Fluid Branding Privacy & Cookies Policy

1. Introduction

1.1 - We are committed to safeguarding the privacy of our website visitors and service users.
1.2 - StoneX is powered and operated by Fluid Branding.
1.3 - This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data. 'Personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.4 - By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.5 - In this policy, "we", "us" and "our" refer to Fluid Branding. For more information about us, see Section 11.

2. How We Use Your Personal Data

2.1 - In this Section 2 we have set out:

2.1.1 - The general categories of personal data that we may process;
2.1.2 - In the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
2.1.3 - The purposes for which we may process personal data; and
2.1.4 - The legal bases of the processing.

2.2 - Usage Data

We may process data about your use of our website and services ("Usage Data"). This data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of this data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 - Service Data

We may process your personal data that is provided in the course of the use of our services ("Service Data"). This data may include your name, email address, telephone number, physical address, company details, and information regarding your requirements for us to complete services offered to you. The source of this data is you or your employer. This data may be processed for the purposes of offering and selling relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4 - Transactional Data

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("Transaction Data"). For offline payment processing this data may include your contact details, your card details and the transaction details. Data relating to online payment cards is not stored by Fluid Branding and is handled entirely by our online payment processor, Stripe.com. The source of this data is you or your employer. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business.

2.5 - Marketing Data

We may process personal data to market our products and/or services to users of our website and services ("Marketing Data"). This data may include name, company name, email address, and information regarding your contact preferences. The source of this data is you or your employer. This data may be processed to send you email communications intended to offer you services and/or products that we think may be of interest to you. The legal basis for this processing is our legitimate interests (when the data subject represents a Limited Company or Corporation) and consent (when the data subject represents an Individual, Sole Trader or Partnership).

2.6 - Personalisation Data

We may process personal data to build profiles on users of our website and services ("Profile Data"). This data may include company type, job title, department, industry sector, age, gender, information on the use of our website, and general interests. The source of this data is you or your employer. This data may be processed to give us a wider understanding of how our website and services are used, as well as allowing us to improve and/or personalise your experience through the website. The legal basis for this processing is our legitimate interests, namely improving our website and services and business growth.

2.7 - Correspondence Data

We may process information contained in or relating to any communication that you send to us ("Correspondence Data"). This data may include the communication content and metadata associated with the communication. The source of this data is any communication you send to us, through email, via telephone or through forms on our website (through which the metadata is generated). This data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.8 - Publication Data

We may process information that you post for publication on our website or through our services ("Publication Data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The source of this data is any information you submit regarding our products and/or services, either via email or through channels such as review collection services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and growing our business through the publication of verified customer reviews.

2.9

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.11

In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3. Providing Your Personal Data To Others

3.1

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.

3.3

We may disclose service to our suppliers insofar as reasonably necessary for the fulfilment of orders through our services.

3.4

Online Financial Transactions are processed by our payment provider Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. Fluid Branding does not store card details for any transactions relating to online payments processed by Stripe. Fluid Branding has a Data Processing Agreement set up with Stripe in order to ensure data protection and compliance with privacy laws. Stripe's Privacy Policy and Terms & Conditions can be found at https://stripe.com/gb/privacy.

3.5

In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. International Transfers of Your Personal Data

4.1

In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2

We use third party facilities (such as our website hosting, marketing database, and online chat software) in the United States of America. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. Further details on these safeguarding measures can be obtained by emailing [email protected].

4.3

We use third party facilities (such as our supplementary graphics studio service, Doodle) in India. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. Further details on these safeguarding measures can be obtained by emailing [email protected].

4.4

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining And Deleting Your Personal Data

5.1

This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or purposes.

5.3 We will retain your personal data as follows:

5.3.1 - Personal Data will be retained by Fluid Branding for as long as there is a legitimate business need for retention, unless otherwise stated in this clause. This may include the need for uses such as record keeping, analysis and reporting.
5.3.2 - Google Analytics Data will be retained for a maximum period of 50 months following the user's last session on our website, as per our Data Retention Policy.
5.3.3 - A copy of our Data Retention Policy is available upon request, and can be obtained by [email protected].

5.4

As stated in section 7.5, you have the right to request removal of your personal data from our systems. See section 7.5 of this policy for further details on the right to erasure.

5.5

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Ammendments To This Policy

6.1

In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.2

We may notify you of changes to this policy by email.

7. Your Rights

7.1 7.2 Your principal rights under data protection law are:

7.2.1 - The right to access;
7.2.2 - The right to rectification;
7.2.3 - The right to erasure;
7.2.4 - The right to restrict processing;
7.2.5 - The right to object to processing;
7.2.6 - The right to data portability;
7.2.7 - The right to complain to a supervisory authority; and
7.2.8 - The right to withdraw consent.

7.3

You have the right to request access to your personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.5.1 - It may take up to 28 days for any such request for erasure to take effect in our systems.

7.6

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9

To the extent that the legal basis for our processing of your personal data is:
7.9.1 - consent; or
7.9.2 - That the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable

7.10

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In the UK this will be the Information Commissioner's Office (ICO).

7.11

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.12

You may exercise any of your rights in relation to your personal data in writing to us at our registered office address.

8. About Cookies

8.1

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies Used On Our Website

9.1

We and our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.2

The following is a list of cookies that are set on our website whilst browsing, along with information of the third party that sets them (if applicable), and an explanation of their purpose:

Organisation	Cookie Set	Purpose / Explanation
Fluid Branding	ci_session, PHPSESSID, cookieacceptance	These cookies deal with site functionality, and are required for our website to function correctly.
Google Tag Manager	_dc_gtm_UA-#######-#	Google Tag Manager allows website owners to enable third party scripts on their site - we use Google Tag Manager to enable certain website features offered by third parties and analytics
Google Analytics	_ga, _gali, _gat_UA-#######-#, _gid	Google Analytics uses cookies to determine which domain to measure, recognise unique users and track pages they visit as well as other behavioural information.

10. Managing Cookies

10.1

Most browsers allow you to refuse to accept cookies and to delete cookies. You can however obtain up-to-date information about blocking and deleting cookies via these links: 10.1.1 - Google Chrome: https://support.google.com/chrome/answer/95647?hl=en;
10.1.2 - Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
10.1.3 - Opera: http://www.opera.com/help/tutorials/security/cookies/;
10.1.4 - Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
10.1.5 - Safari: https://support.apple.com/kb/PH21411; and
10.1.6 - Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

10.2

Blocking all cookies will have a negative impact upon the usability of many websites, including this one. If you block cookies, you will not be able to use all the features on our website.

11. Our Company Details

11.1

Our website is owned and operated by Fluid Branding Ltd.

11.2

We are registered in England and Wales under registration number 05867605, and our registered office is at ESAM Building, Carluddon Technology Park, Carluddon, St Austell, Cornwall, PL26 8WE.

11.3

You can contact us:
11.3.1 - by post, to the postal address given above;
11.3.2 - using our website contact form;
11.3.3 - by telephone, on the contact number published on our website; or
11.3.4 - by email, using [email protected].

12. Data Protection Contact Details

12.1

Fluid Branding is not required by law to appoint a Data Protection Officer, however any enquiries relating to privacy and data laws can be directed to [email protected].