1 Introduction

FluidOne is backed by Livingbridge. Livingbridge is a private equity firm of over 80 people in the UK, US and Australia investing in fast-growing businesses valued up to £200m. FluidOne operates one of the most connected last mile networks in the UK with reach across the globe. By connecting into as many carriers as possible we are able to build data networks to span any location and specification.

Below is some quick guidance on terminology to help you clearly understand this Policy
Personal data is any information relating to an identified or identifiable living person.
The Data Controller is a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. In the context of this Policy, FluidOne is the Data Controller.

2 Security

FluidOne is committed to protecting your personal data and privacy. We are certified to internationally recognised quality and security standards (ISO/IEC 9001 and ISO 27001), with a UKAS accredited body. We have security measures in place designed to prevent the loss of data, preserve data integrity, and to control access to the data and know that ensuring the accuracy and security of your personal data is essential to retaining your confidence and trust.

3 Purpose of this Privacy Policy

The purpose of this privacy policy is to describe, in cases where FluidOne is the Data Controller, why and how we collect and use your personal data and provides information about your rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy policy or as otherwise stated at the point of collection. When collecting and using personal data, our policy is to be fair, lawful and transparent about why and how we process personal data.

4 What do we do with your Personal Data

Please go to the sections of this policy that are relevant to you, to find out more about what we do with your personal data: -

4.1 If you are a FluidOne B2B client

4.1.1 Why we use your personal data

We use your data for the following purposes: -

To facilitate the delivery, support and invoicing of new and existing services.
To inform of service affecting events and contractual changes, including pricing and contract renewals.
To identify if you have registered with the Corporate Telephone Preference Service (CTPS), Telephone Preference Service and/or have notified FluidOne that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
To contact you in compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne;
To send you electonic and postal communications regarding FluidOne’s activities.

4.1.2 How we obtain your personal information and the types of personal information we may obtain

Your personal information is collected in a number of ways, including enquiries submitted via the FluidOne website, through direct inbound contact made by you, or indirect contact via our inbound marketing campaigns utilising social media. We process the following types of personal information in relation to you - e.g. (this is not an exhaustive list):

Name
Job Title
Contact Details (Work address, work email address, work telephone number).

4.1.3 Our legal basis for using your personal data

The processing of your personal data is based upon the lawful basis of Legitimate Interests, with the minimum necessary level conducted to achieve the purposes outlined in section 4.1.1.

4.1.4 Who we share your data with

We may share your information with:

Network carriers who we engage to deliver part of the service, e.g. TalkTalk Business and BT Wholesale.
Technology Providers who we engage to support our operations and/or host our data, e.g. Axians (hardware support), HubSpot (inbound marketing) and Interlink (equipment courier).
Marketing Partners – e.g.: -
- Telemarketing Organisations (e.g. Astute) – so that they can: -
  - Contact you in the future, on our behalf, regarding our products and services (i.e. via telephone, postal and electronic marketing);
  - Share your information with us, for compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne;
  - Cleanse our data, ensuring it is accurate and properly formatted.

4.1.5 The transfer of your personal data to a country or international organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

4.1.6 How long we keep hold of your data

We retain processed personal data for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is 7 years.

4.1.7 Statutory or contractual requirement

The provision of your personal data is a contractual requirement in order to fulfil the purposes outlined in section 4.1.1.

4.1.8 Automated decision making and profiling

We do not make any decisions in relation to your personal data, solely by automated means without any human involvement. Nor do we conduct any automated processing of personal data to evaluate certain things about you.

4.2 If you are visiting our website

4.2.1 Why we use your personal data

We use your data for the following purposes:

If you visit our website – your personal data is obtained using cookies (see 4.2.8 for our Cookie Policy) and is used to: -
- Track visitor identity, including timestamp of first, last and current visits and the viewing session number (incremental for repeat visits);
- Track visitors who use the live chat function, enabling the resumption of previous chat sessions across multiple site visits.
If you send an enquiry via our website, either by Live Chat or Contact Us, your personal data is used: -
- To identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified FluidOne that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
- To contact you in compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne;
- To send you electonic and postal communications regarding FluidOne’s activities.
If you submit a job application via our website – please refer to Section 4.6

4.2.2 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of:

Legitimate interests – The information we collect allows us to keep you updated on FluidOne's latest product announcements, software updates and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by emailing us directly (contact@fluidone.com), or by using the unsubscribe link that appears in the footer of all our email communications.
Legal Obligation – For cases where you may have opted out of marketing communications, we also have a legal obligation to hold some personal data, albeit limited, in order to ensure no more marketing is sent to you. We may also use this personal information for internal purposes such as contract fulfilment, data analysis and research to improve FluidOne's products, services and customer communications.

4.2.3 Who we share your data with

We may share your information with:

Telemarketing Organisations (e.g. Astute) – so that they can:
- Contact you in the future, on our behalf, in compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne;
- Cleanse our data, to ensure it is accurate and up to date.
- We may also contact you using the information these organisations share with us, for compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne.

4.2.4 The transfer of your personal data to a country or international organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

4.2.5 How long we keep hold of your data

4.2.6 Automated decision making and profiling

4.2.7 Cookie Policy

To improve your experience on our site, we may use 'cookies'. A cookie is a small text file that our site may place on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies (click here for guidance). However, in a few cases some of our website features may not function as a result.

Our website also uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.

By using this website, you consent to the processing of data about you by Google in the manner described in Google's Privacy Policy - external site and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google - external site.

FluidOne also uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to "like" or "share" information from this website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other Personal Information.

4.2.7.1 Links to other websites

Our website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. When you go to other websites from here, we advise you to be aware and read their privacy policy.

For further information visit www.aboutcookies.org or www.allaboutcookies.org.

4.3 If you are someone who has provided us with your contact details at an exhibition, conference or equivalent event

4.3.1 Why we use your personal data

When you provide your business contact details at an exhibition, your personal data is used to:

Identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified FluidOne that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
To contact you directly (or via our Telemarketing partners) in the future regarding our products, services, and/or events (i.e. via telephone, postal and electronic marketing), unless we have identified that you do not wish to receive marketing information, as per above;
To send you electronic and postal communincations, for compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne.

4.3.2 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of:

Legitimate Interests – The information we collect allows us to keep you updated on FluidOne's latest product announcements, software updates and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by emailing us directly (contact@fluidone.com), or by using the unsubscribe link that appears in the footer of all our email communications.
Legal Obligation - For cases where you may have opted out of marketing communications, we also have a legal obligation to hold some personal data, albeit limited, in order to ensure no more marketing is sent to you. We may also use this personal information for internal purposes such as contract fulfilment, data analysis and research to improve FluidOne's products, services and customer communications.

4.3.3 Who we share your data with

We may share your information with:

Telemarketing Organisations (e.g. Astute) – so that they can: -
- Contact you in the future, on our behalf, regarding our products and services (i.e. via telephone, postal and electronic marketing);
- Contact you in the future, on our behalf, regarding our future events (i.e. via telephone, postal and electronic marketing);
- We may also contact you using the information these organisations share with us, for compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne.
- Cleanse our data, to ensure it accurate and up to date.

4.3.4 The transfer of your personal data to a country or international organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

4.3.5 How long we keep hold of your data

4.3.6 Automated decision making and profiling

4.4 If you are contacting us directly via telephone or email

4.4.1 Why we use your personal data's

We use your data for the following purposes:

To progress the enquiry as a business opportunity;
Identify if you have registered with the Corporate Telephone Preference Service, Telephone Preference Service and/or have notified FluidOne that you do not wish to be contacted and/or receive direct marketing information regarding our products, services and activities;
To contact you directly (or via our Telemarketing partners) in the future regarding our products, services, and/or events (i.e. via telephone, postal and electronic marketing), unless we have identified that you do not wish to receive marketing information, as per above;
We will contact you in compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne.
To send you electronic and postal communications regarding FluidOne’s activities.

4.4.2 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of:

Legitimate Interest – The information we collect allows us to keep you updated on FluidOne's latest product announcements, software updates and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by emailing us directly (contact@fluidone.com), or by using the unsubscribe link that appears in the footer of all our email communications.;
Legal Obligation - For cases where you may have opted out of marketing communications, we also have a legal obligation to hold some personal data, albeit limited, in order to ensure no more marketing is sent to you. We may also use this personal information for internal purposes such as contract fulfilment, data analysis and research to improve FluidOne's products, services and customer communications.

4.4.3 Who we share your data with

We may share your information with:

Telemarketing Organisations (e.g. Astute) – so that they can: -
- Contact you in the future, on our behalf, regarding our products and services (i.e. via telephone, postal and electronic marketing);
- Contact you in the future, on our behalf, regarding our future events (i.e. via telephone, postal and electronic marketing);
- We may also contact you using the information these organisations share with us, for compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne.
- Cleanse our data, to ensure it accurate and up to date.

4.4.4 The transfer of your personal data to a country or international organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

4.4.5 How long we keep hold of your data

4.4.6 Statutory or contractual requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data.

4.4.7 Automated decision making and profiling

4.5 If you are a FluidOne supplier

4.5.1 Why we use your personal data

We use your data for the following purposes:

To maintain a relationship with you in relation to our orders and your services, e.g. in relation to service delivery activities, invoicing and ongoing communication/relationship management;
To send you electonic and postal communications regarding FluidOne’s activities.

4.5.2 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of:

Legitimate Interests – for compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne, to maintain a relationship with you in relation to our orders and your services;
Consent – for inclusion in marketing, supplier activities and/or events, where you have consented to be contacted, or where we will seek your consent;
Legal Obligation - For cases where you may have objected to direct communication, we also have a legal obligation to hold some personal data, albeit limited, in order to ensure no more communications are sent to you. We may also use this personal information for internal purposes such as contract fulfilment, data analysis and research to improve FluidOne's products, services and customer communications.

4.5.3 Who we share your data with

We do not intend to share your data with any third party.

4.5.4 The transfer of your personal data to a country or international organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

4.5.5 How long we keep hold of your data

4.5.6 Statutory or contractual requirement

The provision of your personal data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the personal data. However, in the absence of personal data for communication and engagement before, during and after the service has been provided, substitute anonymous business contact details would be contractually required to fulfil the obligations of service.

4.5.7 Automated decision making and profiling

4.6 If you are a FluidOne recruitment applicant

4.6.1 Why we use your personal data

We use your data for the following purposes:

Consider you for a recruitment vacancy;
To conduct a DBS check for successful candidates, prior to any employment offer being made.

4.6.2 How we obtain your personal information and the types of personal information we may obtain

We process the following types of personal information in relation to you:

Name
Job Title
Contact Details (Work address, work email address, work telephone number).

4.6.3 Our legal basis for using your personal data

The processing of your personal information is based upon the lawful basis of:

Legitimate Interest – for compliance with a legal obligation to which FluidOne is subject or when we have assessed it is necessary for the purpose of legitimate interests pursued by FluidOne, we will be able to consider your application and contact you in this respect.

4.6.4 Who we share your data with

We do not intend to share your data with any third party.

4.6.5 The transfer of your personal data to a country or international organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

4.6.6 How long we keep hold of your data

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for your personal data and other documentary evidence is detailed in our Employee Data Privacy Policy if successful, or 12 months if unsuccessful.

4.6.7 Statutory or contractual requirement

There is no statutory or contractual requirement for the provision of your personal data during the application stages, however your employment history and a method of contact is a suggested minimum in order to fulfil the purposes of the recruitment process.

The provision of your personal data is a necessity for a DBS check which is a pre- requisite for any employment offer. It is also a contractual requirement for entering into an employment contract.

4.6.8 Automated decision making and profiling

4.7 If you are a visitor to FluidOne offices

4.7.1 Why we use your personal data

We use your data for the following purposes:

Notification of your arrival to the individual(s) that you are visiting;
For security, evacuation and health and safety purposes.

4.7.2 Our legal basis for using your personal data

The processing of your personal data is based upon the lawful basis of Legitimate Interests, as it is important to ensure the safety of yourself and others and also to ensure the security of our information.

4.7.3 Who we share your data with

We may share your information with:

Sign In App - All information entered into the welcome device in our 5 Hatfields office foyer is securely saved in Cloud storage provided by Sign In App.
Gyron – The datacentre landlord for our Hemel Hempstead office location who master the building access arrangements.

4.7.4 The transfer of your personal data to a country or international organisation outside of the European Union

We do not intend to transfer your personal data to any countries or International Organisations outside of the European Union.

4.7.5 How long we keep hold of your data

We retain your personal data as a record for 7 days after the date of your visit to the 5 Hatfields office. Following a visit to our Hemel Hempstead office, as this is a datacentre facility the records are held for the duration of contractual agreements at the site.

4.7.6 Statutory or contractual requirement

The provision of your personal data is not a statutory or contractual requirement, nor are you obliged to provide the personal data. However, by not providing this personal data you are acknowledging that FluidOne are unable to fulfil the intended purposes outlined in section 4.7.1.

4.7.7 Automated decision making and profiling

5 FluidOne's Contact Details

The Data Controller is FluidOne Limited (registered in England under registration no. 05296759 and with its registration address at 5 Hatfields, London, SE1 9PG). FluidOne’s Head of Compliance is the Company’s Data Protection Representative. If you have any questions about this privacy policy or how and why we process personal data, please contact us via any of the routes below:

Post: Head of Compliance, FluidOne Limited, 5 Hatfields, London, SE1 9PG

Email: privacy@fluidone.com

Phone: 0345 868 7848

6 Your Rights

Under certain circumstances, you have the rights under data protection laws in relation to your personal data. These rights are summarised below but if you would like more information on these rights, please go the ICO’s website. Additionally, if you wish to exercise any of these rights listed below, please contact us using any of the contact details provided here.

6.1 Access to your personal data

You have a right of access to personal data held by us as a Data Controller. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (1 month under GDPR).

6.2 Correcting your personal data

You have a right to request amendment(s) to your personal data. Wherever practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make the necessary amendments based on the updated information.

6.3 Restriction of processing of your personal data

In certain circumstances, you have the right to request the restriction or suppression of your personal data. This effectively allows you to limit the way that we use your persona data.

6.4 Object to processing

In certain circumstances, you have the right to object to the processing of your personal data. This effectively allows you to ask us to stop processing your personal data. Where we have told you that any use of information is based on ‘legitimate interest’, you can raise an objection to that use. When you make an objection, we’ll have up to one month to respond to you. We will stop using the information in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We’ll always tell you what the justification is.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other parts of Livingbridge and/or our Marketing Partners.

6.5 Erasure (also known as “the right to be forgotten”)

In certain circumstances, you have the right to request the erasure of your personal data.

6.6 Portability

In certain circumstances, you may have the right to obtain and reuse your own personal data, that you provided to us, for your own purposes across different services. This data will be provided in a structured, commonly used and machine-readable format and we can transmit this data directly to other parties at your request.

6.7 Withdrawal of consent

Where we process your personal data based on consent, you have a right to withdraw consent at any time.

If you would like to request to withdraw your consent, please contact us using the contact details provided here. Alternatively, to stop receiving our Marketing emails, please click on the unsubscribe link in the any of the emails we have sent to you.

6.8 Complaints

In the event you wish to complain about our use of your personal data, please send an email with the details of your complaint to privacy@fluidone.com. We will look into and respond to any complaints we receive.

You also have a right to lodge a complaint with the Information Commissioner's Office (ICO) (the UK’s data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website: www.ico.org.uk

7 Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on this web page. If we believe that the changes are material, we’ll let you know by posting the changes on this website and sending you a communication about the changes. This privacy policy was last updated on 22/02/2024.