1. About Fluid
Fluid.co.uk and associated URLs (Site) and the “Fluid” brand are
owned and operated by MI Money Limited, trading as Fluid (Fluid).
In these terms and conditions, “our”, “we”, and “us” refer to Fluid.
We are committed to protecting and respecting your privacy.
(a) are registered in England and Wales (Company Registration Number 06967012) with VAT number 974859255;
(b) have our registered office and main trading address at Chapter House, 16 Brunswick Place, London N1 6DZ;
(c) are authorised and regulated by the Financial Conduct Authority in respect of consumer credit related activities including the carrying out of credit broking (FCA FRN 511936). You can find our authorisation details here;
Data protection law applies to our collection and use of personal information and MI Money Limited is a data controller for that personal information (ICO Registration Number Z2112995) of Chapter House, 16 Brunswick Place, London N1 6DZ — details of our registration can be found online at the ICO website.
2. About our service
The service we provide through Fluid.co.uk is to introduce you to third
party product providers (Product Providers), and if you wish to
proceed to check your eligibility for their products, or to apply for
their products, we collect your information and pass it through to
those third parties for those purposes. We do not offer credit ourselves,
we act as a credit broker.
We also work with our sister company, TotallyMoney Limited, to provide you with access to other offers should you be unsuccessful in obtaining the Fluid product that you apply for.
3. About this policy
This policy explains:
- What personal information we collect from you
- How we use your information
- How we store your information
- Who we may disclose your information to
- If you are applying for the Fluid Credit Card, an outline of how NewDay Limited and companies in the same group (NewDay) will use your information (see also the NewDay Privacy Notice).
- Your rights regarding your personal information
We may revise this policy at any time by posting an update on the Site. Your continued use of the Site after any such change will indicate to us that you accept the new policy and the changes will be binding on you. You should therefore check the Site from time to time to review the current version of the policy.
4. The information we collect about you
We may process the following data about you:
- Information that you submit through the Site – for example if you complete a form to check your eligibility for the Fluid credit card. 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 the Site.
- If you contact us, we will keep a record of that correspondence.
- 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.
- We may, to the extent it is necessary, be provided with details of transactions you carry out through or as a result of using the Site. For example a credit card company may inform us that you made a successful application for a credit card, for the purposes of calculating commissions due to us, but they would not tell us your credit limit for example.
- 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.
- 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.
- Information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. See section 12.
5. How we use your information
We use the information held about you in the following ways:
- To provide you with information, products or services that you request from us, including to process a request for a quotation or application for a product or service you make through our Site.
- To carry out, or to enable a Product Provider to carry out, a soft search against your credit file in order to provide you with your likelihood of being accepted for a Fluid credit card before you make an application.
- To introduce you to Product Providers that you have elected to be introduced to, and to carry out our obligations arising from any contracts entered into between you and Product Providers via the Site.
- Where you have elected to receive marketing (either from us, or from our sister company TotallyMoney Limited), we will process your data in order to provide you with such marketing. You may opt out of such marketing at any time by clicking on the unsubscribe link in any email we send to you, or by contacting us here.
- 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.
- To ensure that content from our Site is presented in the most effective manner for you and for your computer.
- To personalise (where possible) 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.
- To look up and validate the postcode that you provide in any personal details submitted.
- To validate the email address you provide as being an active and accurately entered email address.
- To meet legal or regulatory requirements.
- To enter into correspondence with you.
- For the purposes of website (and where applicable app) analytics.
- 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.
6. How and where we store your personal data
- All of the information that you give us is stored on secure servers. We will periodically review this information to ensure that we do not keep it for any longer than is necessary.
- 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 encryption technology to ensure that all your personal and transactional information is encrypted before transmission to certain Product Providers. Our security policies are in place to safeguard your privacy from unauthorised access or improper use – and we will continue to enhance our security as and when new technology becomes available.
The data that we collect from you may be transferred to, and stored
at, a destination outside the European Economic Area (EEA) as follows:
- NewDay may make transfers as set out in the NewDay Privacy Notice;
- Where we send you marketing, we may use an email service provider located in the US that provides adequate protection for your data by being part of the Privacy Shield framework;
- The support services for some of our technology providers may be located outside of the EEA and to the extent that they process your data, we will ensure adequacy through the Privacy Shield framework (for US services) or other recognised protective arrangements;
- We do not retain your data for longer than is necessary.
7. Where we disclose your information to third parties
When you submit your data onto our Site, you consent to our use of your personal data in the following ways:
- If you check your eligibility, or wish to apply for a Fluid credit card, we need to disclose the information you entered into the site to NewDay Limited (NewDay), which is the Product Provider that provides the Fluid credit card product you have applied for. This information is necessary to check your eligibility for a product or to process your application. NewDay will perform a search with a credit reference agency using the personal information we provide to them. Further information about how NewDay will use your personal details is set out in section 10 below. This disclosure is necessary for the purposes of providing you with the eligibility check for a Fluid credit card, and potentially the ability to apply for the Fluid credit card.
- Where you have elected to receive marketing from our sister company, TotallyMoney Limited as part of your submission of personal data to the Site, we will share your data with TotallyMoney Limited for that purpose.
- 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 and conditions 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.
- 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.
- 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.
Where you have elected to receive email marketing from our sister company, TotallyMoney Limited as part of your submission of personal data to the Site, we will share your data with TotallyMoney Limited. They may use your personal information to send you information about promotions, Products and services that may be of interest to you by email, and to tailor the marketing messages you receive. You may unsubscribe from receiving marketing communications from TotallyMoney Limited at any time by emailing email@example.com or by clicking the unsubscribe link in any marketing email you receive from them.
9. Communications with you
If you contact us, we may keep a record of that correspondence. For research purposes, from time to time, we may ask you to complete a survey, although you do not have to respond. We may send you service messages in relation to your use of the Site where we need to make you aware of changes for example.
10. Credit Card Applications
THIS SECTION IS ONLY RELEVANT TO YOU IF YOU WISH TO CHECK YOUR
ELIGIBILITY FOR OR TO APPLY FOR A FLUID CREDIT CARD
If you wish to check your eligibility for, or 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 NewDay, the Product Provider.
Please read NewDay’s Privacy Notice carefully before proceeding, as it will apply to their handling of your data once they receive it from us.
Using your personal information, NewDay 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. NewDay will inform you of the result. If NewDay 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 using NewDay’s application form or to terminate your application at that point. If NewDay determines that you are not eligible for the Fluid Credit Card, you will then be given the option to proceed to see alternative possible credit products using the TotallyMoney service, which is operated by our sister company TotallyMoney Limited.
PLEASE NOTE THAT:
Your credit file will not be provided to you directly.
The eligibility check process will not have any adverse impact upon your credit standing.
Even if NewDay indicates that you are likely to be accepted for a Fluid Credit Card, this is no guarantee that you will be accepted for the card.
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 the Fluid card issuer for a Fluid credit card, then the Fluid card issuer will proceed to carry out its own identification and credit application checks in accordance with its own criteria and in accordance with the joint set of terms agreed between the UK credit reference agencies, which will apply to your data when a full credit check is carried out on you. You can read the terms here.
11. Your rights
You have a right to:
Access to your personal information (this may be subject to an administration fee of £10).
Rectify your personal information if it is inaccurate or incomplete.
Obtain erasure of your personal information where there is no compelling reason for its continued processing in certain circumstances.
Obtain restriction of processing of your personal information in certain circumstances.
Object to processing of your personal information in certain circumstances.
Receive your personal information data provided to us as a controller in a structured, commonly used and machine-readable format where our processing of the data is based on consent or necessity for performance of a contract to which you are a party or to take steps at your request prior to entering into such a contract and the processing is carried out by automated means.
Lodge a complaint with a supervisory authority.
Object to and not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects you.
To exercise the rights outlined above in respect of the personal information processed by us as a controller, contact us at firstname.lastname@example.org.
We may obtain information about your general internet usage by using a cookie file which is stored on your browser – or the hard drive of your computer. Please also see our Cookies Notice for more information. Cookies contain information that is transferred to your hard drive. Some of these cookies are essential for the Site to operate. They help us to:
Improve our site and deliver a better and more personalised service;
Estimate audience size and usage pattern;
Store information about your preferences;
Observe your browsing history;
Recognise you when you return to the Site.
widely used in order to make websites work, or run more efficiently,
as well as to provide information to the owners of the Site.