Privacy Policy

At Fluid Finance one of our main priorities is the privacy of our users. This Privacy Policy document contains types of information that is collected and recorded by the company and how we use it.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

This Privacy policy aims to protect the privacy and the fundamental rights of the users when their Personal data are processed by the Company, such as the fundamental rights of the users while they are browsing the Website.

We store your Personal data in a secured manner and process your Personal data with all appropriate care and attention in accordance with the Federal Data Protection Act (RS 235.1), the Ordinance on the Federal Data Protection Act (RS 235.11), the European General Data Protection Regulation (EU 2016/679) and the Nigerian Data Protection Regulation, 2019.

Our platform may be used to obtain "Evolve Services" as described in the Fluid Finance App Terms of Use. The collection, use, and disclosure of your personal information related to Evolve Services is governed by Evolve Bank & Trust's ("Evolve") privacy policy available at https://www.getevolved.com/privacy-policy/, as modified or supplemented from time to time. By accessing Evolve Services through us, you agree that we may share your information with Evolve and Evolve may share your information with us. This includes your personal identification information, account balances, transaction data, and other information needed to provide Evolve Services. To the extent we are permitted to use that information in connection with "Non-Evolve Services" as described in the Fluid Finance App Terms of Use, we will do so in accordance with this Privacy Policy. In all other instances, Evolve's privacy policy shall control over this Privacy Policy, but only with respect to information collected, obtained, or created in connection with the Evolve Services.

Consent

By using our website or our services, you hereby consent to our Privacy Policy and agree to its terms. In particular, the Consent for the Processing of Personal data is given once the Visitor ticks the box in the pop-up window which says "I have read the Privacy Policy and agree to be bound by it".

If you do not agree with the terms of this privacy policy, please do not visit and use the Website.

Ethics of society and users' rights

a) Legality We guarantee that we process the data in compliance with the applicable laws (Federal Data Protection Act, Ordinance on the Federal Data Protection Act, GDPR, NDPR) and with respect for the personality and right to privacy of our users.

b) Good faith and proportionality We guarantee compliance with the principles of good faith and proportionality, i.e. we do not collect or process any data without the knowledge or against the will of the concerned person, and only collect and process the data necessary to provide our products or services.

c) Purpose hereby, by law or in the circumstances We collect and process user data for a purpose that is either intended by this notice or permitted by law or made relevant by the circumstances.

d) Understanding of the purpose of the processing by the user/transparency We strive to ensure that the collection and in particular the purpose of the data processing are recognisable by the concerned person.

e) Information and respect for consent We hereby inform the users of how we process their data and how they are used. In addition, consent is always required, either by checking the box "Ihave read the Privacy Policy and agree to be bound by it", or when it comes to sensitive data or personality profiles, in an explicit and written manner.

f) Accuracy of data We ensure that user data is accurate and up-to-date.

g) Right of access and rectification Any person may request access to the data concerning him or her and may also, if he or she finds an error, request that it be rectified immediately.

h) Adequate level of data protection in the event of communication abroad In the event of a transfer of data abroad, we undertake to provide sufficient guarantees regarding the level of data protection in the country of transfer, so that it is equivalent to the level of protection in Switzerland.

i) Data security We have taken the appropriate technical and organizational measures to ensure the security of the data.

j) Record keeping and annual monitoring We maintain a data register, transversal to all departments, so that each employee respects this privacy policy and in order to produce annual reports to improve our processes.

k) Right to erasure At the end of a period set by law, we guarantee the deletion of obsolete data in the spirit of the "right to be forgotten". You have also the right to request that we erase your personal data, under certain conditions.

l) The right to restrict or object to processing You have the right to request that we restrict or stop the processing of your personal data, under certain conditions.

m) The right to data portability You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Exercise of your rights

Under section 2 of this privacy policy, you have the right to exercise your rights and we must respond to you within one (1) month from the day of receipt of the application.

Information we collect

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

a) Visitors data

When you browse the Website, the company automatically:

• uses Google Analytics; • uses Facebook pixel.

b) Users data

When you become a User, the Company shall collect: – your email address;

c) Referendum data

When you, as a User, the Company shall collect: – your IP address; – your browser User-Agent.

d) Newsletter's subscriber data

When you, as a Visitor or a User, subscribe to our newsletter, we collect your IP address your name, surname, your country of residence and your email address for the sole purpose to send you our newsletter.

How we use data

The data for the different types of visitors is broken down as follows:

a) User data:

Users consent to information about transactions being made public on the blockchain (if applicable), meeting our principle of transparency. As a result, anyone can gain insight into this transactional information. Other data is encrypted and kept confidential to ensure the best security and confidentiality, unless a judicial or regulatory authority requires access.

User data will be used for the purposes of:

b) Use of Google Analytics:

The website uses Google Analytics, a web analysis service provided by Google Inc.

Storage of your personal data

Your Personal data will be stored in Europe. You agree that the Company may store your Personal data in any country of the EEA, including Switzerland. The storage as well as the Processing of your Personal data may require that your Personal data are ultimately transferred/transmitted to/stored at a destination outside of your country of residence, notably Switzerland.

Where permitted by law, by accepting the terms of this Notice, you agree to such transferring, transmission, storing and/or Processing. You also agree that such activities may take place to or in countries offering a lower level of protection than your country of residence.

Log Files

www.fluid.ch follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

Transfer of data to jurisdictions or regulatory authorities

In the context of compliance with our legal obligations or set by our regulatory authority or by a judiciary court, we may be required to provide these authorities with any data they deem useful.

Children's Information and access

The user must have the civil majority set by his country of origin, knowing that the majority is set at 18 years for the countries of Europe and varies in some other states of the world. No services or information may be provided to a minor, except with the consent of his or her parents or legal guardians.

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

www.fluid.ch does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Jurisdiction and governing law

This Notice and any questions shall be governed by the laws of Switzerland, to the exclusion of any rules of conflict resulting from private international law.

Any dispute relating to this Notice must exclusively be brought before the courts of Geneva, subject to an appeal to the Swiss Federal Court.

Legal

Incorporation name: Fluid Finance SA Address: Quai du Mont-Blanc 3, 1201 Geneva, Switzerland Email: community@fluid.ch

For any questions about your rights or data, contact us at: support@fluid.ch