Privacy Policy
Last updated on 29 January 2018
Fluidly Limited (“we”, “our”, “us”) is committed to privacy compliance and to earning the trust of our users (“you”, “your”) who are made up of users who come to us directly, or via our accountant partners, as either a staff user or an indirect customer.
To earn that trust, we aim to be transparent and ensure you understand our privacy practices. This policy (together with our Terms of Service) set out the basis on which your personal data is collected and used in connection with your (or your accounting service provider’s ( “Accountant Partners”)) use of Fluidly services.
Please read the following carefully to understand our views and practices regarding your
personal data and how we will treat it.
Contents
We are a provider of cashflow forecasting and management services. We work with our users:
We will be the party responsible for making decisions about how your personal information is processed (the “controller”) when (i.) you have access to the Fluidly platform, and we are providing you with services directly; or (ii.) if we contact you about our services as a prospective customer (see Marketing below). In each case, your personal information will be processed in accordance with this policy.
Where you are a customer of our Accountant Partners, and where they, with your agreement, have authorised our processing of your personal information in connection with their use of our services (which includes our preparation of aggregate level insights), they will be the party responsible for processing your personal information. In which case it will be processed in accordance with their privacy notice – please see your accounting service provider’s website for further information.
In order to provide our services or information about our services
We may collect, use, store and transfer different kinds of personal data about you in connection with your direct and indirect use of our services.
Personal data means any information about a living individual from which that person can be identified. Generally speaking, we will collect the following categories of information in connection with your use or your Accountant Partner’s use of our services:
Other information collected when you use our website and services
With regard to each of your visits to our site we will automatically collect the following
information:
In addition to the information provided to us by our users, we may also receive information about you from others, including:
The service we provide is dependent on collecting as much information about cash management as we can. This means we may use information that we receive from you in providing the services, including information on payment terms, late payments account manager contact details and cash collection, to allow us to make cash flow predictions or assist with providing or improving the services for the benefit of all clients. From time to time, we may also share anonymized and aggregated information about users of our services and information collected from providing those services, such as by publishing a report or providing information to our business partners on trends in cash collection, debtors and demographic of users.
Our site uses cookies and similar technologies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.
Please see our Cookie Policy for more information on why we use them and how you can better control their use, through your browser settings and other tools.
We may use the information you provide to decide your eligibility for third party products. This type of activity is known as “profiling” – as we use automated means to process your personal data to inform which products may be relevant to your needs. You may object to profiling (see section 8 below).
We will only use your personal data when the law allows us to. We have set out below a description of all the ways we plan to use your personal data, and what our legal bases are for doing so.
We may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing |
To register you as a new customer or for your free trial of our services |
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To take all necessary steps prior to entering into a contract with you |
To provide our products and/or services to you |
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Performing a contract that we have with you |
To manage our relationship with you, including:
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Identity and Contact Data |
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To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data) |
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To use data analytics to improve our site, products and services, marketing, customer relationships and experiences |
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To prepare anonymised and aggregated insights about users of our services and information collected from providing those services, such as by publishing a report or providing information to our business partners on trends in cash collection, debtors and demographic of users. |
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To make decisions about what products and/or services (including those of other companies) we think may be of interest to you and sending you tailored email marketing |
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To share information with our third-party partners that may be interested in contacting you with information about their products and/or services (in accordance with section 5 of this Policy). |
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For internal management, administrative and organisational reasons – in the event that we: (i) are subject to negotiations for the sale of our business; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. |
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To prevent, detect and fight fraud or other illegal or unauthorized activities. |
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To ensure legal compliance and to comply with legal requirements, assist law enforcement and enforce or exercise our rights, for example our Terms and conditions. |
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We may use your personal data to provide you with information about Fluidly products and/or services that we consider may be of interest to you. Where we send email marketing:
we will assume you are happy to receive relevant marketing communications unless you have previously opted out of such communications.
We may also use your personal data to provide you with information about products and services from our partners and other relevant third parties which we consider may be of interest to you (based on our analysis of your business account(s)). We will only share your personal data with those partners on the basis of your consent. We will never sell your personal data to third parties for the purposes of marketing.
You can opt out of receiving email marketing from us by clicking the unsubscribe button at the bottom of any marketing email you receive from us. Alternatively, you can email us at info@fluidly.com
Methods of communication
We may contact you for the purposes described in this privacy policy by email, direct mail, SMS, push notification or other communication methods depending on both the information and consents you provide to us.
We may share your information with:
A list of these third parties is available on request.
We may also share your information:
The data that we collect from you will be transferred to, and stored at, a destination inside the United Kingdom (“UK”) or the European Economic Area (“EEA”) in accordance with applicable data protection legislation in such territories. It will also be processed by staff operating inside the UK or the EEA who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
When we send your personal information outside of your country, we have in place adequate safeguards to do so. This includes EU standard contract clauses approved by the European Commission or other suitable safeguard to permit personal information transfers from the UK or the European Economic Area (“EEA”) to other countries.
Please get in touch with us if you would like more information about these safeguards.
In certain circumstances, for example if you are an EEA resident, you may exercise the rights available to you under applicable data protection laws as follows:
You can exercise your rights at any time by contacting us using the contact details below.
We respond to all requests we receive from users in accordance with applicable data protection laws. We may ask you to provide proof of identity before we can answer the above requests. In some cases, we may reject requests for certain reasons (for example, if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user).
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted in accordance with industry best practice. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your personal information will be stored in accordance with applicable laws and kept for as long as needed to carry out the purposes described in this Privacy Notice or as otherwise required by applicable law.
We do keep certain transactional records for more extended periods if we need to do this to meet legal, regulatory, tax or accounting needs. For instance, we are required to retain an accurate record of our dealings with our clients, this allows us to respond to any complaints or challenges you or others might raise later. We will also retain files if we reasonably believe there is a prospect of litigation.
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our data protection officer at info@fluidly.com
The time is now
Straightforward cashflow management to help business owners sleep better
20-22, Wenlock Road, London, N1 7GU
© 2020 Fluidly Ltd is registered in England and Wales under Company Registration number 10402874. We are Authorised and Regulated by the Financial Conduct Authority as a Credit Broker under the firm reference number 844093 and as an Account Information Services Provider under the firm reference number 791669. Please note we are a credit broker and NOT a lender.
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