Effective January 1, 2020
Flueid Software Corporation ("Flueid" or "we") respects and is committed to protecting your privacy. This Privacy Notice explains how we collect, use, and protect personal information, when and to whom we disclose such information, and the choices you have about the use and disclosure of that information.
Personal Information Collected as a Third-Party Service Provider
In almost all cases that Flueid is receiving Personal Information, it is acting as a third-party service provider to its clients. In such cases, we may collect or receive Personal Information about or from individuals for the sole purpose of providing services to or on behalf of such clients. In cases where Flueid is providing services to or on behalf of such clients, we do not share consumer information with third parties, other than (1) those with which the clients has contracted to interface with the Flueid application, (2) those which Flueid has contracted with in provision of those services, (3) law enforcement or other governmental authority in connection with an investigation, or civil or criminal subpoenas, court orders, discovery, or legal process, or (4) as directed by the client. The privacy notices of those clients shall apply and you should refer to those privacy notices and/or contact your particular service provider to understand how your Personal Information will be used by such company.
Types of Information Collected
We, and any third party we engage for the purpose of administering, operating, hosting, configuring, designing, maintaining and providing internal support for our Website, as well as third parties we may engage for improving our products and advertising for business to business purposes only, may collect two types of information from you: Personal Information and Browsing Information.
Flueid may collect the following categories of Personal information:
- contact information (e.g., name, address, phone number, email address);
- demographic information (e.g., date of birth, gender, marital status);
- identity information (e.g. Social Security Number, driver’s license, passport, or other government ID number);
- financial account information (e.g. loan or bank account information); and
- other personal information necessary to provide products or services to you.
We may collect Personal Information about you from:
- applications or other forms we receive from you or your authorized representative, which may include information about your assets and identifying information, such as name, address and SSN;
- the correspondence you and others send to us;
- information we receive from our partners or service providers;
- information about your transactions with Flueid, our affiliates, or others;
- information we receive from consumer reporting agencies and/or governmental entities, either directly from these entities or through others; and
- information we receive from other sources, as permitted by applicable laws, rules, and regulations.
Flueid automatically collects the following types of Browsing Information when you access a Flueid website, online service, or application (each an “Flueid Website”) from your Internet browser, computer, and/or device:
- Internet Protocol (IP) address and operating system;
- browser version, language, and type;
- domain name system requests; and
- browsing history on the Flueid Website, such as date and time of your visit to the Flueid Website and visits to the pages within the Flueid Website.
Like most websites, our servers automatically log each visitor to the Flueid Website and may collect the Browsing Information described above. We use Browsing Information for system administration, troubleshooting, fraud investigation, and to improve our websites. Browsing Information generally does not reveal anything personal about you, though if you have created a user account for a Flueid Website and are logged into that account, the Flueid Website may be able to link certain browsing activity to your user account.
Other Online Specifics
Cookies. When you visit an Flueid Website, a “cookie” may be sent to your computer. A cookie is a small piece of data that is sent to your Internet browser from a web server and stored on your computer’s hard drive. Information gathered using cookies helps us improve your user experience. For example, a cookie can help the website load properly or can customize the display page based on your browser type and user preferences. You can choose whether or not to accept cookies by changing your Internet browser settings. Be aware that doing so may impair or limit some functionality of the Flueid Website.
Web Beacons. We use web beacons to determine when and how many times a page has been viewed. This information is used to improve our websites.
Do Not Track. Currently our Flueid Websites do not respond to “Do Not Track” features enabled through your browser.
Use of Personal Information
Flueid uses Personal Information for three main purposes:
- To provide products and services to you or in connection with a transaction involving you.
- To improve our products and services.
- To communicate with you about our, our affiliates’, and others’ products and services, jointly or independently.
When Information Is Disclosed
We may disclose your Personal Information and Browsing Information in the following circumstances:
- to enable us to detect or prevent criminal activity, fraud, material misrepresentation, or nondisclosure;
- to nonaffiliated service providers who provide or perform services or functions on our behalf and who agree to use the information only to provide such services or functions;
- to nonaffiliated third-party service providers with whom we perform joint marketing, pursuant to an agreement with them to jointly market financial products or services to you;
- to law enforcement or authorities in connection with an investigation, or in response to a subpoena or court order; or
- in the good-faith belief that such disclosure is necessary to comply with legal process or applicable laws, or to protect the rights, property, or safety of Flueid, its customers, or the public.
The law does not require your prior authorization and does not allow you to restrict the disclosures described above. Additionally, we may disclose your information to third parties for whom you have given us authorization or consent to make such disclosure. We do not otherwise share your Personal Information or Browsing Information with nonaffiliated third parties, except as required or permitted by law. We do share Personal Information among affiliates (other companies owned by Flueid) to directly market to you. Please see “Choices with Your Information” to learn how to restrict that sharing.
We reserve the right to transfer your Personal Information, Browsing Information, and any other information, in connection with the sale or other disposition of all or part of the Flueid business and/or assets, or in the event of bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By submitting Personal Information and/or Browsing Information to Flueid, you expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above described proceedings.
Security of Your Information
We maintain physical, electronic, and procedural safeguards to protect your Personal Information.
When we provide Personal Information to our affiliates or third-party service providers as discussed in this Privacy Notice, we require that these parties agree to process such information in compliance with our Privacy Notice or in a manner that complies with applicable privacy laws. The use of your information by a trusted business partner may be subject to that party’s own Privacy Notice. Unless permitted by law, we do not disclose information we collect from consumer or credit reporting agencies with our affiliates or others without your consent.
In addition to the other rights herein, we have the right to share and use, for any purpose, the collected Personal Information that is in an aggregated, anonymized form, such that you are not identified (collectively, “De-identified Data”).
We reserve the right to transfer your Personal Information, Browsing Information, and any other information, in connection with the sale or other disposition of all or part of the Flueid business and/or assets, or in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above described proceedings. We cannot and will not be responsible for any breach of security by any third party or for any actions of any third party that receives any of the information that is disclosed to us. We may disclose your Personal Information for any purpose disclosed by us when you provide the information. We may also disclose your Personal Information with your permission or as directed by you.
Choices With Your Information
If you do not want Flueid to share your information among our affiliates to directly market to you, you may send an “opt out” request by email, phone, or physical mail as directed at the end of this Privacy Notice. We do not share your Personal Information with nonaffiliates for their use to direct market to you.
Whether you submit Personal Information or Browsing Information to Flueid is entirely up to you. If you decide not to submit Personal Information or Browsing Information, Flueid may not be able to provide certain services or products to you.
For California Residents: We will not share your Personal Information or Browsing Information with nonaffiliated third parties, except as permitted by California law. For additional information about your California privacy rights see the additional “California Residents” section below.
For Nevada Residents: You may be placed on our internal Do Not Call List by calling (888)934-3354 or by contacting us via the information set forth at the end of this Privacy Notice. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: (702) 486-3132; email: BCPINFO@ag.state.nv.us.
For Oregon Residents: We will not share your Personal Information or Browsing Information with nonaffiliated third parties for marketing purposes, except after you have been informed by us of such sharing and had an opportunity to indicate that you do not want a disclosure made for marketing purposes.
For Vermont Residents: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.
Information From Children
The Flueid Website is not intended or designed to attract persons under the age of eighteen (18). We do not collect Personal Information from any person that we know to be under the age of thirteen (13) without permission from a parent or guardian.
Flueid’s headquarters is located within the United States. If you reside outside the United States and choose to provide Personal Information or Browsing Information to us, please note that we may transfer that information outside of your country of residence. By providing Flueid with your Personal Information and/or Browsing Information, you consent to our collection, transfer, and use of such information in accordance with this Privacy Notice.
Your Consent To This Privacy Notice; Notice Changes; Use of Comments or Feedback
By submitting Personal Information and/or Browsing Information to Flueid, you consent to the collection and use of the information in accordance with this Privacy Notice. We may change this Privacy Notice at any time. The Privacy Notice’s effective date will show the last date changes were made. If you provide information to us following any change of the Privacy Notice, that signifies your assent to and acceptance of the changes to the Privacy Notice. We may use comments or feedback that you submit to us in any manner without notice or compensation to you.
Accessing and Correcting Information; Contact Us
If you have questions, would like to correct your Personal Information, or want to opt-out of information sharing for affiliate marketing, send your requests to firstname.lastname@example.org, or by phone to (888)835-8343, or by mail to:Flueid Software Corporation
11801 Domain Blvd
Austin, TX 78758
Attn: General Counsel
If you are a California resident, you may have certain rights under California law, including but not limited to the California Consumer Privacy Act of 2018 (“CCPA”). All phrases used in this section shall have the same meaning as those phrases are used under California law, including the CCPA. Please also note that nothing in this disclosure should be construed to concede that Flueid or any of its affiliates is a “business” as that term is defined under the California Consumer Protection Act (the “CCPA”).
Right to Know. You have a right to request that we disclose the following information to you: (1) the categories of personal information we have collected about or from you; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for such collection and/or disclosure of your personal information; (4) the categories of third parties with whom we have shared your personal information; and (5) the specific pieces of your personal information we have collected. To submit a verified request for this information, you may submit your request to email@example.com or call (888)835-8343. You may also designate an authorized agent to submit a request on your behalf, which requires submission of written proof of such authorization to firstname.lastname@example.org.
Right of Deletion. You also have a right to request that we delete the personal information we have collected from you. This right is subject to certain exceptions available under the CCPA and other applicable law. To submit a verified request for deletion you may submit your request to email@example.com or call (888)835-8343. You may also designate an authorized agent to submit a request on your behalf, which requires submission of written proof of such authorization to firstname.lastname@example.org.
Verification Process. For either a request to know or delete, we will verify your identity before responding to your request. To verify your identity, we will generally match the identifying information provided in your request with the information we have on file about you. Depending on the sensitivity of the personal information requested, we may also utilize more stringent verification methods to verify your identity, including but not limited to requesting additional information from you and/or requiring you to sign a declaration under penalty of perjury.
Right to Opt-Out. We do not sell your personal information to third parties, and do not plan to do so in the future.
Right of Non-Discrimination. You have a right to exercise your rights under California law, including under the CCPA, without suffering discrimination. Accordingly, Flueid will not discriminate against you in any away if you choose to exercise your rights under the CCPA.
Collection Notice. The following is a list of the categories of personal information we may have collected about California residents in the 12 months preceding the date this Privacy Notice was last updated, including the business or commercial purpose for said collection, the categories of sources from which we may have collected the personal information, and the categories of third parties with whom we may have shared the personal information.
Categories of Personal Information Collected. The categories of personal information we may have collected include, but may not be limited to: real name; signature; alias; SSN; physical characteristics or description, including protected characteristics under federal or state law; address; telephone number; passport number; driver’s license number; state identification card number; IP address; policy number; file number; employment history; bank account number; credit card number; debit card number; financial account numbers; commercial information; internet or other electronic network activity; geolocation data; audio and visual information; professional or employment information; and inferences drawn from the above categories to create a profile about a consumer.
Please note that because the above list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the “Contact” section above.
Categories of Sources. Categories of sources from which we may have collected personal information include, but may not be limited to: the consumer directly; public records; governmental entities; non-affiliated third parties; social media networks; affiliated third parties.
Business Purpose for Collection. The business purposes for which we may have collected personal information include, but may not be limited to: completing a transaction for our Products; verifying eligibility for employment; facilitating employment; performing services on behalf of affiliated and non-affiliated third parties; debugging to identify and repair errors that impair existing intended functionality on our Websites, applications, or products; protecting against malicious, deceptive, fraudulent, or illegal activity.
Categories of Third Parties Shared. The categories of third parties with whom we may have shared personal information include, but may not be limited to: advertising networks; internet service providers; data analytics providers; service providers; government entities; operating systems and platforms; social media networks; non-affiliated third parties; affiliated third parties.
Categories of Personal Information We Have Sold In The Past Year. We have not sold any personal information of California residents to any third party in the 12 months preceding the date this Privacy Notice was last updated.
Categories of Personal Information Disclosed For A Business Purpose In The Past Year. The following is a list of the categories of personal information of California residents we may have disclosed for a business purpose in the 12 months preceding the date this Privacy Notice was last updated: The categories of personal information we have collected include, but may not be limited to: real name; signature; alias; SSN; physical characteristics or description, including protected characteristics under federal or state law; address; telephone number; passport number; driver’s license number; state identification card number; IP address; policy number; file number; employment history; bank account number; credit card number; debit card number; financial account numbers; commercial information; internet or other electronic network activity; geolocation data; audio and visual information; professional or employment information; and inferences drawn from the above categories to create a profile about a consumer.