WHO ARE WE?
We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in this area may change from time to time. We will post the current version of this policy at: www.myfluenthome.com
WHAT IS PERSONAL INFORMATION?
If the policies and procedures outlined in this document do not address a specific situation, individuals are advised to contact the Company’s Privacy Officer for guidance or clarification.
WHAT PERSONAL INFORMATION DO WE COLLECT?
The Company collects and uses only the personal information that we need for providing services and operating our business. Generally, the Company collects the following personal information from individuals for the various purposes set out below:
- email address
- video and audio collected, accessed or streamed via services offered by the Company
- payment history
- financial information
- credit card number
- bank information
- position data, location information accessed or collected through GPS services offered by the Company.
WHY DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?
In serving your needs, it is important to have accurate information about you. We collect your personal information to:
- Establish your identity
- Understand your needs for, and determine your suitability for, products and services
- Provide services to you and process payments for your account
- Provide the video surveillance services offered by the Company
- Provide the GPS services offered by the Company
- Process credit applications
- Manage the Company’s business and operations, including customer relationships and matters
- Meet legal and regulatory requirements
- Better understand an individual’s interests in our products and services
- Deliver, develop, enhance or improve products and services
- Provide warranties for products and services
- Enforce our legal relationship with you
- As is necessary in contemplation of a business transaction, and
- Protect you and us from error and fraud, including verifying your identity to: •Establish your alarm account profile
- Validate an alarm
- Service your security system
- Respond to your requests
- Communicate with you concerning your account
- Notify you of Company and third party new products and services, special offers, Company events and general industry information
- Adhere to applicable legal requirements
We normally collect information directly from our clients. We may collect your information from other persons with your consent or as authorized by law. Before or at the time of collecting personal information, we identify the purposes for which we are collecting the information. We do not provide this notification when personal information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new purpose not included in this policy, we will notify you and seek your consent, unless such disclosure is allowed without consent under the law.
Each time you visit our web pages, such as www.myfluenthome.com, we gather the date, time, browser type, name of the visitor’s Internet service provider, the site that referred the visitor to us, any pages that are requested, the navigation history and IP address of the visitor. The foregoing information does not generally contain anything that can identify users personally. If you object to this gathering of information, you should not use or access our web pages. We use this information for our internal security audit log, trend analysis and system administration, and to gather broad demographic information about our user base for aggregate use. This information may be shared with third parties in order to provide services to us or to analyze, store or aggregate the information.
To the extent that our web sites contain links to other sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party websites.
Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.
You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
The purpose for collecting personal information is set out in this policy. Any necessary consent shall be obtained before personal information is collected, used or disclosed.
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button).
In cases that do not involve sensitive personal information, we may rely on “opt-out” consent.
The amount and type of personal information collected by the Company shall be limited to what is necessary to fulfill the identified purpose. Personal information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by law.
Personal information collected by the Company or on behalf of the Company will be sent to the Company’s head office in Edmonton and will be subject to the laws of Canada. We also send and store personal information in our offices in the United States. Where personal information is stored or processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts or law enforcement or regulatory agencies.
WHAT DO WE DO WITH YOUR INFORMATION?
Your information will only be used by the Company for the purposes outlined above under “Why Do We Collect Personal Information from You?”. We will not disclose your personal information to any third party, except as set out below.Third Party Services
Our service providers/subsidiaries in Canada and the United States collect, use or disclose your personal information for the following purposes:
- data storage services
- marketing services including the notification of new products and services special offers, some customer support services
- alarm monitoring and notification services to us to support our customer base.
Whenever we engage a third party service provider to do work for us, we confirm that its privacy and security standards meet our requirements.Transactions
We may be involved, from time to time, in transactions to sell parts of our business or assets or merge with other businesses. Since our customer information may be part of such transactions, we may use or disclose this information to other parties involved in the transaction. In such cases, the information that is shared is limited to what is necessary to accomplish the transaction, and we take appropriate steps to protect the information from improper use or disclosure, in accordance with the requirements of PIPEDA, PIPA, and PIPA BC.Legal Requirements
There are exceptions where we may collect, use or disclose personal information without consent when required or permitted by law. From time to time, we may be compelled by legal action to release information (e.g., statutory reporting obligation, search warrant, court order, bankruptcy or insolvency proceedings etc.). In certain circumstances, we may also be permitted by law to collect, use or disclose information without the consent of the individual concerned. For example, we may disclose personal information without consent if it is to be used in an emergency that threatens the life, health or security of the individual, or when collecting unpaid amounts owed or owing to us, to other businesses in order to investigate a breach of an agreement or a contravention (or anticipated contravention) of a federal or provincial law where it is reasonable to expect that obtaining the consent from the individual for the disclosure would compromise the investigation. For the purposes of detecting or suppressing fraud we may also disclose personal information without consent to a government institution or to the individual’s next of kin or authorized representative if there are reasonable grounds to believe that the individual has been the victim of “financial abuse,” and where it is reasonable to expect that obtaining the consent from the individual for the disclosure would compromise the ability to prevent or investigate the abuse. We may also make limited disclosure of personal information to an organization or government institution without the individual’s consent in order to reduce the risk or mitigate the harm resulting from a breach.
HOW DO I OBTAIN ACCCESS TO MY PERSONAL INFORMATION?
Upon request received by the Company in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information. Requests to access personal information held by the Company should be directed to the Company’s Privacy Officer.
Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any such documentation provided shall be used for verification purposes only.
A fee for reasonable costs incurred may be charged when responding to more complex requests. The individual will be informed of the applicable fee.
The Company will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information, the Company will provide a list of organizations to which it is likely to have disclosed information.
Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from the Company, individuals wishing to view an original record will do so at the Company’s head office and under the supervision of designated the Company personnel.
LIMITATION TO ACCESS
The Company will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation.
In the event that the Company refuses to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. The Company will respond to your requests for access in accordance with applicable privacy legislation.
MAINTENANCE OF PERSONAL INFORMATION
Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.
Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by the Company and have it amended as appropriate.
Individuals seeking a correction or amendment to their personal information should direct their requests in writing to the Company’s Privacy Officer.
If the individual is not satisfied with the results of the request, the Company shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.
SECURITY OF PERSONAL INFORMATION
Personal information will be retained only as long as necessary and will be disposed of in a manner that is appropriate to the sensitivity of the information. We render client personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.
Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information.
We will notify the Office of the Information and Privacy Commissioner of Alberta, the Federal Privacy Commissioner and any other privacy commissioners as required by law, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals. We will provide you with suggested steps that you may take to protect yourself in such a situation.
If you are not satisfied with the response from our Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.
QUESTIONS AND COMPLAINTS
If you have a question or concern about any collection, use or disclosure of personal information by the Company, or would like to request access to your own personal information, please contact: email@example.comRevised October 2015
United States Policy
We utilize cookies and third-party software services on our website in order to analyze usage which gives us valuable insight pertaining to the content of our website—what we should remove and what we should keep; what is engaging; what helps our site visitors; and, how Fluent can improve performance. Certain pages may ask for personal information which identifies you to our company. This information is entirely “opt in” only. You are not required to offer this information. The information you do choose to submit to us is guarded and protected with our banking-level encryption algorithms to ensure its protection. Your information is not sold or given to unrelated third parties which are not related to the security industry or the support thereof.
OVERVIEW | THE INFORMATION COLLECTED BY FLUENT
Fluent collects a variety of information from you. Information is collected when you complete one of our forms, when you subscribe to our newsletters, when you participate in our surveys, when you register on our website, or when you engage in any other voluntary communication between yourself and fluent, etc.
There will be occasions on which you will provide information on our website including but not limited to your name, telephone number, email address, mailing address, credit card information, IP address, content you post and submit in your resume or CV, etc. By way of example, this information might be provided when you are ordering materials or when you are registering on our website. Disclosing this information is not required to visit our website. You may visit our website, speak on the phone, and meet with our representatives, anonymously. All information we may collect is given on a voluntary basis by you. There are two types of information collected on this site: anonymous information and personally identifiable information (“PII”). Other information may be collected over the phone, in meetings, or by other methods.
Anonymous Information. We collect certain anonymous data regarding the usage of the website. This information does not personally identify you. We gather it to improve the performance of the Site. The anonymous data we collect may include information such as the type of browser you are using, IP address, the pages you view, and the length of your visit to the Site. This information may be attached to internal profiles. Should you offer your personally identifiable information voluntarily, we may attach your anonymous information to your profile.
Personally Identifiable Information. We may ask you to provide personally identifiable information, which may include your name, address, telephone number, fax number, company name, and e-mail address. We may also ask you for relevant details about the product or service that interests you, that you currently have installed, that you may want to have installed at a future date, and other information Fluent deems applicable to the proper care and handling of your account. These details may include whether the location is a business or residence, whether the site is pre-wired for security, and the square footage. This information can be gathered when you send us an e-mail or when you complete the specific web page request form. We also may collect personally identifiable information from you when you provide it to us during telephone calls, face to face meetings, or during the initiation of agreements with paperwork. In all such cases you choose whether to provide us with the personally identifiable information, but certain portions of the Site may not be available to you or we may not be able to respond to your inquiry effectively if you do not provide the PII requested.
My Account. In order to access some of the services on our Site, you are asked to provide additional personal information regarding your customer account with Fluent. This additional information may include existing account numbers, payment or credit card details, service preferences and so forth. We will use this information only to support your customer relationship with Fluent. This includes responding to your requests, customizing your experience on the Site, communicating with you about your account, and providing your choices about how to view and manage the products and services that you receive from Fluent.
WHAT IF ANYTHING IS YOUR INFORMATION USED FOR?
There are certain purposes for which we may use the information we collect from you:
First, we may use the information in a manner that will allow us to improve your experience using our website as well as our products and services. The information you provide will assist our company in being more responsive to your needs.
Second, we will use your information in an attempt to enhance the quality of our website and the service we render to you. It is our goal to regularly maintain and develop our website based in part on the information that is provided by you and our other loyal customers.
Third, we will use this information to enhance the quality of our customer service. Your information assists our organization with providing better and more comprehensive responses to our customer service requests.
Fourth, we will use this information to assist in the processing of transactions.
WHAT YOUR INFORMATION WILL NOT BE USED FOR
There are certain things your personal information will absolutely not be used for. Your personal information absolutely will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
Your personal information may be used for the purpose of contest administration, promotions, surveys or other site features.
Your personal information may be used for the purpose of sending periodic emails. The email address you provide for order processing will be used exclusively for the purpose of sending you information and updates pertaining to your Account. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the conclusion of each email.
HOW DO WE PROTECT YOUR INFORMATION?
As an organization, we have implemented numerous security measures to safeguard your personal information against accidental or unlawful loss, alteration, unlawful disclosure, access or other forms of unlawful processing at all times, including when you enter, submit, or access your personal information.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible exclusively by those individuals who have been entrusted with special access rights to such systems who are required to maintain the confidentiality of the information.
Once a transaction is completed, your private information (credit cards, social security numbers, financials, etc.) will not be maintained for more than 60 days.
You are responsible for the privacy and confidentiality of your username and password. Should unauthorized use of either username or password occur, you are obliged to contact Fluent immediately.
The transmission of data over the internet, by its very nature, requires the use of systems and services under the immediate control of third parties. As a result, Fluent actively works to prevent any violation of the security protocols it has in place, but cannot ensure the complete security of such systems.
Use of Web Beacons. Web beacons are tiny graphics embedded on a website that allow the website to transfer or collect information through a graphic image request. These web beacons allow us or third parties retained by us to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. We may use web beacons to collect information about your web browsing activities to help us determine if a particular webpage on the Site has been visited, and, if so, how many times. This information permits us or third-party software we utilize to measure the overall effectiveness of our online content, and to customize the services offered to our site’s users.
We use log files to store the data that is collected through web beacons. Fluent also uses third-party web beacons to help manage our internal advertising. These web beacons are provided by our ad management partners, namely, Google Analytics. These files enable Google Analytics to recognize a unique cookie on your web browser, which in turn enables us to learn which advertisements bring users to our web site. For more information about Google Analytics, including information about how to opt out of these technologies, go to www.google-analytics.com.
HOW DO WE TREAT “DO NOT TRACK” SIGNALS?
Certain web browsers contain a privacy feature that you can enable that will inform web sites you visit that you do not want to be tracked for purposes like behavioral advertising. It is important to note that this “Do Not Track” (or “DNT”) feature does not prevent or prohibit web sites from tracking you. Instead, the “Do Not Track” technology only requests that a web application disable its tracking or cross-site user tracking of your web browsing activities. Fluent itself does not track users for purposes that would be relevant to a DNT opt-out signal or request.
However, Fluent does use third-party ad management and analytics companies such as Google Analytics and HubSpot. Fluent does not and cannot control the tracking and privacy practices of such third parties. For information about their privacy practices and handling of DNT signals, please visit their web sites at www.google.com/analytics/ and www.hubspot.com
DO WE DISCLOSE ANY INFORMATION TO OUTSIDE PARTIES?
We provide you with our assurance that we will not sell, trade, or otherwise transfer your personally identifiable information to outside parties. However, please be advised that this does not include those trusted third parties who assist our organization with the operation of our website, conducting our business, or providing service to you, provided that these trusted third parties agree to keep this information confidential. We may also release your information when we believe in good faith that the release of this information is necessary and appropriate to comply with the law, to enforce our website policies, or to protect our own rights or the rights of others, or the property or safety of ourselves or others. Additionally, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
As we develop and expand our business, we may transfer any information we have about you in connection with a possible merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Fluent or as part of a corporate reorganization or stock sale or other change in corporate control.
As noted above, we have relationships with third-party services and software to perform tracking and other similar functions for the Site and our advertisements, and to assist us in providing you with customer services. These third parties may collect information about those who use our Site. Fluent reserves the right to include and offer, at our exclusive discretion, third-party products or services on our website. Please be advised that these third-party sites have their own separate and independent privacy policies. As such, we have no responsibility or liability for the content and activities of these third parties or their sites. However, we do seek to protect the integrity of our website and welcome any feedback about these third-party websites.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE
Fluent seeks to be in compliance with the pertinent privacy laws and regulations including but not limited to the California Online Privacy Protection Act. In compliance with these laws and regulations, we will not distribute your personal information to outside parties without your consent.
Consistent with the California Online Privacy Protection Act, all users of our website may make any changes to their personal information at any time by logging into their control panel and going to the ‘Edit Profile’ page.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
We understand, and respect the importance of protecting children’s privacy. Fluent is strictly committed to adhering to and remaining in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). Fluents site, covered by this policy, is not designed for or intentionally targeted at children 13 years of age or younger. As an organization, we do not intentionally collect or maintain any information from anyone under the age of thirteen as required under COPPA, and, in fact, we do not intentionally collect or maintain information from anyone under the age of eighteen. Our website, products and services are all directed to individuals who are a minimum of eighteen years of age or older.
1400 Columbia ST
Vancouver, WA 98660
For further information about the Terms and Conditions regarding the use, disclaimers, and limitations of liability governing the use of our website, please find further information at www.myfluenthome.com/terms.