For more information about how we handle information that is subject to the EU General Data Protection Regulation when we are the controller of that information, please contact us.
You may be able to deal with us without identifying yourself (i.e. anonymously or by using an alias) in certain circumstances, such as when you use our website.
You do not have to provide us with your personal information but if you do not provide us with the personal information that we need, we may not be able to provide our services or assistance to you or our clients on your behalf.
Why does Fluent Group collect and use personal information?
Fluent Group only collects, holds and uses personal information for the purposes for which it was provided to us, related purposes or as permitted or required by law. Such purposes may include:
- providing you and/or our client with the services requested (generally consulting and/or software services) and communicating about the same including in relation to billing
- improving and marketing our services including developing our knowledge management resources, maintaining a database of clients and matters that record Fluent Group’s experience globally, and supporting internal management reporting
- responding to your and/or our clients’ enquiries or providing you with assistance you have requested
- processing application forms you have completed on various sections of the Fluent Group website
- providing you with publications and event invitations based on the areas of interest and mailing lists that you subscribe to
- quality assurance, IT security and operations, and training purposes
- managing relationships with vendors/contractors/third parties
- personnel management including recruitment of personnel, and/or
- complying with our legal and professional obligations including checking for conflicts of interest and other client take on procedures.
In certain circumstances we may be required or permitted by law or Court or Tribunal order to collect certain personal information about you. For example, we may need to collect your name, residential address, date of birth, business name (if any), directorship appointments (if any) and to comply with Anti-Money Laundering and Counter Terrorism and Anti-Bribery and Corruption legislation (eg in Australia the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth)) or professional conduct and practice rules or legislation in the jurisdictions in which we operate.
What personal information does Fluent Group collect?
Fluent Group generally collects personal information such as:
- your name
- your contact details (eg address, email address, phone number)
- details about your occupation
- details about your professional memberships
- details about your interests in areas of technology or events
- information about your dealings with us or with our clients, and/or
- information relevant to our work for you or our clients.
How does Fluent Group collect personal information?
Fluent Group may collect your personal information in various ways, including via telephone, our website, email or hardcopy and/or online forms. In most situations we collect your personal information directly from you. However, we may also collect information from third parties, such as:
- your insurer
- a company in which you are a shareholder or officeholder
- your employer
- anyone seeking our services in relation to their dealings with you.
Who does Fluent Group disclose personal information to?
Fluent Group is a global professional services firm operating through a number of separately constituted and regulated legal entities which provide consulting, creative, software development and other client services in accordance with the relevant laws of the jurisdictions in which they respectively operate and Fluent Group may share your personal information with one or more of them. Details of the different Fluent Group entities that provide consulting, creative, software development and other client services to clients in respect of each country in which Fluent Group carries on business is available on request.
Your personal information may also be confidentially disclosed to other entities. Such entities generally include:
- our third party service providers for the purpose of enabling them to provide, manage or administer a service offered through Fluent Group (such as our IT service providers, organisations providing secure storage and archiving services, and insurers)
- your representatives if you have provided consent for such disclosure
- government bodies, regulators, law enforcement agencies and any other parties where authorised or required by law
- any other entities identified at the time of collecting your personal information or to which we are legally required to disclose your personal information.
How does Fluent Group protect personal information?
We take reasonable steps to protect any personal information that we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure. For example, we implement the following security measures:
- security procedures for access to our business premises
- security procedures within our offices
- IT security procedures including password protection, firewalls, intrusion detection and site monitoring; and
- mandatory confidentiality guidelines for all staff within the business.
However, data protection measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your personal information. You must take care to protect your personal information (for example, by protecting any usernames and passwords). You should notify us as soon as possible if you become aware of any security breaches.
Accessing your personal information held by Fluent Group
You may access personal information we hold about you, subject to a small number of legal restrictions or exemptions. Where such restrictions or exemptions exist we will advise you of those reasons at the time of your request.
If you wish to access the personal information we hold about you or request correction of it, you should contact the member of our staff responsible for your engagement(s) or our privacy officer (using the contact details below).
While we do not charge you for a request for accessing your personal information you should be aware that we do charge a reasonable fee (which will be notified to you once you make a request) for time and cost in the following circumstances:
- if an extended amount of time is required to collate and prepare material for you, and
- if you wish to have your files photocopied for you.
How can you correct and update your information?
We take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up-to-date. However, we also rely on you to advise us of any changes to your personal information. Please contact us using the contact details below as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete or up-to-date so that we can update our records accordingly.
What do you need to do if you have a complaint?
Our privacy officer will investigate the issue and determine the steps (if any) that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns. If your complaint relates to Fluent Partners Pty Ltd T/A Fluent Group, you can complain to the Australian Privacy Commissioner via www.oaic.gov.au.
GPO Box 3645
Sydney, NSW, Australia 2001
Email: [email protected]