• Introduction
  • 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");
    • (iii)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".
  • Please read this Privacy Policy carefully.
  • 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. If you do not accept the amendments you may at any time stop using our Services and the Devices through deactivating your account with Glue.
  • Personal Data that we collect
    Glue collects information in order to develop our Services, operate effectively and provide you the best products, services and experiences we can.

    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.

    We collect and ask the following types of information when you access or use our Website, Services, Applications or Device(s):
  • Online purchase and installation

    Why do we use your personal data?
    We will use your personal data to manage your purchase online through gluehome.com by processing your orders and returns via our online services and send you notifications of delivery status or in the event of any problems with the delivery of your items.
    We will use your personal data to manage your payments. We will use your personal data to arrange the installation of our devices through our 3rd party installation partners.Your personal data is being used to identify you and to confirm your address with external partners.

    What types of personal data do we process?
    We will process the following categories of personal data:
    • (i)contact information such as name, address, e-mail address and telephone number
    • (ii)payment information and payment history
    • (iii)order information

    Who has access to your personal data?
    Your personal data that is forwarded to third parties is only used to provide you with the services mentioned above. We use external companies to validate your address, communication agencies to send you order confirmation, warehouse and distribution suppliers in connection with the delivery of your order, and payment service providers for processing your payment.
    Please be aware that many of these recipient companies have an independent right or obligation to process your personal data.

    What is the legal ground to process your personal data?
    The processing of your personal data is necessary for Glue to fulfil the agreement with you to manage and deliver the order to you, and manage the service of having your devices installed for you.
  • Provide and administer our services

    Why do we use your personal data?
    We will use your personal data to create and manage your personal account in order to give you a personalised and relevant experience. E.g.to apply personal greetings to emails we send you or to allow you to log on to your account.

    What types of personal data do we collect?
    We will always process your e-mail address and/or phone number and password that you submit to us when you sign up for your Glue account.
    We will process your address and GeoLocation Lat/Long data attached to the locks in your account to deliver our in-home delivery services.
    We will process following categories of personal data to provide personalised services:
    • (i)contact information such as name, last name
    • (ii)account settings

    Who has access to your personal data?
    Data that is forwarded to third parties, is only used to provide you with the services mentioned above

    What is the legal ground to process your personal data?
    The processing of your personal data is necessary to fulfil our agreement with you and our legitimate interest to give you a personalized Service.
  • Improve our services

    Why do we use your personal data?
    We will use data to evaluate, develop and improve our services, products and systems for all of our customers. For this purpose we will not analyse your data on an individual level, all processing will be done on pseudonymised data. E.g. we will track how many customers interact with a certain feature within the Application over a given time frame and count your usage of this feature as part of an overall anonymised usage statistic.

    What types of personal data do we collect?
    We will also process the following categories of personal data connected to your cookies/ use of our application
    • (i)click / interaction history
    • (ii)navigation and browsing history

    Who has access to your personal data?
    Data that is forwarded to third parties, is only used to provide you with the services mentioned above, to optimize the website/ application, website agencies and analysis tools for product improvements. We use web/app-analysis companies to analyse our customers' online behaviour on a general level.

    What is the legal ground to process your personal data?
    The processing of your personal data is based on our legitimate interest to manage, administer and improve your usage of our website, application and devices.
  • Customer service

    Why do we use your personal data?
    We will use your personal data to manage your queries, to handle complaints and warranty matters for products and technical support matters through e-mail, our chat function, telephone and through social media. We may also contact you if there is a problem with your order.

    What types of personal data do we process?
    We will process any data you provide to us, including the following categories
    • (i)contact information such as name, address, e-mail address and telephone number
    • (ii)payment information and payment history
    • (iii)order information
    • (iv)account or member number
    • (v)all correspondence in the matter

    Who has access to your personal data?
    Data that is forwarded to third parties is only used to provide you with the services mentioned above.

    What is the legal ground to process your personal data?
    Our legitimate interest to handle customer service requests and to fulfil the agreement with you for warranty handling.
  • Fulfillment of legal obligations

    Why do we use your personal data?
    We will use your personal data to comply with our legal obligations, for example tax and book-keeping requirements, court rulings and requests from authorities.

    What types of personal data do we process?
    We will process following categories of personal data
    • (i)customer number
    • (ii)order number
    • (iii)name
    • (iv)postal address
    • (v)transaction amount
    • (vi)transaction date

    Who has access to your personal data?
    Your data will be shared within Glue AB and its affiliates.
    We will share your personal data with IT companies that provide bookkeeping system solutions.

    What is the legal ground to process your personal data?
    The processing of your personal data is necessary for Glue to fulfil its legal obligations.
  • Establish, exercise and defend legal claims

    Glue may process your Personal data for the purposes of establishing, exercising and defending legal claims in the un-likely event of a dispute. Personal data processed for these purposes include:

    Why do we use your personal data?
    We will use your personal data to comply with our legal obligations, for example tax and book-keeping requirements, court rulings and requests from authorities.

    What types of personal data do we process?
    We will process following categories of personal data
    • (i)customer number
    • (ii)order number
    • (iii)name
    • (iv)other information necessary for the purpose

    Who has access to your personal data?
    Your data will be shared within Glue AB and its affiliates.
    We will share your personal data with IT companies that provide bookkeeping system solutions.

    What is the legal ground to process your personal data?
    The legal basis for the above processing of your personal data is that the processing is necessary in order to fulfill our legitimate interest to establish, exercise and defend legal claims.
  • Direct marketing

    Why do we use your personal data?
    We will use your personal data to send you marketing offers, information surveys and invitations through emails, text messages, and other means. In order to optimise your experience with Glue we will provide you with relevant information, recommended products, send you reminders of products left in your shopping bag and send you personalised offers. All these services are based on what you have clicked on and information you have submitted to us, e.g we might ask you if you would want to complete the purchase of a Glue Smart Lock.

    What types of personal data do we process?
    We will process following categories of personal data
    • (i)contact information such as e-mail address, telephone number and address
    • (ii)what products and offers you have clicked on
    • (iii)what type of in-Home services you have interacted with

    If you have a Glue account we will also process your personal data submitted in relation to the account and membership such as
    • (i)name
    • (ii)address
    • (iii)how you navigated and clicked on the website or within the application

    Who has access to your personal data?
    Data that is forwarded to third parties is only used to provide you with the services mentioned above, to media agencies and technical suppliers for distribution of physical and digital direct marketing. We never pass on, sell or swap your data for marketing purposes to third parties outside of Glue and its affiliates.

    What is the legal ground to process your personal data?
    The processing of your personal data is based on your consent when you agree to direct marketing.

    Your right to withdraw your consent
    You have the right to withdraw your consent for the processing of your personal data at any time and also object to direct marketing. When you do so, Glue won't be able to send you any further direct marketing offers or information based on your consent.

    You can opt out from direct marketing by the following means:
    • (i)following the instruction in each marketing post
    • (ii)by editing the settings of your Glue account
  • Information we automatically collect from your use of the glue application and/or website
    • (i)Geo-location Information. When you use certain features of the application, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device's GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device's settings menu. We do this only at certain times and will always display the data to you before storing it.
    • (ii)Usage Information. We collect information about your interactions with the Application and Website, such as the pages or content you view, and other actions.
    • (iii)Log Data and Device Information. We automatically collect log data and device information when you access and use the Application or our Website, even if you have not created an account or logged in. That information includes, among other things: details about how you've used the application or website (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you've viewed or engaged with before or after using the website or application.
    • (iv)Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies, or engage others to track your behavior on our behalf. While you may disable the usage of cookies through your browser settings, Glue currently does not respond to a "Do Not Track" signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.
  • Sharing of your information
  • We do not share or sell your Personal Data to third parties without your express consent.
    • (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.You may ask to see a copy of the safe guards and further information as to which countries your personal data is transferred.
    • (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.
  • 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 using the same high grade security standards that banks and governments use, 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.
  • Data retention
  • We will retain Personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by local law to which Glue is subject. We are using the following criteria to establish our retention period: (i) as long as we have an ongoing relationship with you (either as an individual or in your capacity as employed by one of our corporate customers, suppliers or co-operations partners); (ii) as required by legal obligations to which Glue is subject (such as tax and accounting obligations); and (iii) as advisable in light of our legal position (such as applicable statutes of limitations).
  • Right to erasure
  • If you no longer want us to use your information to provide our services and products to you, you can request that we erase your personal information and close your Glue Account. Please note that if you request the erasure of your personal information:
    • You will no longer have access to your Glue account through our Application and lose the ability to interact with our devices via our application.
    • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Glue may keep some of your information for tax, legal reporting and auditing obligations.
    • Because we maintain the Glue Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
    • Glue owns and may freely use such data and information that has been anonymised by us (or third parties), for example for statistics purposes.
  • Right to access
  • You are entitled to obtain a confirmation from Glue as to whether your Personal Data are being processed by us and, if so, access to the Personal Data and the following information:
    • the purposes of the processing;
    • the categories of Personal Data processed;
    • the recipients of Personal Data (in particular in countries outside EU/EEA);
    • the recipients of Personal Data (in particular in countries outside EU/EEA);
    • information about the rights stated herein;
    • information about the source from which the Personal Data are collected; and
    • the existence of automated decision-making, including profiling.

    Moreover, you are upon your request entitled to receive a copy of your Personal Data in a commonly used electronic format.
  • RIGHT TO PORTABILITY
  • Whenever Glue processes your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.
  • RIGHTS IN RELATION TO AUTOMATED DECISION-MAKING, INCLUDING PROFILING
  • You have the right to not be subject to fully automated decision-making, including profiling, if such decision-making has legal effects or similarly significantly affects you. This right does not apply if the decision-making is necessary in order to perform under a contract with you, if the decision-making is permitted under applicable law or if you have provided your explicit consent.
  • RIGHT TO RECTIFICATION
  • You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed. If you have a Glue Account, you can edit your personal data under your account.
  • RIGHT TO OBJECTION
  • You have the right to object to processing of your personal data that is based on Glue's legitimate interest. Glue will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.

    You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.

    You can opt out from direct marketing by the following means:
    • following the instruction in each marketing email
  • RIGHT TO WITHDRAW CONSENT
  • You can at any time withdraw a consent to processing of personal data.
  • HOW TO CONTACT US
  • If you have any questions about this Privacy Policy or the Services, please contact us at support@gluehome.com.
  • COMPLAINTS TO THE SUPERVISORY AUTHORITY
  • You are welcome to contact us with any enquiries and complaints that you may have regarding the processing of your Personal Data. However, you also have the right to lodge complaints pertaining to the processing of your Personal Data to the Swedish Data Protection Authority (Sw. Dataskyddsmyndigheten).