Privacy Policy
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
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:
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:
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:
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:
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:
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:
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).
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 | Identity and Contact Data
Financial Data |
To take all necessary steps prior to entering into a contract with you |
To provide our products and/or services to you including our credit broking service | Identity and Contact Data
Financial and Invoice Data |
Performing a contract that we have with you
Our legitimate business interests (ensuring that actual and potential providers of products or services to you have the information they need to make informed decisions about the risks of doing business with you) |
To manage our relationship with you, including:
Sending you service communications about your account or our relationship with you; Notifying you about our site and products or services and of changes in our terms or privacy notice; and Responding to any communications or complaints you send to us |
Identity and Contact Data | Performing a contract that we have with you;
Complying with our legal obligations; Our legitimate business interests (keeping our records up-to-date, studying how customers use our products/services) |
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data) | Identity and Contact Data
Technical Data |
Our legitimate business interests (running our business, providing admin and IT services network security, preventing fraud or for a business reorganisation or group restructuring);
Complying with our legal obligations |
To use data analytics to improve our site, products and services, marketing, customer relationships and experiences | Technical Data
Usage Data |
Our legitimate business interests (to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy) |
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. |
The categories listed in section 2 above | Our legitimate business interests (to develop aggregate level insights about the use of our services, and ongoing trends such as cash collection, debtors and demographic of users) |
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 | Identity and Contact Data
Financial and Invoice data |
Our legitimate business interests (developing our products/services, growing our business) – where we send you marketing messages, you can always tell us if you no longer want to receive them by contacting us at [email protected];
Your consent, which you can withdraw at any time via the link in the email, or by contacting us at [email protected]; |
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). | Identity and Contact Data | Your consent, which you can withdraw at any time by contacting us at [email protected]; |
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. | The categories listed in section 2 above | Our legitimate interests (to allow us to change our business) |
To prevent, detect and fight fraud or other illegal or unauthorized activities. | The categories listed in section 2 above | Our legitimate interests (to protect our reputation as a provider of financial services)
Complying with our legal obligations In connection with legal claims |
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. | The categories listed in section 2 above | Complying with our legal obligations
In connection with legal claims Our legitimate interests (to cooperate with law enforcement and regulatory authorities) |
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 [email protected].
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.
Please note that if you are an individual and share finances with someone (e.g. a joint bank account or joint credit ) that person will be recorded on your credit report by credit reference agencies as your ‘financial associate’. Lenders may check the credit history of your financial associates when deciding whether to approve lending to you. You can ask credit reference agencies to update your credit report if you feel you are no longer associated with that person.
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, if they significantly diminish our responsibilities, we will notify 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 [email protected]
The time is now
Helping accountants and their clients grow through bespoke funding.
57 Broadwick Street, London W1F 9QS
© 2022 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. Fluidly is ISO 27001 certified. Fluidly is registered at 57 Broadwick Street, London, W1F 9QS
Website by Lyfe Studio