1.1. We are committed to safeguarding the privacy of our website visitors and service users.
1.2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. 'Personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.4. In this policy, "we", "us" and "our" refer to Fluid Branding Ltd. For more information about us, see Section 11.
2. How we use your personal data
2.1. In this Section 2 we have set out:
2.1.1. the general categories of personal data that we may process;
2.1.2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
2.1.3. the purposes for which we may process personal data; and
2.1.4. the legal bases of the processing.
2.2. Usage Data:
We may process data about your use of our website and services ("Usage Data"). This data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of this data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3. Lead Data:
We may process data about your company's use of our website and services ("Lead Data"). This data may include your company IP address, company name, business telephone number, email address and names of key decision makers at your company.
2.3.1. Lead Forensics:
We use Lead Forensics (https://www.leadforensics.com/) to track activity on our website(s). Lead Forensics provides us with information on the IP address of the requesting computer, the date and duration of the user’s visit, and the web pages which the user visits. The Lead Forensics tool uses IP tracking for identifying businesses and does not utilise cookies. The Lead Forensics tracking code only provides information that is readily available in the public domain. It does not, and cannot, provide individual, personal or sensitive data regarding who has visited our website. This data may be processed for the purposes of identifying companies that may want to make use of our products and/or services. The legal basis for this processing is our legitimate interests, namely growing our business by forming relationships with new clients in a B2B environment. Lead Forensics' Software Data Compliance policy can be viewed here (https://www.leadforensics.com/software-data-compliance/).
2.3.2. GatorLeads from Spotler:
We use GatorLeads as part of Spotler’s suite of marketing tools to collect information on visitors to our website. This is accomplished in the following ways:
18.104.22.168. IP address lookup: When you visit our website we will record your IP address. This address will be matched against public and proprietary IP address databases to provide us with information about your visit. This information may identify the organisation to whom the IP address is registered but not individuals. In some limited cases i.e. single person companies, it may be possible to identify personal data from publicly available ICANN data.
22.214.171.124. Cookies, tracking & beacons: We may use various technologies to collect and store information when you use our website or Service, and this may include using cookies and similar tracking technologies, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website and Service, serve targeted advertisements, and gather demographic information about our user base as a whole.
126.96.36.199. The legal basis for the above processing is our legitimate interests, namely growing our business by forming relationships with new clients and developing relationships with existing clients in a B2B environment.
2.4. Service Data:
We may process your personal data that is provided in the course of the use of our services ("Service Data"). This data may include your name, email address, telephone number, physical address, company details, and information regarding your requirements for us to complete services offered to you. The source of this data is you or your employer. This data may be processed for the purposes of offering and selling relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4.1. Individual Mailing Data:
Certain orders may require us to deliver products and/or services to individuals on your behalf. Examples of such data include personal address information, names, and contact details. These individuals have not entered into a contract with us - this data is provided by you or your employer. We act as Processor to such data, with you as the Controller.
The legal basis for this processing is the performance of a contract between you and us. Details on our data retention policy can be seen in section 5. Individual Mailing Data will not be used for any other processing than that mentioned in this section (2.4.1). They will not be processed for marketing or prospecting purposes.
2.5. Transaction Data:
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("Transaction Data"). This data may include your contact details, your card details and the transaction details. The source of this data is you or your employer. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business.
2.6. Marketing Data:
We may process personal data to market our products and/or services to users of our website and services ("Marketing Data"). This data may include name, company name, email address, job title, industry sector, information regarding your contact preferences, and any other information that may be deemed required to further enhance our ability to market products and/or services to you effectively. This data may be processed to send you email communications or show advertisements intended to offer you services and/or products that we think may be of interest to you.
The legal basis for this processing is our legitimate interests for company growth based on a business to business company model.
We may obtain the above information;
2.6.1. Through you or your employer: This includes information given by you via form fills on our website or associated landing pages, or information provided verbally or in writing.
2.6.2. Through prospecting activities: We may obtain information about you from third party sources, such as public databases, data service companies, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us.
Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, email address, contact number, technographics, and online behavioural data (such as information about your use of social media websites, page view information, and search results and links).
We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.
UPDATE: As of 01/03/2021, our marketing automation provider changed from Dotdigital to Spotler. During this transition period, if a user wishes to edit their marketing and/or email preferences and find that a suitable page is not available on our website, we request they email [email protected] A member of our team will then be able to process such a request.
2.7. Personalisation Data:
We may process personal data obtained in the aforementioned ways to build profiles on users of our website and services ("Profile Data"). This data may include company type, job title, department, industry sector, age, gender, information on the use of our website, general interests, and any other information that may be deemed required to further enhance our ability to market products and/or services to you effectively. This data may be processed to give us a wider understanding of how our website and services are used, as well as allowing us to improve and/or personalise your experience through the website. The legal basis for this processing is our legitimate interests, namely improving our website and services and business growth.
2.8. Correspondence Data:
We may process information contained in or relating to any communication that you send to us ("Correspondence Data"). This data may include the communication content and metadata associated with the communication. The source of this data is any communication you send to us, through email, via telephone or through forms on our website (through which the metadata is generated). This data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.9. Publication Data:
We may process information that you post for publication on our website or through our services ("Publication Data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The source of this data is any information you submit regarding our products and/or services, either via email or through channels such as review collection services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and growing our business through the publication of verified customer reviews.
2.10. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.11. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.12. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.
3.3. We may disclose data to our suppliers insofar as reasonably necessary for the fulfilment of orders through our services.
3.4. Fluid Rewards is a client benefit offering points for each order placed, which can be redeemed for rewards such as gifts or experience days. This service is run on behalf of Fluid Branding by a third party, Incentivesmart.
3.4.1. Upon order completion, customers will be invited to sign up for this service.
3.4.2. Customers signing up for this service submit their personal data willingly to Incentivesmart.
3.5. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. International transfers of your personal data
4.1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2. We use third party facilities (such as our website hosting, and online chat software) in the United States of America. The United Kingdom and European Commission have made an "adequacy decision" (referred to as an “adequacy regulation” in the United Kingdom) with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the United Kingdom and the European Commission. Further details on these safeguarding measures can be obtained by emailing [email protected]
4.3. We use third party facilities (such as our supplementary graphics studio service, Binated) in India. The European Commission have made an "adequacy decision" (referred to as an “adequacy regulation” in the United Kingdom) with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the United Kingdom and the European Commission. Further details on these safeguarding measures can be obtained by emailing [email protected]
4.4. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting your personal data
5.1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or purposes.
5.3. We will retain your personal data as follows:
5.3.1. Personal Data will be retained by Fluid Branding for as long as there is a legitimate business need for retention, unless otherwise stated in this clause. This may include the need for uses such as record keeping, analysis and reporting.
5.3.2. Google Analytics Data will be retained for a maximum period of 50 months following the user's last session on our website, as per our Data Retention Policy.
5.3.3. A copy of our Data Retention Policy is available upon request, and can be obtained by [email protected]
5.4. As stated in section 7.5, you have the right to request removal of your personal data from our systems. See section 7.5 of this policy for further details on the right to erasure.
5.5. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Amendments to this policy
6.1. We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
6.2. We may notify you of changes to this policy by email.
7. Your rights
7.1. In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2. Your principal rights under data protection law are:
7.2.1. the right to access;
7.2.2. the right to rectification;
7.2.3. the right to erasure;
7.2.4. the right to restrict processing;
7.2.5. the right to object to processing;
7.2.6. the right to data portability;
7.2.7. the right to complain to a supervisory authority; and
7.2.8. the right to withdraw consent.
7.3. You have the right to request access to your personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.5.1. It may take up to 28 days for any such request for erasure to take effect in our systems.
7.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9. To the extent that the legal basis for our processing of your personal data is:
7.9.1. consent; or
7.9.2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.10. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In the UK this will be the Information Commissioner's Office (ICO).
7.11. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.12. You may exercise any of your rights in relation to your personal data in writing to us at our registered office address.
8. About cookies
8.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies used on our website
9.2. The following is a list of cookies that are set on our website whilst browsing, along with information of the third party that sets them (if applicable), and an explanation of their purpose:
- FORM_KEY: Stores randomly generated key used to prevent forged requests.
- PHPSESSID: Your session ID on the server.
- GUEST-VIEW: Allows guests to view and edit their orders.
- PERSISTENT_SHOPPING_CART: A link to information about your cart and viewing history, if you have asked for this.
- STF: Information on products you have emailed to friends.
- STORE: The store view or language you have selected.
- MAGE-CACHE-SESSID, MAGE-CACHE-STORAGE, MAGE-CACHE-STORAGE-SECTION-INVALIDATION, MAGE-CACHE-TIMEOUT, SECTION-DATA-IDS, PRIVATE_CONTENT_VERSION, X-MAGENTO-VARY: Facilitates caching of content on the server to make pages load faster.
- MAGE-TRANSLATION-FILE-VERSION, MAGE-TRANSLATION-STORAGE: Facilitates translation of content to other languages.
- fb_visitor_id, analytics_client_id, track_entry, track_referer, track_source, track_sourceid: Allow us to analyse site usage in order to make improvements to site functionality and user experience. They also let us know how users are arriving at our website.
- _dc_gtm_UA-#######-#: Google Tag Manager allows website owners to enable third party scripts on their site – we use Google Tag Manager to enable certain website features offered by third parties, such as Olark Chat.
- _uetsid, MUID, MUIDB: These cookies is used to track usage of the website in order to monitor the performance of off-site marketing activities through Bing.
- wow.session is an Essential cookie with a Session lifespan. This is an IIS Session CodeStandard session cookie served by the web server.
- wow.anonymousid is an Analytics cookie with a 2 years lifespan. This is an Anonymous Visitor ID. The cookie does not store user data, only stores active menu node over post-back.
- wow.schedule is an Essential cookie with a Session lifespan. This is a Load Balance Session QueueStandard session cookie served by the web server.
- wow.utmvalues is an Analytics cookie with a Session lifespan. This cookie stores the UTM values for the session. The cookie does not store user data, only stores active menu node over post-back.
- wow.trackingdata is an Marketing cookie with a Session lifespan. This is an Encrypted GatorMail identificationCookie which is only used by GatorMail integration so GatorLeads knows email contacts visiting website.
- wow.data is an Analytics cookie with a 2 years lifespan. This is an Encrypted GatorMail identificationCookie which is only used by GatorMail integration so GatorLeads knows email contacts visiting website.
- __racnt, __racplx0, __rafm, __rasel0, __rasesh, __ratel0: Ruler Analytics sets cookies that help us to determine how the website is being used and how users are arriving at the website, so we can improve onsite user experience and our marketing activities.
- bcookie, BizoID, bscookie, lang, lidc, UserMatchHistory: Linkedin sets cookies so it can serve adverts on its own platform based on what you have viewed elsewhere on the internet. Linkedin matches users of their service that have been on our website, and serves ads back to our website accordingly.
- fr: Facebook sets cookies so it can serve adverts on its own platform based on what you have viewed elsewhere on the internet. Facebook matches users of their service that have been on our website, and serves ads back to our website accordingly.
- PREF, VISITOR_INFO1_LIVE, YSC: We occasionally embed Youtube videos on our website – these cookies are set by Youtube and used for the functionality of these videos.
10. Managing cookies
10.1. Most browsers allow you to refuse to accept cookies and to delete cookies. You can however obtain up-to-date information about blocking and deleting cookies via these links:
10.1.1. Google Chrome: See here (https://support.google.com/chrome/answer/95647?hl=en) for details;
10.1.2. Firefox: See here (https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences) for details;
10.1.3. Opera: See here (http://www.opera.com/help/tutorials/security/cookies/) for details;
10.1.4. Internet Explorer: See here (https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies) for details;
10.1.5. Safari: See here (https://support.apple.com/kb/PH21411) for details; and
10.1.6. Edge: See here (https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy) for details;
10.2. Blocking all cookies will have a negative impact upon the usability of many websites, including this one. If you block cookies, you will not be able to use all the features on our website.
11. Our company details
11.1. Our website is owned and operated by Fluid Branding Ltd.
11.2. We are registered in England and Wales under registration number 05867605, and our registered office is atESAM, Carluddon Technology Park, Carluddon, St Austell, PL26 8WE.
11.3. You can contact us:
11.3.1. by post, to the postal address given above;
11.3.2. using our website contact form;
11.3.3. by telephone, on the contact number published on our website; or
11.3.4. by email, using [email protected]
12. Data protection contact details
12.1. Fluid Branding is not required by law to appoint a Data Protection Officer, however any enquiries relating to privacy and data laws can be directed to [email protected]