The Information We Collect
We collect a variety of information from you and other sources when you use the Fluz Service, including technical information as well as information that can be used to identify you individually, sometimes referred to as "personally identifiable information."
When you register to use the Fluz Service, you provide us with certain personal information such as your name, username, phone number, email address, payment information (e.g. credit card or debit card number) and any other personal or preference information that you provide to us.
When you launch the Fluz Service, we automatically collect a variety of information about your device and your use of the Fluz Service in log files, such as your IP address, device ID, operating system, and browser type, as well as information regarding items on the Fluz Service that you view or access and transactions you engage in using the Fluz Service, including transaction-related information, such as when you make purchases or respond to offers. This information is gathered for all users. We may also use "cookies," or small pieces of information that are stored by your browser on your computer's hard drive so that the Fluz Service may access that information on return visits. We generally do not store or retrieve any personally identifiable information in cookies. If you have set your browser to reject cookies, you may not be able to take full advantage of all the features of the Fluz Service.
If you choose to use our invitation service to tell a friend about the Fluz Service, we may ask you for information needed to send the invitation, such as your friend's email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Fluz stores this information to send this one-time invitation, to register a friend connection if your invitation is accepted, and to track the success of our referral program. Your friend may contact us at firstname.lastname@example.org to request that we remove this information from our database.
By using the Fluz Service, you are consenting to have your personal data transferred to and processed in the United States.
Use of Information Obtained by Fluz
Fluz uses the information you provide or that we collect from third party sources to operate, maintain, enhance, and provide all of the features found on the Fluz Service. We will use the contact information you have provided to contact you for administrative purposes, for customer service purposes, to notify you of activity within the Fluz Service, to address intellectual property infringement, rights of privacy, or defamation issues, regarding User Content that you have posted to the Fluz Service, or to send you notifications regarding new services offered by Fluz that we think you may find valuable.
Fluz or our reward partners, which include Empyr, Inc. (“Reward Partners”), and payment card networks, including American Express, Visa and MasterCard (“Payment Card Networks”), use your information to confirm whether purchases made by you are qualifying transactions, contact you in connection with any such purchases, and to comply with laws and regulations related to purchases made by you through the Fluz Service.
Fluz, Payment Card Networks, and Reward Partners use your credit card or debit card information to track your purchases. In addition, if you opt-in to have any cash back earned by you credited to your credit card or debit card, we will use your credit card or debit card information for the purposes of processing any cash back you may earn to your selected credit card or debit card account.
Fluz uses information in your profile or related to your activities on the Fluz Service in order to personalize the application experience for you (such as remembering your information so that you will not have to re-enter it during your visit or the next time you use the Fluz Service), and to understand and analyze the usage trends and preferences of our users, to improve the way the Fluz Service works and looks, and to create new features and functionality.
Fluz uses automatically collected technical information, "cookies" information, and any other information we collect from you during registration or at other times to: (a) provide customized third party advertisements, content, and information; (b) monitor and analyze the effectiveness of the Fluz Service and third party marketing activities; (c) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (d) track your entries, submissions, and status in any promotions or other activities.
Payment Card Network Transactions and Your Data.
- Fluz or Reward Partners will use your transaction data to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for a Reward or an Offer, which may include Fluz sharing your transaction-related data with our Reward Partners.
- Fluz or Reward Partners may share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points should be awarded; for example, Fluz or Reward Partners may share the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction.
- Fluz or Reward Partners may provide participating merchants or manufacturers aggregated and anonymized information relating specifically to enrolled card activity solely to allow our participating merchants to assess the results of their campaign.
- Fluz or Reward Partners may create a record of the transaction data and thereafter maintain and use data in connection with operating Fluz rewards program.
- Fluz or Reward Partners may conduct analysis for the improvement and optimization of the Fluz rewards program.
- Fluz or Reward Partners and/or Payment Card Network may provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.
You authorize the sharing, exchange and use of transaction data described above and herein by and among Fluz and Fluz’s Rewards Partners, applicable Payment Card Networks and applicable merchants.
IMPORTANT NOTE: You may opt-out of transaction monitoring on the payment card(s) you have registered at any given time by:
- Go into your settings by clicking the Settings icon on the navigation bar
- Click on the Cards section
- Click on the trash bin
- Confirm that you want to remove the linked card
Protection & Storage
We store and process your personal and financial information and electronic copies of all correspondence through Google Cloud and VGS. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. The privacy policies and security systems utilized by these parties can be viewed at https://cloud.google.com/security/privacy/,
Sharing Your Information with Third Parties
Fluz is not in the business of selling your information, and we take your privacy very seriously. In the course of providing the Fluz Service to you and other users, we make limited disclosures of your information to others for a variety of purposes.
The Fluz Service may currently or in the future enable users to publish information and communicate in a variety of ways. Any personally identifiable information that you voluntarily choose to make available to others through use of the Fluz Service, such as on a public profile page or in a comment, posting, or in other User Content, will be available for use without restriction to the recipients. Once you make your personal information available to others in this manner, Fluz cannot control how it is collected, used, and disclosed by the recipients. If you choose to use features on the Fluz Service that allow you to publish or syndicate information to third party services such as Facebook, use and disclosure of any information you choose to disclose in this manner will be subject to such third party's privacy policies.
Although we may allow you to set privacy options that limit access to your User Content, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you may choose to share your information. Therefore, we cannot and do not guarantee that User Content you post on the Fluz Service will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained in the Fluz Service.
Fluz may also share automatically collected and other non-personally identifiable information in an aggregate form (such as user trends, application downloads, and demographic information) with a variety of third parties, including our affiliates, advertisers, publishers, and other current and prospective investors or business partners. This information may be used to assist such parties in understanding the usage, viewing, and demographic patterns for certain programs, content, services, advertisements, promotions, and/or functionality on the Fluz Service.
In the event that the Fluz Service links to certain third party content which requires access credentials (such as a name, user ID, or password) for access, we may provide the access credentials that you give to us to the operator or website owner of the third party content in order to facilitate and enable your access to that third party content.
We share your information with third parties where we believe such sharing is 1) incidental to our ordinary business operations (e.g., emailing you through a third party server), 2) legally required or when we choose to collaborate with a law enforcement agency in the investigation or other law enforcement activity, 3) useful to protect and defend our rights and property, 4) useful to protect the personal safety or property of our customers or the public, or 5) authorized by you.
Third Party Advertising
Fluz does not provide any personally identifiable information to these third-party ad servers or ad networks without your consent or except as part of a specific program or feature for which you will have the ability to opt-in. However, please note that if an advertiser asks Fluz to show an advertisement to a certain audience or audience segment and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience they were trying to reach.
Changing or Removing Information
Fluz users may modify or delete certain profile information at any time by logging into their account. Information will be updated promptly in active user databases. Individuals who wish to deactivate their Fluz Service account may do so by editing their user accounts or by emailing us at email@example.com. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to other Users. Further, even after removal, copies of User Content may remain viewable in cached and archived form or if other Users have copied or stored your User Content or if you shared specific information publicly through various social channels.
Fluz takes certain precautions to protect our users' information and to limit the risk that it will be accessed without authorization, including use of certain industry standard technologies and practices. We cannot, however, ensure or warrant the security of any information you transmit to Fluz, and you do so at your own risk. If Fluz learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Fluz may post a notice through the Fluz Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach, or if you have any questions about the security of Fluz applications, please contact us at firstname.lastname@example.org
Modifications to this Policy
Data Collection Policies
This Policy describes how we collect, use, transfer, and safeguard information about you and your options regarding accessing or modifying such information. The Policy applies when you:
- Agree to the Fluz Terms and Conditions;
- Visit or utilize a Fluz website on which this Policy is posted;
- Download any Fluz Service (such as the Fluz Rewards app) to your mobile device;
- Create a Fluz account through the Fluz app or any other account for a Fluz Service;
- Use any Fluz Service to conduct a Payment Method transaction, carry out any Fluz Merchant Loyalty/Rewards Account program function (such as point accrual or reward redemption) using a Fluz Service, or to opt-in, review or redeem any advertisements or offers through a Fluz Service
In this Policy we use the terms “personal information” and “personally identifiable information” or “PII” to describe information that can be associated with an individual and can be used to identify that individual. We do not consider personal information or PII to include information that has been anonymized or aggregated so that it does not identify an individual. You represent that if you give us PII on behalf of someone else, the person providing the PII to you gave you consent to provide their individual information to Fluz. If someone else gives us PII on your behalf, you represent that you gave that person consent to provide your PII to Fluz.
In this Policy, the following definitions apply:
“Fluz” means the Fluz standalone mobile app or any payment functionality Fluz provides in any separate Fluz Merchant app.
“Fluz Account” means the account you create by registering your mobile device to use the Services through either the Fluz app or any separate Fluz Merchant app using Fluz.
“Feedback” means all feedback, suggestions, and ideas you provide to Fluz concerning improvements or enhancements to the Services. “Feedback” may also include survey responses or other reporting methods.
“Loyalty/Rewards Account” means a loyalty/rewards account you have with a participating Fluz Merchant that you choose to load into your Fluz Account that will be used in conjunction with all of your purchase of goods and services at that participating Fluz Merchant unless and until you remove that Fluz Merchant’s Loyalty/Rewards Account from Fluz.
“Fluz Merchant” means a merchant that participates in the “Fluz Network.”
“Fluz Network” means the mobile payments network developed and managed by Fluz Inc., which includes the Fluz app and any other product or Service created, developed or facilitated by Fluz.
“Payment Method” means the payment type or account you load into your Fluz Account to pay for goods and services at participating Fluz Merchants.
“Personal Information” or “Personally Identifiable Information” (or “PII”) means information that can be associated with an individual and can be used to identify that individual, and may include Feedback, User Generated Data or any other PII necessary to participate in the Services.
“Services” means the mobile products or services offered by Fluz online and offline.
“Third-Party Provider” means a third-party service provider retained by Fluz whose products, services or support may be used to provide the Services, including Payment Method issuers.
“User Generated Data” means any information generated by your use of the Services, including automatic reporting and other tools that give you the ability to create, post and distribute various forms of content for, and in connection with, the Services, including, but not limited to: payment transaction data; pictures; photographs; videos; and other information, including content generated by you. For pictures, photographs, and videos, the User Generated Data includes only those pictures, photographs, and videos that you take through Fluz, and does not include those pictures, photographs, and videos you take via the standard functions on your mobile device, or that you take through any other app not related to Fluz.
How We Collect Information
Fluz collects information from you regarding your use of the Services in the following ways:
Fluz will collect information from you, including PII, when you interact with the Services. For example, you provide information to Fluz when you:
- Sign up for the Fluz app, update profile information, or any other Fluz information;
- Add a Payment Method to Fluz;
- Initiate or complete a Payment Method transaction, a Loyalty/Rewards Account transaction or redeem an offer using the Services (including the location information of the physical point-of-sale terminal where such Payment Method transaction or Loyalty/Rewards Account transaction occurs for Fluz’s operational uses, such as transaction record information and fraud detection/prevention);
- Opt-in to receive advertising or offers or other marketing communications as part of the Services;
- Interact with any advertising or offers in the Services;
- Redeem a promo code or other offer;
- Complete a survey related to the Services; or
- Receive customer support
In addition, Fluz may collect other information through the Services. For example, Fluz collects data through use of technologies such as:
- Location-based services for which you opt-in or location detection technology, such as GPS signals, sent by your mobile device;
- Please note that failure to opt-in for location-based services using your mobile device may reduce or eliminate some of the Fluz features or other Services available to you
- Device identifiers (such as unique device identifiers or device fingerprint);
- Data analytics (such as analyzing anonymized and aggregated data generated by the Services);
- Services analytics (such as diagnostics to improve the functionality of the Services); or
- Physical point-of-sale terminals for advertising and marketing Services that you opt-in to receive.
Fluz Inc. sometimes obtains PII from other sources, such as through mergers and acquisitions with other companies, as well as through commercial arrangements with Third-Party Providers, business partners, and other sources. Information Fluz receives from a third party is subject to your separate agreement with such third party, unless you enter into a separate agreement with Fluz or otherwise give Fluz your permission to use such information. Fluz may merge information Fluz receives from third parties with information Fluz has collected or will collect subject to such limitations.
Information We Collect
You must provide Fluz with the following information in order to use the Services requested:
- Your full legal name, date of birth, physical address, email address, and mobile device number;
- Payment transaction data and details for payments made for goods and services at participating Fluz Merchants;
- Payment Method data you choose to enter into Fluz, as well as information needed to complete Payment Method transactions. Payment Method data may include your bank account information, credit or debit account or gift card or stored value account details, related security codes or other payment credentials;
- Additional PII required for authentication of Payment Methods you choose to enter into Fluz, such as driver’s license number, social security number, or answers to challenge and response questions used to authenticate your identity.
- Loyalty/Rewards Account IDs or account numbers;
Optional circumstances that may necessitate PII collection:
- Interest in and use of advertising, marketing and offers in conjunction with use of Fluz;
- Responses to survey questions regarding the Services
- Please note if you participate in surveys, Fluz will collect the information you provide to Fluz, which may include PII;
- Your user preferences, product and Services interests, communication choices, and other user profile information, including Feedback and User Generated Data;
- Your protected health information, claims or other information used to measure your health or wellness if such information is included in your Payment Method transactions.
- Please note that while direct protected health information is not normally required for a Payment Method transaction, some protected health information, such as the number of prescriptions you purchase each month, or the location of the pharmacy or store where you purchase prescriptions, may be included in information generated in conjunction with a Payment Method transaction.
Information Collected from your Wireless Operator
For security and identity purposes, personally identifying information will be collected from your mobile provider.
General Information Automatically Collected by Fluz When You Use the Services
Fluz uses location detection technology to determine your approximate location, nearby Wi-Fi access points, and cell towers. When you use the Services, Fluz automatically collects and stores certain information in activity logs such as details of how you used the Services.
Special information is automatically collected for certain Services. For example, if you use the Services in connection with a mobile device or mobile application, Fluz will automatically collect additional information about you, your device, and the Services on your device such as:
- Mobile device settings and operating information such as system and version; screen resolution; services version (e.g. 1.0, 2.0, etc.); and device type, identifiers or capabilities;
- System activity;
- Hardware settings;
- Total amount of time spent in the Services;
- User creation time;
- Length of Services session.
Unique Information Generated by Your Use of the Services
Fluz also collects certain types of unique information generated by your use of the Services such as:
- Application identifiers;
- Session ID and User ID in connection with use of Fluz Account;
- Information, including usage information, such as frequency of use or average number of minutes for use, generated through use of the Fluz Account;
- Date and time;
- Location of purchases to complete a Payment Method transaction;
- Internet Protocol (IP) address;
- Other transaction data such as amount of purchase, store name or register number;
Optional circumstances that may necessitate unique information generated by your use of the Services:
- If you opt-in for certain location-based advertising and marketing Services or other Services
- For example, such information will be used to “recognize” you within a store or specific geographic location to provide relevant ads and offers, or in conjunction with a Fluz Merchant’s loyalty/rewards program or customer appreciation activities
- If you opt-in for other location-based services, location information necessary to provide such Services
- For example, store locators and directions
- If you opt-in for Services involving advertising or offers, transaction data for marketing purposes that is used to generate relevant advertising and offers, which may be used in conjunction with such advertising or offers;
- If you opt-in and register your Loyalty/Rewards Accounts with a participating Fluz Merchant, information necessary for you to participate in such loyalty/rewards program.
- Please note that Fluz will automatically transmit information regarding any loyalty/rewards benefits based upon the rules of the specific Fluz Merchant’s loyalty/rewards program. Information about these loyalty/rewards is shared only with the Fluz Merchant or issuer owning or operating the loyalty/rewards program. Use of your information is governed by the Fluz Merchant or issuer owning or operating the loyalty/rewards program. Refer to their terms and conditions governing use of your information.
How We Use Information We Collect
We use information we collect to: conduct business and improve the effectiveness of Fluz Services; develop new products and Services; provide information and support for the Services; conduct research and analysis including focus groups and surveys; better understand your needs and interests; personalize communications and advertising/offers; promote a quality experience for users of Services; and to perform other business activities related to the Services as needed or as otherwise described in this Policy.
For example, we will use your information to:
- Create and maintain your Fluz Account(s);
- Communicate, interact and build the Fluz relationship with you;
- Gather transaction statistics relating to your use of Fluz in order to collect information to measure, analyze and improve the Services;
- Manage dispute resolution and perform customer service activities;
- Customize the content, products, and features (including marketing offers that you opt-in to receive) that are offered to you in the Services;
- Process, fulfill, and follow up on transactions and requests for products, services, support, and information via the Services;
- Engage in market research and analysis;
- Comply with legal requirements;
- Enforce our agreements;
- Deter, detect, and prevent fraud and other prohibited or illegal activities.
How We Share and Disclose Information
Fluz may share or disclose your information with:
- Fluz Merchants based on your purchase of goods and services from that \Fluz Merchant, or participation in that Fluz Merchant’s loyalty/rewards program;
- Third-Party Providers involved in providing the Services;
- Third-Party Providers using your information on Fluz’s behalf in connection with signing up for a Fluz Account;
- Third-Party Providers using your information on Fluz’s behalf in connection with loading a Payment Method into Fluz;
- Third-Party Providers using your information on Fluz’s behalf in connection with a potential or actual Payment Method transaction;
- Third-Party Providers or Fluz Merchants using your information on Fluz’s behalf in connection with the loading of and use of a Loyalty/Rewards Account in Fluz;
- Third-Party Providers using your information to evaluate and enhance the performance of the Services;
Fluz reserves the right to disclose any PII necessary to protect the rights or safety of any person or entity at its sole discretion.
Fluz reserves the right to disclose any PII necessary to detect or respond to instances of potential or actual fraud or other illegal activities, to respond to a law enforcement agency’s request for information or cooperation in an investigation, or to respond to judicial process or other valid government investigation or process, at its sole discretion.
Cookies and “Do Not Track”
Fluz does not track your activities on other mobile apps. Fluz does not allow Third-Party Providers or other third parties that we have agreements with to track your activities across different mobile apps when you use Fluz. Fluz may share information with software companies that power your mobile device or app stores and companies that provide common tools and information for apps about consumers.
Your browser may be set to allow you to be notified when a cookie is to be placed on your browser, decline the cookie or delete cookies that have been placed on your browser. For general information regarding opt-out, you can visit the Networking Advertising Initiative (NAI). You can also find specific information regarding opting out of interest-based advertising that uses web browser and cookie information at this specific NAI webpage. You may also check your web browser’s instructions. Some functions of our website may not work or may work slowly if a cookie is refused.
Our website uses third party service providers to serve and host our advertisements. These third parties may place cookies on your computer if you click on or access the advertising. The third party cookies are used to track whether the site was accessed from the advertisement. The cookies generated from the advertisements do not contain PII. We do not control these cookies and they may not follow the rules we have set for our own cookies.
We also use invisible pixels, sometimes called web beacons, on our website to count how many people visit certain web pages and to collect other website usage information. Information collected from invisible pixels is used and reported in the aggregate without the use of a customer’s Personally Identifiable Information.
Use of our Services is only available to individuals who are of legal age to contract in their applicable state of residence. Fluz’s Services are not directed to children under 18 years of age. If that policy changes, we will obtain consent from a parent or guardian before we knowingly collect data from anyone under the age of 18.
Enforcement of this Policy
Fluz regularly reviews its compliance with this Policy. Please submit any questions or concerns regarding this Policy or Fluz’s treatment of PII to Fluz’s physical address or email address referenced above.
Changes to this Policy
Please note that this Policy may change from time to time. We will update Policy changes at this URL or, if the changes are significant or reduce your rights in any material manner, by a more prominent method.
Our Commitment to Security
We have put in place appropriate administrative, technical, and physical safeguards to help prevent unauthorized access and maintain data security and correctly use the information we collect. No system can be completely secure, however, and we do not guarantee that unauthorized disclosures and access will not happen.
Please submit any questions or concerns about your information to Fluz’s physical address or email address referenced above. We will provide you the personal information requested if reasonably available, or will describe the types of personal information we typically collect. We will make reasonable efforts to respond to your question as soon as possible.
Before we provide access to any data, including PII, or make any changes to it we will ask you to verify your identity or provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. We may keep a copy of the information for our records. Your right to review, update, correct, and delete your PII may be limited, subject to the law of your jurisdiction of residence: (i) if your requests are abusive or unreasonably excessive, (ii) where the rights or safety of another person or persons would be encroached upon, or (iii) if the information or material you request relates to existing or anticipated legal proceedings between you and us, or providing access to you would prejudice negotiations between us or an investigation of possible unlawful activity. Your right to review, update, correct and delete your information is also subject to our records retention policies and applicable law, including any statutory retention requirements.
Additional Financial Disclosures
By using our service, you grant Fluz the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You authorize Fluz to share your identity and account data with third parties for the purposes of opening and supporting your third parties account, and you are responsible for the accuracy and completeness of that data.