Privacy Policy

1. Introduction

Fluid Finance Ltd ("we", "us", "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Data Controller: Fluid Finance Ltd
Contact: contact@fluidfinance.uk

2. Information We Collect

2.1 Personal Information

When you invest with Fluid Finance or express interest in our services, we may collect:

• Full name and contact details (email, phone, address)
• Date of birth and nationality
• Tax identification numbers and residency information
• Bank account details for transfers and withdrawals
• Employment and income information
• Investment experience and risk tolerance assessments
• Source of funds and wealth verification documentation
• Identity verification documents (passport, driving license, utility bills)

2.2 Financial Information

• Investment amounts and portfolio allocations
• Transaction history and performance data
• Account balances and profit/loss information
• Withdrawal and redemption requests

2.3 Technical Information

• IP addresses and browser information
• Dashboard login activity and access logs
• Device information and operating system
• Website usage data and analytics

3. How We Use Your Information

We process your personal data for the following purposes:

3.1 Service Provision

• Processing investment subscriptions and redemptions
• Managing your investor account and providing dashboard access
• Executing trades and managing portfolio allocations
• Processing withdrawals and transfers
• Providing performance reports and account statements

3.2 Regulatory Compliance

• Complying with Anti-Money Laundering (AML) regulations
• Conducting Know Your Customer (KYC) verification
• Meeting FCA regulatory requirements
• Tax reporting and compliance obligations
• Responding to regulatory inquiries and audits

3.3 Communication

• Sending monthly performance reports
• Providing fund updates and announcements
• Responding to investor inquiries
• Sending important operational notices

3.4 Legal Basis for Processing

We process your personal data based on:

• Contractual necessity: To fulfill our obligations under the subscription agreement
• Legal obligation: To comply with AML, KYC, tax, and regulatory requirements
• Legitimate interests: To improve our services and communicate fund updates
• Consent: For marketing communications (where applicable)

4. Data Sharing and Disclosure

We may share your personal data with:

4.1 Service Providers

• Broker-dealers and custodians (for trade execution and custody)
• Fund administrators and accountants
• Technology service providers (dashboard, reporting systems)
• Legal and compliance advisors
• Identity verification services

4.2 Regulatory Authorities

We may be required to disclose your information to the Financial Conduct Authority (FCA), HM Revenue & Customs (HMRC), and other regulatory bodies as required by law.

4.3 Third-Party Safeguards

All third parties we work with are required to maintain appropriate security measures and process your data only as instructed and in compliance with applicable data protection laws.

5. Data Security

We implement industry-standard security measures including:

• Encryption of data in transit and at rest
• Secure access controls and authentication protocols
• Regular security audits and vulnerability assessments
• Staff training on data protection and security
• Incident response procedures for data breaches

While we employ robust security measures, no system is completely secure. We cannot guarantee absolute security but commit to maintaining industry best practices.

6. Data Retention

We retain your personal data for as long as necessary to:

• Maintain your investor account while you remain a client
• Comply with regulatory retention requirements (typically 7 years after account closure)
• Resolve disputes and enforce our agreements
• Meet tax and audit obligations

7. Your Rights

Under UK GDPR, you have the following rights:

• Right of access: Request a copy of your personal data
• Right to rectification: Correct inaccurate or incomplete data
• Right to erasure: Request deletion of your data (subject to legal obligations)
• Right to restrict processing: Limit how we use your data
• Right to data portability: Receive your data in a structured format
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: For consent-based processing

To exercise these rights, contact us at contact@fluidfinance.uk. We will respond within one month.

8. Cookies and Tracking

Our website uses essential cookies for functionality and analytics cookies to improve user experience. You can manage cookie preferences through your browser settings. The investor dashboard requires functional cookies to operate.

9. International Data Transfers

Your data is primarily stored and processed within the United Kingdom. If we transfer data internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the UK Information Commissioner's Office.

10. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via email to active investors. The "Last Updated" date at the bottom of this page indicates when changes were last made.

11. Complaints

If you have concerns about how we handle your personal data, please contact us first at contact@fluidfinance.uk. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

12. Contact Information

Last updated: December 2024