Privacy policy

This is a translation of the Swedish integritetspolicy. If the two versions differ, the Swedish version prevails.

1. Introduction and scope

clearminds AB (“clearminds”, “we”, “us”) provides the nodus service, a platform for operators of office hotels and coworking spaces and for their tenants.

This privacy policy describes how personal data is processed in nodus and on the website nodus.se. It applies to:

contact persons and administrators at operators that are customers of clearminds,
users at the operators’ tenants (“members”),
visitors to the operators’ premises, to the extent they appear in door-access or doorbell events, including photos they choose to take with the doorbell app, and
visitors to the website.

2. Controller and contact

clearminds AB, org. no. 559476-7971, Luntmakargatan 26, Stockholm.

clearminds is the controller for the processing set out in section 3, including network and traffic data. For data that clearminds processes on behalf of an operator, the operator is the controller.

Send all questions about this policy and all requests to exercise your rights, for example access or erasure, to [email protected].

3. Roles

clearminds is the controller for:

contact details of the operators’ contact persons and administrators,
data about visitors to the website,
clearminds’ own user accounts and the security logs clearminds keeps to protect the platform, and
network and traffic data and connection logs that arise when you use a network managed through nodus (see sections 4, 5 and 8). clearminds determines the purposes and means of this processing. It is separate from the processing of member data that clearminds carries out on behalf of an operator.

For other data about tenants, members and visitors, which is processed on behalf of an operator, the operator is the controller and clearminds is the processor. clearminds then processes the data on the operator’s instructions and under the data processing agreement in Annex 1 to the customer terms (see section 7.3 of the customer terms and https://nodus.se/en/data-processing-agreement). Questions about such data are answered primarily by the operator responsible for the data.

4. Personal data we process

Account data: name, email address, phone number if you or the operator have entered one, and which company (tenant) you belong to at the office hotel.
Sign-in data: when you sign in through an external provider (Google, Microsoft, Slack, LinkedIn or Discord), we receive your user ID at the provider, display name, email address and the address of your profile picture. We never receive your password at these providers. Access tokens used during sign-in are discarded after use. You can unlink a sign-in account you have linked at any time in the portal.
Usage data: access logs, audit log entries, bookings of meeting rooms (title, time and the organiser’s email address) and of desks, printing history (document name, number of pages and time), doorbell and alarm events, support tickets, your notification settings and push subscriptions, and the actions you perform in the service.
AI assistant and AI-assisted interpretation of leases (the operator is the controller):
- When you chat with the assistant in the member portal or in Slack, your message and earlier messages in the same conversation, your name and the time are sent to the AI provider, together with the operator’s FAQ, building information (addresses, floors, rooms, directions and which tenants are in which rooms) and details of how your company’s network is configured: the network’s name, address range, gateway and DHCP range. In Slack, your location in the building may also be included.
- To answer, the assistant can retrieve data from nodus and send it to the AI provider: the name, email address and role of colleagues at your company, meeting rooms and your company’s bookings, events in your company’s event log (for example door access and the doorbell), equipment on the premises and directions. At your request, the assistant can book and cancel meeting rooms and pass the matter on to the operator’s staff.
- When you ask it to, the assistant can look up which devices are connected to your company’s network according to the DHCP server’s current assignments (IP address, MAC address, hostname, status and when the device was last seen). Logs of past connections (RADIUS and DHCP), flow data and infrastructure and operations logs are never sent to the AI provider.
- When the operator uploads a lease, or sends it in by email, the text of the lease is sent to the AI provider, or images of the pages if the lease is scanned, to produce suggested lease details. The operator reviews the suggestions before they are used. Leases may contain names, contact details and personal identity numbers of signatories and contact persons.
Data about signatories and board members: when the operator imports leases, nodus retrieves data about the tenant company, including the names of signatories and board members, from the company register Bizzdo (bizzdo.se). If you are a signatory or board member of a tenant, your data may therefore appear in the operator’s lease records.
Device data: IP address, browser type and operating system, collected automatically for security and troubleshooting.
Network and traffic data (clearminds is the controller): when you use a network managed through nodus, clearminds records which device connects, which network address it gets and who is signed in (connection logs). We also record how traffic flows in the network: which address communicates with which other address, how much and when (flow data). This means we can see which services a device has been in contact with, but the content of your communications is not recorded. We also measure how much of the network’s capacity each company (tenant) uses.
Operator contact data: name, email address and role of the operator’s administrators.
Billing data exchanged with Fortnox:
- customers (name, organisation number, address, email address, customer number and external reference),
- invoices (lines, amounts, VAT, dates and status),
- articles, and
- payments (amount and date).

Billing data is exchanged between nodus and the operator’s own Fortnox company on the operator’s instruction. Fortnox processes the data under the operator’s own agreement with Fortnox.

Visitor photos (nodus doorbell / Nodus Virtual Reception)

The nodus doorbell is an app that runs on tablets in the reception of the operator’s premises. It is available for iOS and Android under the name Nodus Virtual Reception, and as a web app (PWA). Visitors use it to notify the company or person they are visiting that they have arrived.

Taking a photo is optional. When you arrive, you can choose to take a photo of yourself with the tablet’s camera and attach it to the arrival notification you send to the company or person you are visiting. The camera is used only when you choose to take a photo.
No face recognition. No face recognition, face detection or other biometric analysis is performed on the photo. The photo is not used to identify anyone automatically and is not used to train AI. It is an ordinary picture that is shown to the recipient.
Storage. The photo and your message are sent to clearminds’ servers and stored in clearminds’ own self-hosted object storage, not with a third-party cloud provider. The photo is accessed only through signed links that are valid for a limited time.
Delivery to the recipient. The company or person you visit receives the notification as a push notification in the browser, which does not contain the photo, and in the member portal, where the photo and your message are shown. If the company has set it up, the notification is also sent:
- by email, through clearminds’ own mail server; the email shows the photo through a link that is valid for a limited time,
- to Slack, which receives a link to the photo that is valid for a limited time (see section 6), and
- by SMS through 46elks; the SMS does not contain the photo.
Retention. Visitor photos are deleted automatically 90 days after they were taken, and earlier if the notification is deleted or the company is removed from nodus (see section 8).
No other use. Apart from the recipients described here, the photo is not shared with or sold to anyone, and it is not used for advertising or tracking.

5. Purposes and legal bases

We process personal data to:

provide the office hotel’s services, for example door access, Wi-Fi, meeting room booking, printing and doorbell notifications,
verify your identity and manage access to accounts,
keep security and audit logs for building security and compliance,
send service-related messages, for example about access events and the doorbell,
troubleshoot technical problems and improve the service with anonymised or aggregated data, and
handle invoicing.

The legal bases are:

The office hotel’s services to you as a member, for example your account, door access, Wi-Fi, bookings, printing and notifications: the operator’s legitimate interest in performing its agreement with the company you belong to and in running the office hotel (art. 6.1 f GDPR). You are not yourself a party to that agreement.
Sign-in and access to accounts, including through an external provider: the operator’s legitimate interest in secure sign-in (art. 6.1 f GDPR). You choose yourself whether to sign in through an external provider.
Security and audit logs in the building: the operator’s legitimate interest in security and in being able to investigate incidents (art. 6.1 f GDPR).
Operations, troubleshooting and security logs for the platform, including the usage statistics and crash reports from the doorbell app (section 6): clearminds’ legitimate interest in a secure and working service (art. 6.1 f GDPR). The service is improved with anonymised or aggregated data (section 8 of the customer terms).
clearminds’ customer relationship with the operators and its invoicing of them: the agreement between clearminds and the operator. For the operator’s contact persons, the basis is clearminds’ legitimate interest in managing the customer relationship (art. 6.1 f GDPR). Accounting records are kept to comply with the Swedish Bookkeeping Act (1999:1078) (legal obligation, art. 6.1 c GDPR).

For invoicing of tenants through Fortnox the operator is the controller, and the legal basis is the operator’s agreement with the tenant company and, for the company’s contact persons, the operator’s legitimate interest (art. 6.1 f GDPR).

You have the right to object to processing based on legitimate interest (see section 9).

Network and traffic data. clearminds processes network and traffic data and connection logs for operations monitoring, capacity planning, troubleshooting, customer support, security and the investigation of abuse. The legal basis is clearminds’ legitimate interest in network security, operations and troubleshooting (art. 6.1 f GDPR, cf. recital 49). The processing is not based on contract, since you as a member are not a party to the agreement between clearminds and the operator. Where clearminds has a statutory obligation to disclose the data, for example at the request of the police or a prosecutor, the legal basis for the disclosure is legal obligation (art. 6.1 c GDPR).

The AI assistant, lease interpretation and announcements. For the AI assistant, including booking meeting rooms at your request, the operator is the controller and clearminds is the processor. The legal basis is the operator’s legitimate interest in giving members efficient support and service (art. 6.1 f GDPR). For the AI-assisted interpretation of leases the legal basis is the operator’s legitimate interest in administering its agreements (art. 6.1 f GDPR), and for speech synthesis of announcements the operator’s legitimate interest in reaching the people in the building with information (art. 6.1 f GDPR). For these processing activities too, clearminds is the processor. Personal identity numbers in leases are processed only where this is clearly justified with regard to the purpose of the processing, the importance of a secure identification or another considerable reason (Chapter 3, Section 10 of the Swedish Act (2018:218) containing supplementary provisions to the EU General Data Protection Regulation).

Visitor photos. For visitor photos and arrival notifications from the doorbell app (section 4), the operator is the controller and clearminds is the processor. The legal basis is the operator’s legitimate interest in letting visitors announce their arrival to the company or person they are visiting (art. 6.1 f GDPR). Taking a photo is optional.

6. Recipients

We do not sell personal data. Data may be disclosed to:

Your company’s administrators: the administrators your company has designated at the office hotel can see members’ names, email addresses and activity.
Colleagues at your company: through the AI assistant, colleagues at your company can see your name, email address and role, events in the company’s event log in which you appear, and which devices are connected to the company’s network according to the DHCP server’s current assignments.
The company or person a visitor is visiting: a visitor’s photo and message are shown to the company or person the visitor has chosen at the reception tablet, as described in section 4.
The office hotel’s operator: the operator uses nodus to manage access, networks and premises on your behalf. Access permissions are synchronised to the building’s access-control system, which the operator runs.
Meeting room displays: displays at meeting rooms may show booking details, for example the title and the organiser’s name. The display service is clearminds’ own.
Error reporting: we use clearminds’ own Sentry installation (sentry.clearminds.se) for error reports and performance data. An error report contains the error, the page and action where it occurred, browser details, your IP address and your user ID. When an error occurs in the member portal, a recording of the page just before the error is also kept, with all text, input fields and images masked. In the admin app such a recording is made only if you have turned on session recording yourself, at sign-in or in the app. The recording is held only in the browser’s memory until an error occurs, and is not sent at all if no error occurs. The data is stored on clearminds’ own infrastructure within the EU and is used only to find and fix technical errors.
The operator’s Fortnox company: when the operator has connected Fortnox, billing data is exchanged as described in section 4.
Google Cloud (Vertex AI): the AI assistant and the AI-assisted interpretation of leases use language models in Google Cloud (Vertex AI). The processing takes place in an EU region, in a paid service. Under Google Cloud’s terms, Google does not use the data to train its AI models. Google Cloud is a sub-processor of clearminds.
Google Cloud Text-to-Speech: announcements the operator writes may be converted into speech through Google Cloud Text-to-Speech. The announcement text is then sent to Google.
Google Calendar: if the operator has connected a meeting room to a Google calendar, the booking’s title, time and description are sent to that calendar.
Slack: if you use the assistant in your company’s Slack workspace, the conversation is also stored at Slack, under your company’s agreement with Slack. If the operator has connected the support to a Slack channel, conversations in the portal’s support chat are mirrored there so that the operator’s staff can follow them. If a company has connected the doorbell to Slack, arrival notifications from the doorbell app are posted to the company’s Slack workspace, and Slack then receives a link to the visitor photo that is valid for a limited time. Slack is a third party and processes the notification under the company’s agreement with Slack.
SMS and push notifications: if the operator sends notifications by SMS, they go through the operator’s own SMS provider 46elks, using the operator’s own account; your phone number and the message are then sent to 46elks. SMS notifications from the doorbell app never contain the visitor photo. Push notifications in the browser are delivered through the push service provided by your browser’s vendor; push notifications from the doorbell app do not contain the visitor photo.
Firebase Analytics (Google): the doorbell app (Nodus Virtual Reception) uses Firebase Analytics, a Google service, for anonymous usage statistics and crash reports. No advertising ID is collected, ad personalisation is turned off and the data is not used for tracking across apps or websites. Visitor photos are never sent to Firebase.
Maps, icons and logos in the admin app: the admin app loads map images from OpenStreetMap (tile.openstreetmap.org), looks up addresses through OpenStreetMap’s search service Nominatim, and loads map markers and icons from unpkg.com and cdn.jsdelivr.net. When an administrator picks a logo for a tenant, icons are fetched directly from the tenant’s website. These requests go directly from your browser to these services, which therefore receive your IP address and details about your browser, and, for an address search, the address you search for. The recipients process the data under their own terms.
Cloudflare: Cloudflare is used as an edge proxy/CDN in front of nodus.se and the service’s other domains (for example api.nodus.se, app.nodus.se and member.nodus.se) and handles DNS. The admin app and the member portal are served from Cloudflare Pages. Traffic to the website and the service therefore passes through Cloudflare.
Authorities and others: where required by law (art. 6.1 c GDPR), or where needed to establish, exercise or defend legal claims or to report a suspected crime to a competent authority, based on clearminds’ legitimate interest (art. 6.1 f GDPR, cf. recital 50). Network and traffic data and connection logs are disclosed to authorities, for example the police or a prosecutor, where clearminds has a statutory obligation to disclose them (see sections 5 and 8).

7. Transfers outside the EU/EEA

nodus runs on infrastructure operated by clearminds within the EU; the admin app and the member portal are served from Cloudflare Pages.

The AI processing in Google Cloud (Vertex AI) takes place in an EU region. In some cases Google may access the data from countries outside the EU/EEA, for example for support and operations. Cloudflare, Inc. is based in the United States, and traffic that passes through Cloudflare may be processed outside the EU/EEA. Google Cloud Text-to-Speech, Google Calendar and Firebase Analytics are not limited to an EU region, so data sent to them may also be processed outside the EU/EEA. Where data is transferred to a country outside the EU/EEA, this relies on the European Commission’s adequacy decision for the EU–US Data Privacy Framework, to the extent the recipient participates in the framework, and otherwise on the European Commission’s standard contractual clauses (Article 46.2 c of the GDPR). You can obtain a copy of the safeguards by contacting [email protected].

The admin app’s requests to OpenStreetMap and Nominatim go to the OpenStreetMap Foundation in the United Kingdom, which has an adequate level of protection under a decision of the European Commission. unpkg.com and cdn.jsdelivr.net are served through global CDN networks, and tenants’ websites may be hosted anywhere, so requests to them may be processed outside the EU/EEA. These requests are made directly by your browser and are not covered by any agreement between clearminds and the recipient (see section 6).

8. Retention

Data that clearminds processes on behalf of an operator is kept according to the operator’s instructions and at most for the duration of the agreement between the operator and clearminds. After the agreement has ended, it is deleted under section 13.3 of the customer terms.

Account data is kept for as long as your account exists in nodus. The operator decides when an account is removed. When your account is removed, the account data is deleted. Access and security events, the audit log and booking history in which you appear are kept as set out below.
Access and security events and the audit log of administrative actions are kept during the agreement between the operator and clearminds, because they are needed to maintain building security and investigate incidents. No shorter fixed retention period is applied today.

Network and traffic data is kept as follows:

Flow data (how traffic has flowed in the network) is stored in our flow-analysis system. It contains network addresses but no usernames. Data about individual connections is kept for at most 90 days. After that we keep only statistics, aggregated per 5 minutes for 180 days and per hour for up to 2 years.
Capacity measurements per company: how much of the network’s capacity each company uses is kept per minute and per 5 minutes for 90 days, and after that as a daily summary for 2 years. The measurements concern the company’s network as a whole, not individual users. If the company has only one user, they may still relate to an individual person.
Connection logs: From 2026-10-28, connection logs that link devices to users (DHCP, RADIUS and the network system’s client history, including 802.1X identity and device name) are kept for at most 90 days and are then deleted. The 90-day retention is justified by network security, troubleshooting and the investigation of abuse, including being able to respond to requests from authorities, which often arrive weeks or months later (art. 6.1 f GDPR, recital 49). From the same date, RADIUS session data (session times, access point and data volume) is kept after 90 days without user identity (username, MAC and IP address) and only per tenant, for capacity planning and follow-up. This data is kept during the agreement between the operator and clearminds and is deleted when the agreement has ended. If the tenant has only one user, the data may still relate to an individual person. Until 2026-10-28, connection logs are kept longer: in nodus, authentication attempts are kept for 90 days and closed network sessions for 180 days from the connection, and in the infrastructure and operations logs for at most 90 days.
Infrastructure and operations logs are kept for at most 180 days. Data in these logs that links devices to users is kept separately for at most 90 days.

The link between a device and a user exists in the connection logs (DHCP, RADIUS). From 2026-10-28, flow data older than 90 days can therefore normally only be linked to the tenant’s network and not to an individual user. Flow data may nevertheless relate to an individual person, for example if a device has a fixed IP address or if the tenant has only one user. clearminds therefore treats flow data as personal data throughout the retention period.

Invoices are kept by the operator in the operator’s Fortnox company under the Swedish Bookkeeping Act (1999:1078). clearminds keeps its own record of the invoicing in nodus for the term of the agreement and for the export period that applies after the agreement ends (see section 13.3 of the customer terms).

clearminds’ own invoices to its customers are kept as required by the Swedish Bookkeeping Act (1999:1078).

The AI assistant and lease interpretation. Conversations with the assistant are kept in nodus during the agreement between the operator and clearminds and are deleted under section 13.3 of the customer terms after the agreement has ended. No shorter fixed retention period is applied today. Conversations in Slack are also kept at Slack under your company’s agreement with Slack. Leases uploaded for interpretation are kept until the operator has approved or rejected the suggestion. Leases the operator rejects and leases that could not be interpreted are deleted after 30 days. An approved lease is kept together with the lease details for as long as the operator keeps the lease in nodus.

Visitor photos. Photos that visitors take with the doorbell app (section 4) are deleted automatically 90 days after they were taken. A photo is deleted earlier if the notification it belongs to is deleted or if the tenant is removed from nodus. The notification itself without the photo (the message text, the time and the recipient) is kept like other events in nodus, during the agreement between the operator and clearminds.

9. Your rights

Under the General Data Protection Regulation (GDPR) you have the right to:

access your personal data,
have inaccurate data rectified,
request erasure of your data,
request restriction of the processing,
object to processing based on legitimate interest, and
receive your data and transfer it (data portability).

If you are a member or a visitor and the data is processed on behalf of an operator, the operator is the controller. In that case, contact your operator first. If you contact us, we help the operator answer your request.

The AI assistant. The assistant in the member portal and in Slack is an AI system, and in the portal’s support chat the assistant’s replies are marked “AI”. The replies are generated automatically and are not reviewed by a human before they are shown. During an ongoing conversation in the portal’s support chat you can choose “Talk to a human” to pass the conversation to the operator’s staff, if the operator has enabled personal support. You can also ask the assistant to bring in a human. The assistant makes no decisions with legal effects for you or that similarly significantly affect you (Article 22 of the GDPR). Meeting rooms are booked only at your request.

Send requests to [email protected].

You also have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), www.imy.se.

10. The website, cookies and local storage

The website uses no cookies and no analytics.

Cookies. The member portal and the admin app set no cookies of their own. api.nodus.se does set two cookies, but only on the sign-in page used when you give an external app or AI service access to nodus (/oauth/login/) and on clearminds’ technical administration (/admin/):

csrftoken protects the sign-in form against forged requests (CSRF) and is kept for one year.
sessionid keeps you signed in while you approve the access and is kept for two weeks or until you sign out.

Both are sent only over encrypted connections. If you sign in with Google, Microsoft, Slack, LinkedIn or Discord, that service sets its own cookies on its own domain, under its own terms.

Local storage. The member portal and the admin app keep the following in the browser’s local storage (localStorage):

your sign-in (access and refresh tokens) and a copy of your profile, including your name and email address, so that you stay signed in. This is deleted when you sign out.
which customer and site you have selected in the admin app.
your settings, for example light or dark mode, which announcements you have dismissed and sound settings.
your email address, if you tick “Remember me” when you sign in to the admin app. It stays until you sign in without ticking the box.

Temporary values, for example a network plan change you are in the middle of and a guard that stops the page from reloading in a loop after an update, are kept in session storage (sessionStorage) and disappear when you close the tab.

The member portal installs a service worker only when you turn on push notifications. A push subscription is then also kept at your browser’s push service until you turn the notifications off, which you can do in the browser at any time.

Error reporting (section 6) stores nothing on your device.

The meeting room displays keep a key that identifies the display and a copy of the room’s schedule, at most 24 hours old, so that the display keeps working during an outage.

All of this is needed to provide the service or a feature you have chosen yourself, so no consent is required (Chapter 9, Section 28 of the Swedish Electronic Communications Act (2022:482)). We use no tracking cookies and no advertising analytics.

Server logs at Cloudflare and on our own infrastructure, for example the IP address and time of a request, are kept for security reasons.

11. Security

We use industry-standard security measures, including encrypted connections (TLS), access controls and regular security reviews, to protect your data.

12. Changes and version history

This is version 1.1 of the privacy policy, effective from 2026-10-13.

We may update the policy. Changes are announced on this page and in the portal.

Version	Effective from	Change
1.0	2026-09-29	First version.
1.1	2026-10-13	Visitor photos from the nodus doorbell app (Nodus Virtual Reception) and the app’s use of Firebase Analytics.