Glede logo

Glede Privacy Policy

In this Privacy Policy, "us", ";we", or "our"; means Glede Norway AS. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your Personal Information.

By providing Personal Information to us, you consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Personal Information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information and the financial information, including the credit card information of the Glede Business User.

Table of content

1. Definitions

1.1 In this Privacy Policy:

(a) the following capitalised terms have the following meanings:

  1. Non-personal Information means information which does notrelate to a person and/or cannot be used to identify a person.
  2. Personal Information means any information which can be used to identify an individual and described in detail in clause 2.
  3. We will treat all personal information in accordance with any and all obligations that are binding upon us under the Personal Data Act of 15 June 2018.

(b) any other capitalised terms which are defined in the Terms & Conditions have the same meaning as they do in the Terms of Use.

2. What is "personal information"?

Personal information held by you may include your:

  1. name and date of birth;
  2. Company organization number, full name, email address and mobile number for individuals using the Platform;
  3. residential and business postal addresses, telephone/mobile/fax numbers and email addresses;
  4. bank account and/or credit card details for agreed billing purposes;
  5. your computer and connection information; and
  6. any information that you otherwise share with us.

3. What Personal Information do we collect?

3.1 We may collect Personal Information about you when you use the Platform, register on the Platform or interact with us in any way

3.2 Information you provide to us: We collect all information which Users voluntarily provide to us through using the Platform or interacting with us. This includes information provided:

  1. during registration;
  2. during correspondence, enquiries, support services or phone calls, or customer surveys; or
  3. uploaded onto the Platform in any way.

The Personal Information we may collect includes without limitation:

  1. basic information such as your first and last name;
  2. contact information including email address and phone number;
  3. demographic information such as postal code, age, and gender;
  4. other relevant information in relation to your use of the Platform;
  5. geographic location;
  6. any other information that enables Users to be personally identified.

3.3 Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Platform (Automatic Data). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Platform, details of the Glede Gifts you have sent or received or information about how you came to the Platform. We collect Automatic Data based on your consent which was granted to us by you when you registered as a User and accepted this Privacy Policy.

3.4 Sensitive Information: Sensitive information is defined in the Personal Data Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. Sensitive information will be used by us only:

  1. For the primary purpose for which it was obtained;
  2. For a secondary purpose that is directly related to the primary purpose;
  3. With your consent; or where required or authorised by law.

3.5 Information we obtain from others: We may also collect or receive Personal Information from third party sources, such as other Users, suppliers, social media or other third-party integrations.

4. Why do we collect, use and disclose Personal Information?

4.1 We may collect, hold, use and disclose your Personal Information for the following purposes:

  1. to verify your identity;
  2. to enable you to access and use our Platform, send or receive Glede Gifts and interact with Users;
  3. to operate, protect, improve and optimise our Platform, business and our Users’ experience, such as to perform analytics, conduct research and foradvertising and marketing;
  4. to send you service, support and administrative messages, reminders,technical notices, updates, security alerts, and information requested byyou;
  5. to send you marketing and promotional messages and other informationthat may be of interest to you, including information sent by, or on behalfof, our business partners that we think you may find interesting;
  6. to administer rewards, surveys, contests, or other promotional activities orevents sponsored or managed by us or our business partners; and
  7. to comply with our legal obligations, resolve any disputes that we mayhave with any of our Users, and enforce our agreements with third parties.

4.2 We may also disclose your Personal Information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the services that you receive.

4.3 The information we collect is not distributed, sold or leased to third parties for commercial purposes, except for other purposes when we have your permission or when we are obliged to do so.

5. Do we use your Personal Information for direct marketing?

5.1 We and/or our carefully selected business partners may send you direct marketing communications and information about the services offered on our Platform. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Personal Data Act. You may opt-out of receiving marketing materials from us by contacting us through the contact us feature below, or by using the opt-out facilities provided (e.g. an unsubscribe link).

6. To whom do we disclose your Personal Information?

6.1 We may disclose Personal Information for the purposes described in this Privacy Policy to:

  1. our employees and related bodies corporate;
  2. EML Money DAC, authorised by the Central Bank of Ireland under the European Union (Payment Services) Regulations 2018 (Ref C95957);
  3. Mastercard;
  4. third-party suppliers and service providers (including providers for the operation of our Platform and/or our business or in connection with providing our services to you);
  5. professional advisers, dealers and agents;
  6. payment systems operators (e.g. merchants receiving card payments);
  7. our existing or potential agents, business partners or partners;
  8. our sponsors or promoters of any competition that we conduct via ourservices;
  9. anyone to whom our assets or businesses (or any part of them) aretransferred;
  10. specific third-parties authorised by you to receive information held by us;and/or
  11. other persons, including government agencies, regulatory bodies and lawenforcement agencies, or as required, authorised or permitted by law.

7. Using our website and cookies

7.1 We may collect Personal Information about you when you use and access our Platform. While we do not use browsing information to identify you personally, we may record certain information about your use of our Platform, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

7.2 We may also use "cookies"; or other similar tracking technologies on our Platform that help us track your Platform usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our Platform may not work as intended for you if you do so.

7.3 We may also use cookies to enable us to collect data that may include Personal Information. For example, where a cookie is linked to your account, it will be considered personal information under the Personal Data Act. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy.

8. Security

8.1 We may hold your Personal Information in either electronic or hard copy form. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, we cannot guarantee the security of your Personal Information.

9. Retention

9.1 We may retain your Personal Information as long as you register to the Platform. You may close your account by contacting us. However, we may retain Personal Information for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

10. Exclusions

10.1 Links: Our Platform may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

10.2 Personal Information Provided to Others: This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through the Platform or through any other means, or information posted by you to any public areas of the Platform.

11. Your Rights

11.1 We want you to be in control of how your personal information is being used by us. As a user of Glede´s Platform you have several rights associated with your information. In accordance with European General Data Protection Regulation (GDPR) you have the right to the following:

  • The right to access. You have the right to request Glede for copies of your personal information. We may charge you a small fee for this service. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.
  • The right to rectification. You have the right to request that Glede correct any information you believe is inaccurate. You also have the right to request Glede to complete the information you believe is incomplete.
  • The right to erasure. You have the right to request that Glede erase your personal information, under certain conditions.
  • The right to restrict processing. You have the right to request that Glede restrict the processing of your personal information, under certain conditions.
  • The right to object to processing. You have the right to object to Glede processing of your personal information, under certain conditions.
  • The right to data portability. You have the right to request that Glede transfer the information that we have collected to another organization, or directly to you, under certain conditions.

These rights can be exercised at any time by contacting us at support@glede.app. If you make a request, we have one month to respond to you.

12. Information About Children

12.1 Glede´s Platform is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16 years of age. If you are under the age of 16, please do not use the Glede Platform and do not provide any personal information to us. If you believe that we are processing the personal information concerning a child, please contact us using the information provided under the “Contact Us” section, at the bottom of this page.

13. Changes to the Privacy Policy

13.1 We reserve the right to change this Privacy Policy from time to time, to reflect how we are processing your information. If you disagree to the updated Privacy Policy, you may cancel your account and discontinue using our Platform. If you do not cancel your account before the changes in the Privacy Policy becomes effective, your continued access to the Glede Platform and use of our Platform will be subject to the updated Privacy Policy.

13.2 The Privacy Policy was last updated on 25th of August 2022.

14. Making a complaint

14.1 If you think we have breached the Personal Data Act or any other relevant privacy law, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us using the contact us feature below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

15. Contact Us

15.1 For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us using the details set out below:

15.2 Contact us at support@glede.app.