This policy explains how and why Glase collects and uses your personal data. It also describes your rights with respect to Glase and how to exercise those rights. For questions about this policy or about how Glase works with data protection, please contact us by e-mail to email@example.com.
In order to offer you the services provided by Glase, we need to process your personal data in accordance with this policy. We always ensure that the information we collect about you and the personal data processing is done responsibly and securely, always with respect for your privacy.
Before using our services or our website, it is important that you read this policy and that you contact us at the above address in case there is something you do not understand. By continuing to use the services provided by Glase, you indicate that you understand the content of this policy in its entirety and that Glase may contact you electronically.
This policy applies to all services provided by Glase, but we may also provide additional personal data appendices related to specific services.
What type of personal data and information do we collect?
Information that you provide to us. In connection with creating an account in Glase or by using services provided by Glase, you may directly or indirectly provide information about yourself to Glase. This may include:
- Identity and personal data – name, personal ID number, date of birth, citizenship, and other type of identification data.
- Contact information – delivery and billing address, e-mail address, phone number, etc.
- Payment information – bank account number, payment card details (card number, issuing bank, validity date, and CVV code), billing details, etc.
Information we collect about you. When using any of the services provided by Glase (for example, when you make a purchase in a store or online, or add a new bank account), the following information may be collected:
- Personal and contact information – name, date of birth, personal ID number, billing and delivery address, e-mail address, mobile phone number, etc.
- Information about previous purchases – details of transactions and purchases made.
- Historical information – your purchases, payment and credit history.
- Financial information – a credit report including your income, any credits, and negative payment history.
- Information about how you use Glase – how you interact with our services, response times, possible errors, how you accessed and exited the service, as well as delivery notifications when we contact you.
- Device information – e.g. IMEI number and any other unique device identifiers, MAC address, IP address, language settings, browser settings, screen resolution, time zone, operating system, platform, and similar information.
- Geographic information – your geographic location.
- Information from social networking services – in cases where you have connected such services to Glase.
The information that you provide to Glase and the information we collect about you is necessary to enter into a contractual relationship with Glase. The other information we collect is generally necessary for other purposes as described below.
Why and how does Glase use your information?
All data is used to provide, perform, and improve the services offered by Glase. Glase processes your personal data on the following legal basis:
|Purpose of processing||Legal basis for processing|
|To confirm your identity and verify your personal and contact details and keep them updated.||To perform our contractual commitments to you|
|To administer your purchases and payments and maintain our customer relationship in order to, for example, fulfil our obligations to you and provide you with the information, products, and services that you request from us.||To perform our contractual commitments to you|
|To determine which payment methods we can offer you through, for example, internal or external credit checks.||To perform our contractual commitments to you and comply with applicable legislation|
|For analyses in troubleshooting, testing, data and customer analysis, development and administration of Glase’s services, and for other statistical purposes.||To perform our contractual commitments to you and other legitimate interests|
|To ensure that our services are presented appropriately and effectively to you and your device.||To perform our contractual commitments to you|
|To offer the serviced provided by Glase in a safe and secure manner and prevent the abuse of said services.||To perform our contractual commitments to you and comply with applicable legislation|
|To conduct risk analyses in order to prevent fraud and for risk management.||To comply with applicable legislation and other legitimate interests|
|To improve our services and for general business development, such as improving credit risk models in order to minimise fraud, develop new products and features, and new business opportunities.||Other legitimate interests|
|To communicate with you regarding the services you use or other services and products we believe may be of interest to you.||Other legitimate interests|
|To comply with applicable legislation, such as anti-money laundering and accounting laws, and capital adequacy requirements.||To comply with applicable legislation|
Automated decision-making and profiling
Automated decision-making means that a computer makes automated decisions that have or may have legal or similar implications. This is used in relation to credit risk assessments. These decisions can be based on a combination of your transaction history and information from external credit checks. Even though this is a automated process, you always hold the right to contact Glase to manually handle your case.
We employ profiling to based on your data and transaction history to analyse what services we may offer to you. Furthermore we use profiling to adjust what marketing messages that are communicated to you. You may contact Glase at any time by e-mailing firstname.lastname@example.org and informing us that you no longer wish to receive this type of communication.
Communicate with you
Glase may also use your data to communicate relevant information regarding the services you use, campaigns, competitions, customer satisfaction surveys, or other services we believe may be of interest to you. This may take in place in the form of direct advertising through electronic communication channels or by phone. When receiving such information, you will always be offered the opportunity to say no to future communication of this kind. You may also contact Glase at any time by e-mailing email@example.com and informing us that you no longer wish to receive this type of communication.
Who may we share your information with?
We may transfer or share your information with selected third parties as described below. When doing so, we take all reasonable legal, technical, and organisational steps to ensure that your data is handled securely and with an adequate level of protection upon transfer to or sharing with such selected third parties. We will not sell your personal data to third parties unless we have your permission to do so.
- Credit reporting agencies and similar providers. When applying for one of Glase’s payment methods, your personal data may be shared with credit reporting agencies and providers of similar services in order to assess your credit rating, but also to confirm your identity and address.
- Debt collection agencies. Your personal data may be disclosed in connection with the transfer of debt to a debt collection agency or the equivalent.
- Authorities. Glase may disclose necessary information to authorities such as the police, the Swedish Tax Agency, or other authorities if we are required to do so by law or if you have consented to us doing so. An example of such a legal requirement is the obligation to disclose information related to counteracting money laundering and terrorism financing.
- Others. Logistics and shipping companies that deliver your goods (only applicable to web and mobile app users)
- Divestment. Glase may share your information with third parties:
- In the event Glase sells or buys a business or assets, Glase may disclose your personal data to a potential seller or buyer of such business or assets.
- If Glase, or a substantial part of Glase’s assets, are acquired by a third party, personal data about Glase’s customers may be shared as part of a merger or transfer.
Where do we process your personal data?
The starting point for our processing of your data is that it will take place within the EU/EEA. However, in certain situations the data may be transferred to, and processed in, a country outside the EU/EEA, by a company within the Glase Group or by another vendor or subcontractor. In such cases, Glase will do its utmost to ensure that your data is protected by taking all reasonable legal, physical, technical, and organisational steps to ensure that your data is handled securely and with an adequate level of protection, comparable to the level of protection offered within the EU/EEA. Please note that even though we take reasonable steps to protect your information, no computer system, network, website, etc. is completely secure.
For how long do we keep your personal data?
We keep your personal data only for as long as it is necessary to perform our contractual commitments to you and as long as it is required by statutory periods of retention. When retaining your data for purposes other than our contractual commitments, such as to meet requirements for anti-money laundering, accounting, and regulatory capital requirements, we only retain the data for as long as it is necessary and/or statutory for each purpose. An example of a retention period is related to preventing, detecting, and investigating money laundering, terrorism financing, and fraud, where information needs to be stored for at least five (5) years after the business relationship ceased.
What are your rights?
- Right of access to your data.You may request a copy of your data and verify the information we have about you. The copy is free to order.
- Right to rectification. You have the right to correct inaccurate or incomplete data about yourself.
- Right to object. You have the right to object to our processing on the basis of legitimate interest. We will then assess the matter and if there are grounds for legitimate interest, we may proceed with the processing.
- Right to data portability. You have the right to obtain a copy of the personal data we have about you in a structured format.
- Right to erasure (”right to be forgotten”). You have the right to request the erasure of your personal data in cases where the data is no longer necessary for the purpose for which it was collected. There may, however, be legal obligations for Glase as a payment institution that prevent us from immediately erasing parts of your data. These obligations derive from accounting and tax legislation, banking and money laundering legislation, but also from consumer rights legislation. In such cases, we block the data that we are required to retain from being used for purposes other than fulfilling such legal obligations.
Seqr Payments AB (“Glase”) is a Swedish limited company registered with the Swedish Companies Registration Office with corporate ID number 556876-5100. The company has its registered office at Regeringsgatan 52, SE-111 56 Stockholm, Sweden.
If you have complaints about our handling of your personal data, please contact our customer service for help to get in touch with the person best suited to respond to your complaint. You can also contact the Swedish Data Protection Authority (www.datainspektionen.se).
Glase has a data protection officer as well as a team of customer service staff with focus on data protection issues. Please feel free to ask any questions about how we work with data protection and how we handle your personal data directly to our customer service. You can easily reach them by sending an e-mail to Glase customer service at firstname.lastname@example.org.
Personal data controller:
Seqr Payments AB
SE-111 56 Stockholm, Sweden
Glase is the personal data controller of the processing of your personal data as described above. Glase complies with Swedish data protection laws.
Visit glase.se for more information about Glase.
Entry into force