Last updated 25 May, 2021.
Thank you for choosing to be part of our community at Fluid Tech Inc., doing business as Fluid (“fluid”, “we”, ”us”, “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or all the practices with regards to your personal information, please contact us at firstname.lastname@example.org.
When you visit our website https://www.fluid.app (the “Website”) and more generally, use any of our services (the “Services”, which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
1. What information do we collect?
Personal information you disclose to us
In short: we collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us of our products and Services, when you participate in activities on the Services (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following;
Personal information provided by you. We collect names; phone numbers; email addresses; mailing addresses; password and contact preferences.
Social media login data. We provide you with the option to register with us using your existing social media account details, like your Facebook, Instagram or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS BELOW”.
Information automatically collected. In short; some information such as your Internet protocol (IP) address and all browser and devices characteristics is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) that may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URL’s, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
The information we collect includes:
· Log and usage data. Log and usage data is service related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record and log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date or timestamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called’ crush dumps’) and hardware settings).
· Device data. We collect device data such as information about your computer, phone, tablet or other device you use to access services. Depending on the device use the service data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and or mobile carrier, operating system and system configuration information.
· Location data. We collect location data such as such as information about all devices location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to that information or by disabling your location settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Service.
Information collected through the Website
In short: we collect information regarding your geolocation, mobile device, push notifications, when you use our Website.
If you use our Website, we also collect the following information;
Geolocation information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our Website, to provide certain location based services. If you wish to change our access or panache and is, you may do so in your device settings.
Mobile device access. We may request access or permission to certain features from your mobile device including your mobile devices camera, contacts, microphone, reminders, SMS messages, social media accounts, and other features. If you wish to change our access or permissions, you may do so in your device settings.
Mobile device data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and vision, hardware model Internet service provider and all mobile carrier and Internet protocol (IP) address (or proxy server). If you are using our Website, we may also collect information about the phone network associated with your mobile device, your mobile devices operating system or platform, the type of mobile device you use, your mobile devices unique device ID and information about the features of our Website you are so accessed.
Push notifications. We may request to send you push notifications regarding your account or certain features of the Website. If you wish to opt out from receiving these types of communications, you may turn them off in your device settings.
This information is primarily needed to maintain the security and operation of our Website, for troubleshooting or for our internal analytics and reporting purposes.
Information collected from other sources
In short: we may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third-parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behaviour data), internet protocol (IP) addresses, social media profiles, social media URLs and customer profiles, for purposes of targeted advertising and event promotion. If you interact with us on social media platform using your social media account (e.g. Facebook or Instagram), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media accounts privacy settings.
2. HOW DO WE USE YOUR INFORMATION?
In short: we process your information for purposes based on legitimate business interest, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose is listed below.
We use the information we collect all receive:
To facilitate account creation and log on process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and log on process for the performance of the contract. See the section below headed “HOW DO WE HANDLE YOUR SOCIAL LOGIN” for further information.
To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to indicate your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to contact you about your use of our Services.
To enable user to use the communications. We may use your information in order to enable users to use the communications with each user’s consent.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
To send administrative information to you. We may use your personal information to send you a product, service and new feature information and all information about changes to our terms, conditions, and policies.
To protect our services. We may use your information as part of our efforts to keep ourselves safe and secure (for example, for food monitoring and prevention).
To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
Administrative prize draws and competitions or giveaways. We may use your information to administer prize draws and competitions when you elect to participate in our competitions or giveaways.
To deliver facilitate delivery of services to the user. We may use your information to provide you with the requested service.
To respond to use the enquiries/offer support to users. We may use your information to respond to your enquiries and solve any potential issues you might have with use of our Services.
To send you marketing and promotional communications. We and all our third-party marketing partners may use the personal information you sent us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt out of our marketing emails at any time (see the “What are your property rights “below).
Deliver targeted advertising to you. We may use your information to develop and display personalised content and advertising (and work with third-party is to do so) tailored to your interest and all location and to measure its effectiveness.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In short: we only share information with your consent, to comply with laws, to provide you with Services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: we may process your data if you have given us specific consent to use your personal information for specific purpose.
Legitimate interests: we may process your data when it is reasonably necessary to achieve a legitimate business interests.
Performance of the contract: we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal obligations: we may disclose information where we are legally required to do so in order to comply with applicable law, governmental requests, judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirement).
Vital interests: we may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threat to the safety of any person and legal activities, or as evidence in litigation in which we are involved.
More specifically we may need to process your data or share your personal information in the following situations:
Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business partners. We may share your information with our business partners to offer you certain products, services or promotions.
Other users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with the public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services to a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, the users will be able to view descriptions of your activity, communicate with you within our services, and view your profile.
Offer wall. Our Website may display a third party hosted “offer wall”. Such an offer wall allows third-party advertises to offer virtual currency, gifts, or other items to use this in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our Website and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall you will be brought to an external website belonging to other persons and will leave our Website. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with your relevant reward. Please note that we do not control third-party websites and have no responsibility in relation to the content of such websites. The inclusion of a link towards a third party website does not imply an endorsement by us of each website. Accordingly, we do not make any warranty regarding such third party websites and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy notice and terms of service relating to the use of those websites.
4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In short: if you choose to register or login to our Services using the social account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter login is). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for other uses of your personal information by third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on the sites and apps.
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In short: we may transfer, store, and process your information in countries other than your own.
Our servers are located in United States. If you are accessing our Services from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in United States, South Africa, and other Southern African or African countries.
If you are a resident in the European economic area, then these countries may not necessarily have data protection laws or similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
European Commission’s standard contractual clauses:
We have implemented measures to protect your personal information, including by using the European Commission’s standard contractual clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA in accordance with European data protection laws and regulations. Our standard contractual clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In short: we are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Website.
The Services may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collection by third-party is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In short: we keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in back up archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In short: we aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third-parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.
9 WHAT ARE YOUR PRIVACY RIGHTS?
In short: in some regions, such as the European economic area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European economic area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request please use the contact details provided below. We will consider and act upon any request in accordance with applicable Data protection laws.
If you are relying on your consent to process your personal information, you have the right to withdraw your consent at any time please note however that this will not affect the lawfulness of the processing before it is withdrawn, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you have any questions or comments about your privacy rights, you may email us at firstname.lastname@example.org
If you would at any time like to review or change the information in your account or terminate your account, you can:
· Log into your account settings and update your user account.
Opting out of email marketing: you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list - however, we may still communicate with you, for example to send you service related emails that are necessary for the administration and use of your account, do you respond to service requests, or for non-marketing purposes. Two otherwise opt out, you may:
· Access your account settings and update your preferences.
10. CONTROLS FOR DO-YOU-NOT TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a do not track (“DNT“) feature or setting you can activate to sit on your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If the standard for online tracking is adopted that we must follow in the future, we will inform you about this practice in a revised version of this privacy notice.
11 DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In short: yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California civil code section 1798.83, also known as the “Shine the light law”, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to 3rd parties for direct marketing purposes and the names and addresses of all third-parties with which we share personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California and have a registered account with a service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email addresses associated with your account and statements that you reside in California. We will make sure that the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California code of regulations defines a “resident”, as:
(1) Every individual who is in the state of California for other than a temporary or transitory purpose and
(2) Every individual who is domiciled in the state of California who is outside the state of California for a temporary or transitory purpose.
All other individuals are defined as “non-residents.“
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | examples | Collected
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet protocol address, email address and account name | NO
| B. Personal information categories under California federal law | Name, contact information, education, employment, employment history and financial information | YES
| C. Protected classification characteristics under California offered all the | Gender and date of birth | NO
| D. Commercial information | Transaction information, purchase history, financial details and payment information | NO
| E. Biometric Information | Fingerprints and voice prints | NO
| F. Internet or other similar network | Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems and advertisements | YES
| G. Geolocation data | Device location | NO
| H. Audio, electric, visual, thermal, olfactory or similar Information | Images and audio, video or call recordings created in connection with our business activities | NO
| I. Professional or employment related Information | Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us | NO
| J. Education information | Student records and directory and | NO
| K. Inferences drawn from other personal information | Inferences drawn from any of the collective personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO
We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:
· Receiving help through our customer support channels;
· Participation in customer surveys or contests; and
· Facilitation in the delivery of our services and to respond to your enquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email and email@example.com, or by referring to the contact details at the bottom of this document.
If you are using and authorised agent to exercise your right to opt out we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling inverted, of your personal data.
Fluid Tech Inc. has not disclosed or sold any personal information to 3rd parties for a business or commercial purpose in the preceding 12 months. Fluid Tech Inc. will not sell personal information in the future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data - request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and leave your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that maybe required to protect against illegal activities.
Right to be informed - request to know
Depending on the circumstances, you have a right to know:
· Where do we collect and use your personal information;
· The categories of personal information that we collect;
· The purposes for which the collected personal information is used;
· Whether we sell your personal information to 3rd parties;
· The categories of personal information that we sold or disclose for business purposes;
· The categories of third-parties to which the personal information was sold or disclosed for a business purpose; and
· The business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a customer request or to re-identify individual data to verify a consumer request.
Right to non-discrimination for the exercise of a consumer’s privacy rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request we will need to verify your identity to determine you are the same person about whom we have the information in our system. This verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request to submit we may ask you to provide certain information so that we can match the information you provided with the information we already have on file, we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification method as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
· You may object to the processing of your personal data
· You may request a correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
· you can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in the accordance with the CCPA.
· You may request to opt out from future selling of your personal information to 3rd parties. Upon receiving a request to opt out, we will act upon request as soon as feasibly possible but no later than 15 days from the date of the request submission.
To exercise these rights you can contact us by email at firstname.lastname@example.org, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In short: yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated inverted, revised investment, date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
13. How can you contact us about this notice?
If you have questions or comments about this notice, you may email us at email@example.com or by post to:
Fluid Tech, Inc.
898 South State ST, Ste 310 #200
Orem, UT 84058
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email us at firstname.lastname@example.org
and we will respond to your request with in 30 days.