Fluidly Limited (“we”, “our”, “us”) is committed to privacy compliance and to earning the trust of our customers and their users (“you”, “your”).

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.

This policy applies to the products and services we provide to you, our mobile apps and our websites.

It also applies even if you’re not one of our customers and you interact with us as part of running our business, such as by using one of our products or services paid for by someone else or by enquiring about our products and services.

If you need to give us personal information about someone else in relation to our products and services, the privacy policy will also apply. And if we need the permission of the other person to use that information, you need to check they are okay with this.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Contents

1. Who we are, and our relationship with our Accountant Partners;
2. The information we collect;
3. How we use your personal information;
4. Marketing communications;
5. Where we store your personal information;
6. Third parties and disclosures of your data;
7. How we send information outside of your country;
8. Your rights;
9. Security of information;
10. How long do we keep your personal information?;
11. Changes to our privacy policy;
12. Contact

1. Who we are, and our relationship with our Accountant Partners

We are a provider of (a) cashflow forecasting and management services and (b) a credit broker Authorised and Regulated by the Financial Conduct Authority under the firm reference number 844093. We are not a lender.

We work with our users:

• directly, when they sign up on our website, or when they sign up to our Terms of Service as part of their accounting software package; and
• indirectly, when our products and services are purchased by our Accountant Partners for your benefit.

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; (ii.) if we are providing credit broking services to you; or (iii) 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 (the “controller”). In which case your personal information will be processed in accordance with their privacy notice – please see your accounting service provider’s website for further information.

Here is some further information about us:

• Our website is here.
• We are a company incorporated in England and Wales with company number 10402874
• Our registered office is at 20-22 Wenlock Road, London, N1 7GU
• We are Authorised and Regulated by the Financial Conduct Authority as a Credit Broker under the firm reference number 844093
• We are registered with the Information Commissioner under number ​​ZA285695

2. The information we collect

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 of our services:

• Account and contact details: When you create an account, or sign up to our Terms of Service you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your name and email address. We may also collect additional information in connection with credit applications you make, such as your home address, and date of birth if you use our credit broking service;
• Information relating to your finances: our service involves analysis of your transaction data from your accounting system. It includes information relating to your finances and credit card (“Financial Data”) as well as information in respect of your invoices, invoicing procedures and customers (“Invoice Data”);
• Customer service: If you contact our customer service team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
• Marketing and communications data: including your preferences in receiving marketing material from us and our third parties and your communication preferences.

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:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform (“Technical Data”);
• Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number (“Usage Data”).

Information we receive from others

In addition to the information provided to us by our users, we may also receive information about you from others, including:

• Billing details: When you purchase or subscribe to our services, you will provide our payment service providers with information, such as your debit or credit card number or other financial information. This information is collected on our behalf but we do not receive your payment information;
• Accountant Partners: Our Accountant Partners may provide information about you. For instance, if your accounting service provider integrates or uses our software, we will receive your Financial and Invoice Data. Your service provider may, in accordance with your marketing preferences, share your identity and contact details with us for marketing purposes;
• Third party data sources: We may obtain data about you from (with your consent) credit reference and fraud prevention agencies and (b) from public records such as Companies House and the Electoral Register.
• Third Party details: By granting us access to your Finance and Invoice data, we may receive third party personal data relating to counterparties to those transactions. We only process this data in connection with the delivery of our services, and the development of aggregate level insights.
• Other partners: We may receive identity and contact information about you from our partners, for example in connection with the purchase of marketing lists.

Aggregated Information

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 
• our customers to benchmark their financial position with that of other, similarly situated businesses.  

From time to time, we may also share anonymised 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 all our customers or to our business partners on trends in cash collection, debtors and demographic of users.

Cookies

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.

Automated processing

We may use the information you provide to decide your eligibility for third party products such as loans or other finance products or services. This type of activity is known as “profiling”. 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).

3. How we use your personal information

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.