1. Importance of your privacy

At Fluent, your privacy is of great importance to us. We understand that you entrust us with certain private information to help us provide various products and services. It is essential for us that you understand what personal information that we collect and why.   In exchange for your trust, you expect and deserve our commitment to treat your information with respect and in accordance with this Privacy Policy. Rest assured that we will protect your privacy.   For purpose of clarity, we have users and customers that use different portions of our service but both adhere to this Privacy Policy.   Under no circumstances will Fluent sell or share any personal information about you to or with any person or organization except:   (i) as authorized by you, (ii) in connection with providing various products and/or services to you (the “Service(s)”), (iii) to the extent you make any use of Fluent’s mobile software application commonly referred to as “Fluent app” or any other Fluent mobile application (collectively the “Application“), or Fluent’s website (“Website”), (iv) to partners with which Fluent has a business relationship (our customers), (v) as may be required by law or court order, or (vi) as otherwise set forth herein.  

The Privacy Policy below describes the standards we live up to in handling information about you and any personal information you submit through the Website and/or the Application and sets out the various purposes for which we may process your personal data.

2. A special note about children

Children are not eligible to use our Services and we ask that individuals under the age of 18 do not submit any personal information to us or use the Services. Although visitors of all ages may navigate through the Websites or use our Application, we do not knowingly collect or request personal information from those under the age of sixteen without parental consent. If, following a notification from a parent, guardian or discovery by other means, a child under 18 has been improperly registered on our site by using false information, we will cancel the child’s account and delete the child’s personal information from our records.  

Other age restrictions may be set forth in Fluent’s Terms of Use from time to time.

3. The personal information we collect

There are several areas on the Website and/or within the Application where you may be asked to enter both personal and non-personal information. For more detailed information on the personal information we collect, please see the sections below.

3.1 Registration data

To use certain of Fluent’s Services and/or to access the Application and the Website, you’ll need to provide certain personal information which may include, without limitation, your name, password, phone number and email address.   If a user connects to the Services and/or the Application using credentials from a third party application (e.g. Facebook), the user will provide us with authentication information such as encrypted access credentials. We may also collect other information available on or through the user’s third party application account, including, for example, name, profile picture and email address.

3.2 Technical information we collect

When you use Fluent’s Services and/or access the Application and the Website, we automatically collect certain technical information.   (a) Usage data In order for Fluent to ensure that we are providing the best possible consumer experience on the Website and within the Application, we collect and track certain user and customer information, such as IP address, general geographic location as indicated by the IP address, browser and/or mobile platform type, the webpages viewed on our websites, whether someone interacts with content available on our websites and how.   In addition, when you use the Application Fluent automatically receives and records information on our server logs from your browser or mobile platform, including information regarding your mobile or browser device, IP address and location. Fluent also automatically collects and uses additional information from users and customers such as Application and/or Website open date and time, idle time, and clicks and/or swipes within the Application and/or Website (together with time and order).   (b) Device information We may collect device-specific information, such as your hardware model, operating system version, unique device identifiers, language settings and mobile network information.   (c) Cookies When you visit the Website, our Web server may send a cookie to your computer. This cookie stores a limited amount of information about your site visit and tracks aggregate information on how our site is being used, including session counts, navigation patterns, pages visited, etc. By using cookies we may collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the webpages you view on our websites and whether you interact with content available on our websites and how. If you choose to set your web browser to not accept cookies, Fluent can’t guarantee that the Website will work as intended.   (d) Weblogs Fluent may also utilize web logs to track aggregate information about how our site and/or the Application is being used. Web logs track anonymous user information, including the number of visitors to the Website, operating systems, IP address (if publicly available), and browser type. Unlike cookies, web logs are maintained only on Fluent servers and do not store or place anything on the user’s computer.   (e) Advertisement identification numbers If you come to the Fluent Website or Application from an online advertisement, an anonymous identification number may be passed to the Website or Application. This information cannot be used to gather any personally identifiable information about you. It will only allow us to track the overall effectiveness of our online advertising, marketing and banner advertisement campaigns.

3.3 Other Information we get from your use of the Services

We may collect information about the Services that you use and how you use them. This information includes the following.   (a) Payment data If you make a purchase through the Service, your credit or debit card information (such as card type) and other financial data that we need to process your payment may be collected and stored by us and/or the payment processors with which we work. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, and your card’s type, expiration date, and certain digits of your card number.   (b) Information from surveys You may have the option of completing an online survey at the Website or within the Application from time to time. Participation in surveys is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us in connection with any such survey.   (c) Information from the “Contact Us” section of the Website or Application. You may contact Fluent through the “Contact Us” feature for support issues or general inquires. Participation in this area is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us.   Fluent may also collect information posted by users on social media sites for users that have opted to connect to or otherwise link Fluent with social media accounts including Facebook and Twitter.   (d) Information collected other sections of the Website or Application. Fluent may, from time to time, make various resources available to you at the Website or within the Application. At times we may collect personal information in connection with providing such services.

4. Our legal grounds for handling personal information

There are different legal grounds that we rely on to use your personal information as stated hereunder.

4.1 Performance of a contract

The use of your personal information described herein may be necessary to perform the agreement you have with us. For example, to give you access to the Application, the Website and the Services, to register and maintain your account, to enable payment services, to help with support issues and to make sure that your Application performs as intended or to respond to your requests.

4.2 Legitimate interests

We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyse and improve the Services and the content on our Website and the Application, to send you notifications about software updates or information about our Services or to use your personal information for administrative, fraud detection or legal purposes.

5. How we use personal information

Fluent uses the data we collect to provide you with the Application, the Website and the Services, which includes using data to improve and personalize your experience. We also use the data to communicate with you, for example, informing you about your account, new services, security and other types of updates.

5.1 Providing the Application and the Services

We use data to provide, operate, support and improve the Application, the Website and the Services to ensure that partners can sell food items to users as effortlessly as possible. Such data use also includes the handling of payment information for the purpose of being able to provide you with the Services. This processing is necessary for the performance of the agreement we have with you.   Supplementary User Data may also be used to give users access to customized, personalized, or localized content, recommendations, features, and advertising through the Application and the Services.

5.2 Support services

We use data to respond to customer enquiries, diagnose Application/Service problems and provide other customer care and support services. This processing is necessary for the performance of the agreement we have with you, as well as to serve our legitimate interest.

5.3 Service Improvement

We continually use data for research purposes and to develop and improve our Services, including maintaining and improving the performance of the Application and the Services, developing and adding new features or capabilities. This processing is necessary to serve our legitimate interest.

5.4 Business Operations

We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.

6.5 Security, Safety and Dispute Handling

We use data to protect the security and safety of our users, customers, and the Application, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest.   In addition, Fluent may disclose account or other personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with Fluent’s rights or property, other Website or Application users or anyone else that could be harmed by such activities. This processing is necessary to serve our legitimate interest.

5.6 Communication, Marketing and Advertising

We use the data we collect to deliver and personalise our communications with you. For example, we may contact you by email or other means of electronic communication (including through the Application) to inform you about new features or services, security or software updates or invite you to take part in a survey. This processing is necessary to serve our legitimate interest.  

We may also share certain aggregated data with other third parties for general marketing and demographic purposes; however, this data, when shared on an aggregated basis, does not include any of your personal information.

6. How we share personal information

Fluent does not and will not sell personal information about our users and customers. We only disclose your data as described in this Privacy Policy.   We do not sell or share any personal information about you to or with any person or organization except   (i) as authorized by you, (ii) in connection with providing various products and/or services to you (the “Service(s)”), (iii) to the extent you make any use of Fluent’s mobile software application commonly referred to as “Fluent app” or any other Fluent mobile application (collectively the “Application“), or Fluent’s website (“Website”), (iv) to partners with which Fluent has a business relationship (our customers), (v) as may be required by law or court order, or (vi) as otherwise set forth herein.   In particular, and not in limitation of the foregoing, information you as a user enter at the Website and/or Application;   (i) will be shared with the partners or third party service providers with which Fluent has entered into a business relationship in order to provide the Services, (ii) may be shared with various third parties in connection with making available to you certain offers (which offers may be based on or related to your location at the time the offer is made available, unless you have opted out from receiving marketing information and/or Supplementary User Information).  

In addition, Fluent may disclose or otherwise use non-personal information gathered on the Website or within the Application to third parties on an aggregated basis.

7. International data transfers

  Fluent transfers, processes and stores information about its users and customers on servers located in a number of countries. Information collected within the European Union and European Economic Area (“EEA”), for example, might be transferred to and processed by third parties located in a country outside of the EU/EEA. We take great care in protecting your personal information and have put in place adequate mechanisms to protect it when it is transferred outside of the EU/EEA . For instance, by using the Standard Contractual Clauses as approved by the European Commission.

8. Security and retention of personal information

  While no system is completely secure, Fluent takes precautionary measures to help prevent personal information about you from loss, theft, misuse and unauthorised access.   Fluent will retain your personal information for as long as we deem it necessary to enable you to use the Website, the Application, to provide the Services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business.   If you have a question about Fluent’s security systems and specific retention period for certain types of personal information we process about you, please send an email to philip…@becomefluent.app.

9. Your choices and how to alter the information you submit

9.1 Deleting your information

For purposes of clarity, you are entitled to terminate your Fluent account at any time, at what point all information connected to your account will either be deleted our anonymised. However, binding legal requirements may require that we store certain information for various periods of time. In order to comply with these regulations, we may be unable to delete information from our databases.  

9.2 Altering Information

You can always alter the information you have submitted when creating your Account by going to Settings in the Application Fluent may alter, modify or delete any information you submit to the Website or through the Application if we believe, in our sole discretion, it is necessary or desirable to do so.  

9.3 Opting out of sharing of Supplementary User Data

You can always opt out of Supplementary User Data collection by logging in to the Application and follow the steps listed below: 1. Go to Settings 2. Choose “Personalisation settings” or “Handle notification preferences” 3. Opt out of the Supplementary User Data you want to  

9.4 Altering your Communication, Marketing and Advertising Preferences

You can opt out of receiving direct marketing communications from Fluent by following the instructions included in every email sent to you via the “Unsubscribe” tab. You can also opt out of email subscriptions or in-app messaging by updating your profile settings in the Application or on the Website or by contacting Fluent. We respect your choice, and we will stop sending you promotional emails once you unsubscribe.   Please note, regardless of your communication settings, we will continue to communicate with you regarding changes to terms and conditions, policy updates, service interruptions, data breaches or other significant information about our Services.

10. Your rights in relation to your personal information

We want you to be in control of how your personal information is used by us. Subject to local law, you can do this in the following ways:   you can ask us for a copy of the personal information we hold about you by sending us a signed request you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you; in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and in certain situations, you can also ask us to send the personal information you have given us to a third party.   Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information.   We rely on you to ensure that your personal information is complete, accurate and up to date. Please do inform us of any changes to or inaccuracies in your personal information by contacting philip…@becomefluent.app. We will respond to your request as soon as possible but certainly within 30 days.   Fluent is committed to handle any request, complaint or concern that you may have about our use of your personal information in a fair and transparent way. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to file a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority.

11. Miscellaneous

11.1 Changes or updates to the Privacy Policy

Occasionally we may, in our discretion, make changes to our Privacy Policy, for example to reflect changes in the Services or regulatory requirements. When we update this Privacy Policy, we will revise the last update date.   If there are major changes to the Privacy Policy or in how Fluent uses your personal information, we will inform you either by posting a notice of such changes, prior to them taking place, or by directly sending you a notification. We encourage you to regularly review this Privacy Policy to learn more how Fluent is using and protecting your information.  

11.2 Business Transfer

We may, in the future, sell or otherwise transfer some or all of our assets or equity to a third party. Your personally identifiable information and other information we obtain from you via the Website or the Application may be disclosed to any potential or actual third party purchasers of such assets or equity and may be among the assets transferred.  

11.3 Links

The Website and/or Application may contain links to other websites or applications that are owned and operated by third parties that are not affiliated with us. When you use those links, you leave the Website or Application (as applicable) and we are unable to control how the owners of the websites or applications you link to handle any information they gather about you, including their privacy practices and use of cookies.   This Privacy Policy applies only to the Website and Application and does not govern activities on linked websites or applications. We encourage you to review the privacy policy of any other website or application you visit, download or access to understand its owner’s practices on how it collects, uses and discloses your information.

12. How to contact us

Should there be any inquiries regarding the processing of your personal data, we encourage you to reach out to us via philip@becomefluent.com. Unless stated differently, Philip Eriksson holds the responsibility of overseeing the personal data we gather through our Services as outlined in this Privacy Policy.

  Thanks for taking the time to learn about our Privacy Policy. We hope feel more comfortable using our services now.




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