Effective date: June 29, 2018
We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at email@example.com.
What Information does Fluency collect?
Information You Provide to Us:
We receive and store any information you knowingly provide to us. For example, through the online chat or emails, we may collect Personal Information such as your name, company name, email address, billing and shipping information, product purchase information, phone number, and product registration information. Certain information may be required to register with us or to take advantage of some of our features.
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. If you do not want to receive communications from us, please indicate your preference by sending us an email to firstname.lastname@example.org.
Information Collected Automatically:
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third-party website or service, such third party may also transmit cookies to you.
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services - for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Will Fluency Share Any of the Personal Information it Receives?
We share contact information with resellers to help in the sales process. This information is the information you provided us via chat or email.
Is Personal Information about me secure?
We endeavor to protect the privacy of your information. Chat information remains is kept inside the Wix platform. Request information is stored on our Slack channel. Both systems are only accessed by Fluency Corp employees and require user authentication.
What Personal Information can I access?
We can send chat information within 30 days of the conversation.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at email@example.com
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
You may be able to add, update, or delete the information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage, and disclosure. Fluency will be the controller of your Personal Data processed in connection with the Services.
Note that we may also process Personal Data of our customers’ end-users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
What Personal Data Do We Collect From You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
Personal Contact Details: Full Name, Company Name, Address, E-mail Address, Billing and Shipping Information, Phone Number
The purpose for Prospects: We process this type of Personal Data in order to sell and market our Services to potential customers who have requested demonstrations of our Services.
Legal Grounds: We process this type of Personal Data based on our legitimate interest in providing you with the marketing and the demonstrations of our Services.
The purpose for Customers: We process this type of Personal Data in order to provide customer support.
Legal Grounds: We process this type of Personal Data for our legitimate interests in providing the Services and associated support.
Other Personal Details: Product Purchase Information, Product Registration Information, page and/or feature selection, certain cookie information, Device ID, IP Address and associated Location Data
Purpose: We process this type of Personal Data in order to provide you our Services
Legal Grounds: We process this type of Personal Data for our legitimate interests in providing the Services and performing web analytics to improve the Services and understand how our customers interact with the Services.
How and With Whom Do We Share Your Data?
Customer relationship management providers
Marketing and sales providers
Hosting service providers
Accounting and payment support providers
Administrative support providers
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
Social media services (if you interact with them through your use of the Services)
Third-party business partners whom you access through the Services (e.g. third party applications)
Other parties authorized by you
We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).
We also share Personal Data when we believe it is necessary to:
Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
Protect us, our business, or our users, for example, to enforce our Terms of Service, prevent spam or other unwanted communications and investigate or protect against fraud
Maintain the security of our products and services
If we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that are transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
How Long Do We Retain Your Personal Data?
For customers, we retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. For prospects, we retain Personal Data about you for many years. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. Afterward, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. Please contact us at firstname.lastname@example.org if you are interested in learning more about our Information Security program
Personal Data of Children
We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at email@example.com
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email firstname.lastname@example.org Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint
You have the right to lodge a complaint about the Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge and agree that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S We receive Personal Data from our EU subsidiaries and, in some cases, EU based customers, based on a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, but in some cases, such as when you provide your Personal Data directly to us, such data is necessarily transferred to us in the US since that is where the Services are hosted and operated.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to email@example.com, and we will try to resolve your concerns.