Privacy Policy

This Policy applies to Account Holders, Recipients, website visitors and people who contact or report content to Gluuer. It should be read with the Account Holder Terms and the Recipient Terms.

Gluuer operates globally from Australia and aims to handle personal information consistently with applicable privacy and data-protection laws, including the Australian Privacy Principles where they apply.

Gluuer is a trading name operating under ABN 51 152 756 523. Our address is Level 1, 9-13 Bronte Road, Bondi Junction NSW 2022, Australia. Privacy inquiries may be sent through our contact page at gluuer.com/contact.

An Account Holder decides what Resource to offer, what information to request, whether to invite optional marketing consent and how to use Contacts after collection. The Account Holder is responsible for its own privacy notices, marketing activities, exported Contacts and compliance obligations.

Gluuer processes Recipient information to host the Resource Page, record the submission, deliver the requested Resource, provide analytics, maintain security and support the Account Holder. In some jurisdictions, Gluuer may act as a processor or service provider for the Account Holder for these functions.

Gluuer also determines how personal information is used for Account administration, billing, security, fraud prevention, service analytics, legal compliance, product support and Gluuer's own communications. For those purposes, Gluuer acts independently as the relevant controller or business where those concepts apply.

4.1 Account Holder information

• Name, email address, account identifier and authentication information.
• Business name, sender name, reply-to address and profile information.
• Plan, subscription, billing status and Stripe customer or transaction identifiers. Gluuer does not store full payment-card details.
• Files, destination URLs, titles, descriptions, branding, consent wording and other User Content.
• Contacts, consent records, exports, integration settings and synchronization results.
• Support messages, complaints, appeals and other communications.
• Login, publication, upload, device, browser, IP address, approximate location, security and usage information.

4.2 Recipient information

• Email address submitted through a Resource Page.
• The Account Holder, Resource and Resource Page connected with the submission.
• Whether optional marketing consent was displayed and selected.
• Submission date and time, IP address, browser, device and approximate location information.
• Delivery, bounce, complaint, email-open, link-open, download and access events where those features are enabled.
• QR code, campaign, embed, referral or other source information.
• Reports, support requests and communications sent to Gluuer.

4.3 Website and cookie information

• Pages viewed, buttons selected, account starts, sign-up source and use of product features.
• Cookie identifiers, browser settings, device information, IP address and referral information.
• Analytics information collected through services such as Google Analytics.
• Advertising and measurement information collected through tools such as the Meta Pixel and other marketing cookies, where enabled and permitted.

4.4 Information from third parties

We may receive information from Google authentication, Stripe, connected email-marketing platforms, analytics providers, fraud and security services, support providers, referral partners and other services selected by an Account Holder.

• Directly from you when you create an Account, submit an email address, publish a Resource, contact support, report content or change settings.
• Automatically through the Service, cookies, pixels, logs, delivery events and similar technologies.
• From an Account Holder when it imports, synchronizes or manages information through Gluuer.
• From third-party providers used for authentication, payments, hosting, email delivery, integrations, analytics and security.
• From public or lawful sources when reasonably required to assess fraud, abuse, identity or legal complaints.

• Create, verify, secure and manage Accounts.
• Host Resource Pages and files, process submissions and deliver requested Resources.
• Record consent choices and provide Contacts to the relevant Account Holder, subject to the contact access included in the selected plan.
• Provide analytics, exports, integrations, synchronization and support.
• Process subscriptions, payments, cancellations, refunds and billing inquiries.
• Operate, maintain, troubleshoot and improve the Service.
• Detect, investigate and respond to fraud, abuse, security incidents, complaints and prohibited content.
• Enforce the Terms, manage disputes and protect Gluuer, users, service providers and the public.
• Comply with laws, legal process, regulator requests and lawful authority requests.
• Send Account, billing, security, support and service communications.
• Send Gluuer marketing only where the person has chosen to receive it or another lawful basis applies, and provide an opt-out.
• Measure website and campaign performance, including through analytics and advertising tools where consent is required and obtained.

Where a law requires a legal basis, Gluuer may process personal information because:

• processing is necessary to provide the Service or perform a contract;
• the person has given consent, including optional marketing or non-essential cookie consent;
• processing is necessary for Gluuer's legitimate interests in operating, securing, improving and supporting the Service, where those interests are not overridden by individual rights;
• processing is required to comply with a legal obligation;
• processing is necessary to establish, exercise or defend legal claims; or
• another lawful basis or exception applies.

A person may withdraw consent for future processing based on consent. Withdrawal does not affect processing already completed or processing supported by another lawful basis.

A Recipient's request for a specific Resource is separate from optional consent to receive future marketing. Gluuer records the selection presented through the Service. The Account Holder is responsible for using that status correctly and for proving any consent needed for its future communications.

When an Account Holder exports or synchronizes a Contact, Gluuer cannot control later copies held by the Account Holder or a connected platform. Requests about the Account Holder's marketing, exported data or external mailing list should be directed to the Account Holder. Gluuer will address information that remains under Gluuer's control where required by law and technically possible.

Gluuer does not use Account Holder contact lists for Gluuer marketing unless the relevant Recipient separately chooses to receive Gluuer communications.

Gluuer does not undertake to routinely read or manually review every file, URL or Resource Page. We rely primarily on reports and may review relevant content, metadata or activity when necessary to provide support, investigate a complaint, address a security concern, enforce the Terms or comply with law.

Where available, Gluuer may use automated tools, including machine-learning tools, to assist with security, classification, fraud detection or policy enforcement. Automated results may be reviewed or acted on depending on the risk and available information. We do not represent that automated review detects every harmful or unlawful item.

We may disclose personal information to:

• the relevant Account Holder, including Recipient details and consent status collected through that Account Holder's Resource Page;
• service providers that host, store, authenticate, process payments, deliver email, provide analytics, support the product, prevent fraud or maintain security;
• Google or another authentication provider when a person selects that sign-in method;
• Stripe or another payment provider for subscription and billing processing;
• Google Analytics, Meta and other analytics or advertising providers, subject to applicable consent and settings;
• professional advisers, insurers, auditors and contractors who need the information for their work and are subject to appropriate obligations;
• regulators, courts, law-enforcement authorities, hosting providers or other parties where required by law or reasonably necessary to address fraud, security, illegal content, harm or legal claims;
• a buyer, investor, successor or adviser in connection with a proposed or completed business sale, financing, restructure or transfer, subject to applicable law.

We do not sell personal information for money. Under some privacy laws, the use of advertising cookies or pixels may be treated as sharing or a sale even where no money is received. Where required, we provide cookie controls or other means to opt out of that activity.

Providers used by Gluuer may include Lovable, Supabase, Stripe, Google, transactional-email providers, Cloudflare or other network and security services, Mailchimp, Meta, Google Analytics and other vendors supporting hosting, storage, authentication, billing, communications, integrations, analytics, security and support.

Providers may change as the Service develops. Some providers process information under their own privacy terms, particularly where a person directly creates an account with or connects to that provider.

Gluuer is based in Australia, but personal information may be stored or processed in other countries where Gluuer or its service providers operate. These countries may include the United States and other locations disclosed by the relevant provider. Where required, Gluuer takes reasonable steps to use contractual, technical or organizational safeguards for overseas processing. Privacy protections and government-access rules may differ between countries.

Gluuer may use cookies, pixels, local storage and similar technologies for the following purposes:

• Essential: authentication, security, session continuity, preferences and core Service operation.
• Analytics: understanding visits, sign-ups, feature use, performance and errors.
• Advertising and measurement: measuring campaigns, building audiences and understanding whether advertising led to visits or sign-ups.
• Integrations: supporting connected services and remembering selected settings.

Where law requires consent for non-essential cookies or similar technologies, Gluuer will request that consent before enabling them. You may manage available choices through the cookie controls and browser settings. Blocking some technologies may affect functionality or measurement.

Google and Meta may collect or receive information through their tools and use it according to their own privacy terms and account settings.

Account Holders may send marketing to Recipients only in accordance with the Recipient's consent status and applicable law. The Account Holder is responsible for sender identification, unsubscribe handling and communications sent through its own or connected marketing systems.

Gluuer may send operational messages about Accounts, security, billing, Resources, support or changes to the Service. These are service communications rather than optional marketing where permitted by law.

A person may unsubscribe from Gluuer marketing through the link in the message or by contacting us through gluuer.com/contact. Unsubscribing from Gluuer does not unsubscribe the person from an Account Holder's separate mailing list, and vice versa.

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, to provide the applicable plan, resolve disputes, prevent abuse and meet legal obligations.

• Free File Resources may expire or become unavailable 12 months after upload, in accordance with the applicable plan.
• Paid File Resources may be retained for the availability period described by the plan while the subscription remains active, subject to the Terms.
• Recipient Contact records may be retained while the Account is active and may be deleted or de-identified 24 months after the Account Holder's last activity, unless deleted sooner or retained longer for a legal, security or dispute reason.
• Contacts collected under a plan with limited contact access are stored by Gluuer and shown to the Account Holder with the email address masked once the plan's visible allowance is reached. Masked Contacts are never deleted and collection never stops; they become fully viewable and exportable when a plan that includes contact access is selected.
• Account, support, security, abuse and transaction records may be retained for the period reasonably required for their purpose and any legal obligation.
• When an Account or record is deleted, it is removed or de-identified from active systems according to operational processes. Residual copies may remain in restricted backups for a limited provider backup cycle and are not used for ordinary purposes.
• Information subject to a legal hold, complaint, fraud investigation, chargeback, safety matter or regulatory request may be retained until the matter is resolved.

Retention periods are maximum operational guidelines and may be shortened where appropriate. Gluuer does not guarantee that deleted files or records can be recovered.

Gluuer uses reasonable administrative, technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration or disclosure. Measures may include account verification, access controls, private storage, encryption offered by providers, logging, authentication controls and restricted administrative access.

No online service can guarantee absolute security. Account Holders must protect login access and Recipients should access Resources only from sources they trust.

If you believe an Account or personal information has been compromised, contact us through gluuer.com/contact promptly.

Depending on your location and the applicable law, you may have rights to:

• request access to personal information held about you;
• request correction of inaccurate or incomplete information;
• request deletion or de-identification;
• object to or request restriction of certain processing;
• request a portable copy of information you provided;
• withdraw consent for future processing based on consent;
• opt out of certain marketing, analytics or advertising activities;
• complain to a privacy or data-protection regulator.

To make a request, contact us through gluuer.com/contact. We may need to verify identity and may refuse or limit a request where permitted by law, including where fulfilling it would affect another person's rights or where Gluuer must retain information.

Recipients should also contact the relevant Account Holder about marketing, exported information and external mailing lists controlled by that Account Holder. Gluuer may not be able to delete copies already exported to the Account Holder or another platform.

Account Holders must be at least 18. The Service is not designed for children to create Accounts. A person under 18 should use a Resource Page only with parent or guardian permission and appropriate supervision.

Account Holders must not knowingly use Gluuer to collect personal information from children without any consent, notice or safeguards required by applicable law.

Gluuer assesses suspected data incidents and will provide notifications to affected people or regulators where required by applicable law.

Privacy complaints may be sent through gluuer.com/contact. Please describe the concern and provide enough information for us to identify the relevant Account, Resource or communication. We will assess complaints without guaranteeing a fixed response time.

If you are in Australia and are dissatisfied with our response, you may have the right to contact the Office of the Australian Information Commissioner. People in other locations may contact their local privacy or data-protection regulator.

Gluuer may update this Privacy Policy as the Service, providers or legal requirements change. The updated version will show a new effective date. Material changes will be communicated through the Service, email or another reasonable method where required.

Privacy, access, correction and deletion requests: gluuer.com/contact

Content and abuse reports: gluuer.com/contact

Postal address: Level 1, 9-13 Bronte Road, Bondi Junction NSW 2022, Australia