce our agreements. Your Personal Data will not be kept longer than necessary. Glue owns and may freely use such data and information that has been anonymised by us (or third parties), for example for statistics purposes.

7. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Services, please contact us at [email protected]