Overview
This privacy policy applies between you (the user of our Website and Application) and Gudrun AB (registration number 559496-7654), the owner and provider of the Website and Application. We take the privacy and security of your information seriously. This policy explains how we collect, use, disclose, store, and protect your Data when you access or use our Website and Application.
This privacy policy should be read together with any applicable terms and conditions governing your use of the Website and/or Application.
Company details
Data Controller: Gudrun AB (trading as Qlero).
Registered address: c/o CC Young & Co Sverige AB, Box 271, 581 02 Linköping, Sweden.
Website: https://qlero.io
Application: https://app.qlero.io (and any other qlero.io subdomains used to provide the service).
Privacy contact: hello@qlero.io
Definitions and interpretation
In this privacy policy, the following definitions are used:
Data – All information that you submit to us via the Website or Application, and any information we otherwise receive about you in connection with providing our services. Where applicable, this includes personal data as defined in Data Protection Laws.
Cookie – A small text file placed on your device when you visit certain parts of the Website and/or use certain features of the Website or Application. Details are set out in the Cookie Policy.
Data Protection Laws – All applicable laws relating to the processing of personal data, including the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), any implementing national laws, and, where applicable, the UK GDPR and the UK & EU Cookie Law.
GDPR – The EU General Data Protection Regulation (Regulation (EU) 2016/679).
UK & EU Cookie Law – The Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended.
We, us, our – Gudrun AB (trading as Qlero).
User, you – Any person who accesses or uses the Website or Application and is not (i) employed by us and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to us and accessing the Website or Application in connection with the provision of such services.
Website – https://qlero.io and any sub-domains of this site unless expressly excluded by their own terms and conditions.
Application – The application hosted at https://app.qlero.io and any other qlero.io sub-domains used to deliver the service, unless expressly excluded by their own terms and conditions.
Unless the context requires a different interpretation: (a) the singular includes the plural and vice versa; (b) references to clauses are to clauses of this privacy policy; (c) references to a person include firms, companies, government entities, trusts and partnerships; (d) “including” means “including without limitation”; (e) references to statutory provisions include modifications or amendments; and (f) headings do not form part of this policy.
Scope of this privacy policy
This privacy policy applies only to the actions of Gudrun AB and users in relation to this Website and Application. It does not extend to websites that can be accessed from our Website or Application, including (without limitation) any links we may provide to third-party or social media websites.
For the purposes of Data Protection Laws, Gudrun AB is the “data controller” for the personal data described in this policy unless we indicate otherwise.
Data we may collect
We may collect the following Data from you (which may include personal data), in each case in accordance with this privacy policy:
- Name and professional details (e.g., your name and role).
- Contact information (e.g., email address and telephone number).
- Billing and payment information (e.g., payment card details or payment account identifiers), where you make payments through the Website or Application.
- IP address and other online identifiers (automatically collected).
- Browser type and version and device/operating system information (automatically collected).
- Usage data, such as pages viewed, actions taken in the Application, and URLs and referrers (automatically collected).
How we collect data
We collect Data in the following ways:
- Data you provide to us directly.
- Data we receive from other sources (including our customers and business partners).
- Data collected automatically when you use the Website or Application.
Examples of when you give Data to us include when you:
- contact us via the Website, by phone, post, email, or other means;
- register for an account and set up access to the Application;
- respond to surveys or provide feedback (optional);
- use our services and features within the Application.
Data received from third parties
We may receive Data about you from third parties. In particular, labels and publishers using the system may enter or upload their client information into the Application for the purpose of processing royalties and payments.
Data collected automatically
To the extent that you access the Website or Application, we may collect Data automatically, including:
- information about your visits (date, time, frequency, and how you interact with content), which helps us improve content and navigation;
- information collected via cookies and similar technologies, subject to your cookie preferences and applicable law.
How we use data
We may use your Data to provide and improve our services and for the following purposes:
- Internal record keeping and administration.
- Creating and managing user accounts and access permissions.
- Providing royalty services and related functionality within the Application.
- Processing payments and payouts (where applicable).
- Customer support, troubleshooting, and responding to enquiries.
- Security, fraud prevention, auditing, and ensuring the integrity of the Website and Application.
- Improving and developing our Website and Application (including analytics).
- Complying with applicable legal obligations and enforcing our terms.
We process your Data where it is necessary for our legitimate interests (for example, to operate and improve our services safely and effectively), unless those interests are overridden by your interests or fundamental rights and freedoms. Where applicable, you have the right to object to such processing (see “Your rights” below).
When you register for an account and use our services, the legal basis for processing is typically the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Where we rely on consent (for example, certain cookies or marketing communications where required by law), you may withdraw that consent at any time.
Who we share data with
We may share your Data with the following categories of recipients for the reasons described:
- Service providers who support the operation of our Website and Application (for example, hosting, storage, analytics, communications, and support tools) where processing personal data is required to provide the service.
- Payment service providers that process payments made through the Website or Application and, where applicable, facilitate royalty payouts.
Where we use service providers, we take steps to ensure appropriate safeguards are in place, including contractual protections consistent with Data Protection Laws.
Keeping data secure
We use technical and organisational measures to safeguard your Data, including (as appropriate):
- access controls (including unique user credentials such as username and password);
- secure hosting environments and restricted access to systems;
- encryption in transit (for example, TLS/SSL) for communications and payment flows;
- processes to detect, respond to, and investigate suspected security incidents.
If you suspect any misuse, loss, or unauthorised access to your Data, please contact us immediately at hello@qlero.io.
For general guidance on online safety, you may wish to consult resources such as Get Safe Online (www.getsafeonline.org).
Data retention
Unless a longer retention period is required or permitted by law, we will only hold your Data for as long as necessary to fulfil the purposes described in this privacy policy or until you request that the Data be deleted (subject to legal and contractual requirements).
Even if we delete Data from active systems, it may persist for a period of time in backups or archival media for legal, tax, regulatory, or security purposes.
Your rights
Under Data Protection Laws, you may have the following rights (subject to applicable conditions and limitations):
- Right of access – request a copy of the personal data we hold about you.
- Right to rectification – request correction of inaccurate or incomplete personal data.
- Right to erasure – request deletion of your personal data in certain circumstances.
- Right to restriction – request that we limit how we use your personal data in certain circumstances.
- Right to data portability – request that we provide your personal data to you or another controller in a structured, commonly used, machine-readable format.
- Right to object – object to our processing of your personal data in certain circumstances, including processing based on legitimate interests.
- Right to withdraw consent – where processing is based on consent, withdraw consent at any time (this does not affect the lawfulness of processing before withdrawal).
To make enquiries, exercise any of your rights, or withdraw consent (where applicable), please contact us at hello@qlero.io.
If you are not satisfied with how we handle a complaint, you may lodge a complaint with the relevant supervisory authority. In Sweden, this is Integritetsskyddsmyndigheten (IMY). You may also complain to your local authority where you live, work, or where the alleged infringement occurred.
Links to other websites
Our Website and Application may contain links to third-party websites. We do not control these websites and are not responsible for their content or privacy practices. This privacy policy does not apply to your use of third-party websites, and you should read their privacy policies before using them.
Changes of business ownership and control
We may expand or reduce our business and this may involve a sale, transfer, or reorganisation of all or part of our business. Where permitted by law, Data provided by users may be transferred as part of such a transaction, and any new owner or controlling party may use the Data for the purposes for which it was originally collected, subject to this privacy policy.
We may also disclose Data to a prospective purchaser of our business or any part of it, subject to appropriate safeguards.
Cookies
We may place and access certain Cookies on your device. We use Cookies and similar technologies to improve your experience of using the Website and Application and to improve our services.
Cookies are used in accordance with applicable cookie laws. Where required, we will present you with a cookie notice and request your consent before placing non-essential cookies.
Cookies and similar technologies may be used for the following purposes:
- to recognise and count visitors and understand how users move around our Website and Application;
- to remember your preferences and settings (for example, language or region);
- to support core functionality such as authentication and session management.
You can manage cookies through your browser settings. Disabling cookies may affect the availability or functionality of certain features.
For more information about cookies, including how to disable and delete them, you may refer to aboutcookies.org.
Children
The Website and Application are not intended for children under the age of 16 in the United Kingdom, the European Union, or the European Economic Area.
General
You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
If any provision of this privacy policy is found to be invalid, unlawful, or unenforceable, that provision will be deemed deleted to the extent required, and the remaining provisions will continue in full force and effect.
No delay, act, or omission by a party in exercising any right or remedy will be deemed a waiver of that or any other right or remedy.
Governing law and jurisdiction
This privacy policy and any dispute or claim arising out of or in connection with it shall be governed by and construed in accordance with the laws of Sweden. The courts of Sweden shall have exclusive jurisdiction, subject to any mandatory consumer protection provisions that apply in your country of residence.
Changes to this policy
We may update this privacy policy from time to time to reflect changes to our practices or to comply with legal requirements. Any changes will be posted on the Website and/or within the Application, and will be effective when posted.
Contact us
If you have any questions about this privacy policy or how we process your Data, please contact us at hello@qlero.io.
