Speed, Ease, Value

Fluid Privacy Policy

1. Your personal information

MI Money Limited trading as Fluid.co.uk (We) are committed to protecting and respecting your privacy. MI Money is part of the Media Ingenuity Group, which also includes Media Ingenuity Limited (the MI Group). The MI Group also owns the brands Totally Money (www.totallymoney.com), Granite (www.granitecard.co.uk) and LUMA (www.luma.co.uk) in addition to Fluid (the MI Group brands).

The Data Protection Act 1998 (the Act) imposes obligations on companies that collect personal information as to how that information is collected, stored and processed. As required by the Act, we are registered as a data controller and details of our registration can be found here: www.informationcommissioner.gov.uk. This policy explains:

  1. What personal information we collect from you (section 2)
  2. How we store your information (section 3)
  3. How we use your information (section 4)
  4. Who we may disclose your information to (section 5)
  5. Your rights regarding your personal information (section 6).
  6. If you are applying for the Fluid Credit Card, an outline of how HD Decisions Limited and MBNA Europe Bank Limited (MBNA) will use the information contained in your application and who they will disclose it to (section 7).

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Fluid c/o MI Money Ltd, 3rd Floor, Holden House, 51 – 57 Rathbone Place, London W1T 1JU orenquiries@fluid.co.uk.

2. What information we collect from you

We may collect and process the following data about you:

  1. Information that you provide when you obtain quotations for products and services marketed and/or sold through fluid.co.uk (our site) and information that you provide if you decide to purchase such products and services. The provision of our service may also require us to store the information you provide together with details of your financial information and to combine the information you provide on separate visits to our site. We may also ask you for information when you report a problem with our site.
  2. If you contact us, we may keep a record of that correspondence.
  3. We (or a third party service provider (“Service Provider”) on our behalf) may also ask you to review our service or complete surveys that we may use for research purposes, although you do not have to respond to them.
  4. Details of transactions you carry out through our site and of the fulfillment of your requests by product providers, for example a credit card company, a credit reference agency or insurance company (Product Provider).
  5. Details of your visits to our site including, but not limited to, traffic data, location data, and other communication data and the resources that you access.
  6. Information about your computer, including where available your IP address, operating system and browser type, for system administration, to report aggregate information to our advertisers and to enable us to analyse trends of behaviour. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
  7. Information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies help us to improve our site and to deliver a better and more personalised service. For example, they enable us to store information about your preferences so we can customise our site according to your individual interests and speed up your searches. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site.

3. Where we store your personal data

  1. All information you provide to us is stored on our secure servers. We will periodically review your personal information to ensure that we do not keep it for any longer than is necessary. The maximum period we will retain your personal information for will be 10 years.
  2. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff located outside the EEA who work for us, for one of our Product Partners or in limited circumstances our Service Providers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
  3. The internet is not a secure medium. However we have put in place various security procedures to protect your information. Firewalls are used to block unauthorised traffic to the servers and the actual servers are located in a secure location which can only be accessed by authorised personnel. We use industry-standard secure sockets layer (SSL) 128-bit encryption technology to ensure that all your personal and transactional information is encrypted before transmission to those Product Partners who use encryption technology. Our robust security policies are to safeguard your privacy from unauthorised access/improper use and we will be continue to implement ever-more secure technology as it becomes available.

4. How we use your information

We use information held about you in the following ways:

  1. To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  2. To carry out our obligations arising from any contracts entered into between you and Product Providers via our site.
  3. To process a request for a quotation or application for a product or service you make through our site.
  4. To carry out a search against your credit file where you apply for a Fluid Credit Card, as described in more detail under section 7.
  5. To allow you to access and use our services and to participate in interactive features of our service (if any), when you choose to do so.
  6. To ensure that content from our site is presented in the most effective manner for you and for your computer; to personalise aspects of our overall service to you; to notify you about changes to our service and to analyse trends in your behaviour while on our site.
  7. For remarketing of products and services by us or other MI Group under other MI Group brans where you have consented to be contacted for such purposes.
  8. To provide aggregate information about our users to third party advertisers (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day) to help advertisers reach the kind of audience they want to target.

5. Where we disclose your information to third parties

By submitting information into our site, you are consenting for your personal data to be used by us, our Product Providers and in limited circumstances our Service Providers. This consent applies to both ordinary personal data and to sensitive personal data such as health information, debt information and criminal proceedings or convictions.

Before you provide us with any information about other people, you must first get their permission. This applies to all information you provide about them, but especially to sensitive data such as health information, debt information or criminal proceedings or convictions. In submitting their details, you are confirming to us that you have their permission to do so, and that they understand how their information will be used under the terms of this privacy policy.

Please be aware that once you use our site or our services, you will be regarded as having given your consent to us disclosing your personal information to the following parties:

    1. In order to provide our services we need to disclose the information you entered into the site and that we receive from the third party processing agent to the particular Product Provider who provides the product you have purchased or applied for. This information is necessary to process your purchase or application. We will hold all personal information in confidence and use it only for the purposes of assisting with your purchase or application, with certain exceptions which are detailed in this privacy policy.If you apply for a credit based product our Product Provider will perform a search with a credit reference agency using the personal information we give to that Provider. If you apply for a Fluid Credit Card our Product Provider is MBNA Bank Europe Limited (MBNA). We will disclose the information you enter into the site and that we receive from the third party processing agent to MBNA. Further information about how MBNA will use your personal details is set out in section 7 below.
    2. When you apply for a Fluid Credit Card we will disclose your information to a third party processing agent in order to check your credit file and determine whether you are likely to be accepted for a Fluid Credit Card. Further information about how the processing agent will use your personal details is set out in section 7 below.
    3. Other third parties that might be able to offer an alternative product in the event that your preferred choice of Product Provider does not approve your application, or offer a less attractive product or service than you had originally applied for, or simply a product that meets the basic criteria of the type of product for which you have searched on our site.
    4. Where we expressly set out in this privacy policy, to Service Providers to gather information or reviews from you of our service, in order to enhance our service to you and to help others make informed decisions about our products and services.
    5. The Financial Conduct Authority and/or other regulatory/governing bodies for the purposes of compliance monitoring, where we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of MI Money Limited our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    6. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
    7. We may disclose your personal information to third parties: (i) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and (b) if MI Money Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. Unless you have given us your consent, we will not provide information about you to companies outside our group for their own marketing purposes.

Please note that when you enter a contract with a Product Provider via our site, the information you have provided to us together with any further information requested by, and supplied by you to the Product Provider will be held by the Product Provider for the purposes set out in that Product Provider’s privacy policy. We have no responsibility how a Provider uses your personal information once you have contracted with that provider and have no control over who Product Providers may disclose your information to.

6. Your right to opt out

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can opt out of receiving Fluid or MI Group marketing messages at any time by:

      1. Ticking or unticking boxes on the forms we use to collect your data.
      2. By clicking on the ‘unsubscribe’ link on any marketing email sent to you; or
      3. By emailing enquiries@fluid.co.uk and writing ‘Unsubscribe’ in the subject line

All unsubscribe requests are processed within 7 working days.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

7. Credit Card Applications

THIS SECTION IS ONLY RELEVANT TO YOU IF YOU WISH TO APPLY FOR A FLUID CREDIT CARD

If you apply for a Fluid Credit Card, when you select ‘Continue’, on our application page you are authorising us to provide the information contained in your application to HD Decisions – an Experian business (“HD”).

HD has been appointed as a processing agent for the MI Group. Using your personal information, HD will analyse key elements of your credit file, to provide an indication of whether or not you are likely to be accepted for a Fluid Credit Card. HD will provide that information to Us and we will inform you on our site of the result. If HD determines that you are likely to be accepted for the Fluid Credit Card, you will then be given the option to make a full application for a Fluid Credit Card to the Fluid card issuer using its own application form or to terminate your application at that point.

PLEASE NOTE THAT:

    • Your credit file will not be provided to you directly.
    • You agree that information supplied as a result of the initial HD process can be shared with the card issuer (for them to analyse use of this service and make improvements to their processes or how they use this service).
    • The data returned from the credit bureau will be visible to HD only and will not be shared with any other party
    • This process will not have any adverse impact upon your credit standing.
    • Even if We indicate that you are likely to be accepted for a Fluid Credit Card, this is no guarantee that you will be accepted for the card, as the Fluid card issuer is entirely responsible for the decision on whether to accept you for a Fluid Credit Card or not using their own criteria. The Fluid card issuer is not bound by any indication we may communicate to you.
    • By selecting ‘Continue’ on our site, you are not committing to make an application for a Fluid Credit Card. If you choose to proceed to make a full application to theFluid card issuer for a Fluid credit card from the ranked list of offers, then the Fluid card issuer will proceed to carry out its own identification and credit application checks in accordance with its own criteria.