Fluency Pay Privacy Policy
Last Updated
February 27, 2024
Effective Date
February 27, 2024
Fluency Pay values your business and trust, and is committed to protecting your privacy. Fluency Pay is a
payment platform that uses a combination of proprietary technology to deliver a personalized shopping
experience that is easy and enjoyable for our customers. This Privacy Policy (“Privacy Policy”) explains how
your personal data is collected, processed, or used when you use Fluency Pay’s website, located at
www.fluencypay.ai (the “Site”), services offered through the Site, and through any orders that you place
(collectively, the “Services”).
Who is Responsible for the Processing of Your Personal Data?
Wantable, Inc. DBA Fluency Pay (Referred to as “Fluency Pay”, “we”, “us”, or “our” in this Privacy
Policy.)
Questions / Contacting Fluency pay / Reporting violations
If you have any questions, concerns or complaints about our Privacy Policy, our data collection, or
processing practices, or if you want to report any security violations to us, please contact us at
[email protected], or 909 S. Barclay Street, Milwaukee, WI 53204
Information Collected
Information You Provide to Us:
Account Creation
When you sign up for an account for our Services (an “Account”), you provide us your name, email address,
and password. If you connect to the Service via a Social Networking Site, or “SNS” (defined below), you
also provide your date of birth and profile picture. If you upload a photo to your Account, we will
collect that photo.
Ordering the Services
When you place an order for the Services, we or our third-party payment provider will collect payment,
shipping and billing information in order to process the transaction.
Receiving a Shipment
When you receive a shipment, we record what you keep, what you exchange and what you return. If you
provide us feedback or contact us via e-mail or through the Services, we will collect your name and email
address, as well as any other content included in the message.
When You Contact Us
If you provide feedback or contact us via email, we will collect your name and email address, as well as
any other content included in the email, in order to send you a reply.
When You Post Content
If you post content (text, images, photographs, videos, messages, comments, or any other kind of content)
on our Services, the information contained in your posting will be stored in our servers and other users
of the Services will be able to see it if you post it in an area made public, such as comments on our
blog.
We retain information on your behalf, such as messages you send (including the content of the message and
the recipient data) using your Account.
Surveys
When you participate in one of our surveys, we may collect additional profile information.
Sweepstakes
If you participate in a sweepstakes, contest or giveaway on our Services, we may ask you for your e-mail
address and/or home phone number, to notify you if you win. We may also ask for first and last names and
sometimes post office addresses to verify your identity. In some situations, we may need additional
information as part of the entry process, such as prize selection choice. These sweepstakes and contests
are voluntary.
Online Payments
For online payments, we use the payment services of Stripe or, if designated by you, Paypal . We do not
process, record or maintain your credit card or bank account information.
Information Collected from Social Networking Sites
The Services allow users to share information with us via social networking sites, such as Facebook,
Facebook Messenger, Instagram, Pinterest, LinkedIn, Twitter or TikTok (each an “SNS”). In some cases, you
can sign-in to the Services using your SNS account information. By sharing your SNS profile, you are
allowing us, including your stylist, to access some of your SNS information as allowed by you (such as
profile information and profile photo). We may receive that information from your SNS profile and that
information may be imported to the Services. Our Services also allow you to share information via such SNS
profiles, such as referral links. You acknowledge and agree that you are solely responsible for your use
of SNSs and that it is your responsibility to review the terms of use and privacy policy of the third
party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of
such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of
any such SNSs. You can contact us at [email protected] to have your
SNS profile information removed from
your Account at any time.
Text Messages
If you opt-in to receiving text messages on the site when prompted, Fluency Pay will send you marketing
promotions and/or account notifications that you opted-in for when creating or updating your account.
Consenting to receive text messages is not required to buy goods or services or to otherwise do business
with us. If you sign up for our text messaging program, cookies may be used to personalize your experience
(e.g. send you personalized text messages such as shopping cart reminders). To update your text
preferences, reply HELP for help & STOP for cancel to text message or contact
[email protected]. US
Customers only. Carrier message and data rates may apply. Message frequency varies. Carriers are not
liable for delayed or undelivered messages.
Information
Collected Automatically:
In General
When you use our Services, some information is automatically collected. For example, when you use our
Services, your geographic location, how you use the Services, referring pages, information about the type
of device you use, your mobile network information, your Open Device Identification Number, date/time
stamps for your visit, your unique device identifier, and your browser type, operating system, Internet
Protocol (IP) address, and domain name are all collected. This information is generally used to help us
deliver the most relevant information to you and administer and improve the Services.
Log Files
As is true of most websites, we gather certain information automatically and store it in log files. This
information includes IP addresses, browser type, internet service provider, referring/exit pages,
operating system, date/time/stamp, and clickstream data. We use this information to maintain and improve
the performance of the Services.
Cookies
Like many online services, we use cookies to collect information. “Cookies” are small pieces of
information that a website sends to your computer’s hard drive while you are viewing the website. We, and
some third parties, may use both session Cookies (which expire once you close your web browser) and
persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal
and interactive experience on our Services and to marketing the Services or other products.
Marketing Companies
We work with a number of companies that assist in marketing our services to you on third party websites.
These companies may collect information about online activities conducted on a particular computer,
browser or device over time and across third-party websites or online services for the purpose of
delivering advertising that is likely to be of greater interest to you, on our sites and apps and those of
third parties. While not a comprehensive list, some of these companies we work with are Facebook, Twitter,
Pinterest, TikTok, Google AdWords, Yahoo, Outbrain, Tapjoy and Bing. We also work with affiliate marketing
companies, including Impact Radius. To better understand how these companies use your information, please
see the privacy policies available on their respective websites.
Analytics Companies
We work with a number of third-party analytics companies that collect information anonymously and report
website trends without identifying individual visitors. These services allow us to view a variety of
reports about how visitors interact with the Services so we can improve our website and understand how
people find and navigate it. Currently, we work with the following analytics companies: Dynamic Yield, New
Relic and Google Analytics. This is not intended to be a comprehensive list and we may stop working with
these companies and work with others without notice. You can learn more about how these companies collect,
use and share information about you by visiting their respective websites.
Use of Your Personal Information
General Use
In general, personal information you submit to us is used either to respond to requests that you make,
help us serve you better, or market our Services. We use your personal information in the following ways:
- To choose and deliver your shipment;
- Respond to comments, requests and questions and provide customer service;
- Facilitate the creation of and secure your Account on our network;
- Identify you as a user in our system;
- Provide, process and deliver the Services you request;
- Improve the quality of experience when you interact with our Services, including the testing of different page designs to see which performs better;
- Send you administrative e-mail notifications, such as security or support and maintenance advisories;
- Resolve disputes and/or troubleshoot problems;
- Develop, improve and deliver marketing and advertising for the Services;
- Process and deliver orders;
- Respond to your inquiries related to employment opportunities or other requests;
- Send newsletters, surveys, offers and other promotional materials related to our Services and for other marketing purposes.
We may store and process your personal information in the United States and other countries.
User Feedback
We may post user feedback on the Services from time to time. If you make any comments on a blog, SNS wall
or forum associated with the Service, you should be aware that any information you submit there can be
read, collected or used by other users of these forums, and could be used to send you unsolicited
messages. We are not responsible for the information you choose to submit in these blogs and forums.
Creation of Anonymous Data
We may create anonymous data records from personal information by excluding information (such as your
name) that makes the data personally identifiable to you. We use this anonymous data to analyze request
and usage patterns so that we may enhance the content of our Services and improve Site navigation. We
reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties at
our sole discretion.
Disclosure of Your Personal Information
We disclose your personal information as described below and as described elsewhere in this Privacy
Policy.
Third Party Service Providers
We may share your personal information with third party service providers to: provide you with the
Services that we offer you through our Services; conduct quality assurance testing; facilitate creation of
accounts; to provide technical support; market the Services; and/or to provide other services to Fluency
Pay.
Corporate Restructuring
We may share some or all of your personal information in connection with or during negotiation of any
merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer,
divestiture, or disclosure of all of a portion of our business or assets. In the event of insolvency,
bankruptcy, or receivership, personal information may also be transferred as a business asset. If another
company acquires our company, business, or assets, that company will possess the personal information
collected by us and will assume the rights and obligations regarding your personal information as
described in this Privacy Policy.
Other Disclosures
Regardless of any choices you make regarding your personal information (as described below), Fluency Pay
may disclose personal information if it believes in good faith that such disclosure is necessary: (i) in
connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or
warrants served on Fluency Pay; (iii) to protect or defend the rights or property of Fluency Pay or users
of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation
of the law, this Privacy Policy, or our Terms of Use.
Other Disclosures
Regardless of any choices you make regarding your personal information (as described below), Fluency Pay
may disclose personal information if it believes in good faith that such disclosure is necessary: (i) in
connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or
warrants served on Fluency Pay; (iii) to protect or defend the rights or property of Fluency Pay or users
of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation
of the law, this Privacy Policy, or our Terms of Use.
Referrals
The Services allow you to invite your friends to sign up for the Services by sharing a referral link via
an SNS, email or other means, or by sending invitations through Fluency Pay’s referral page on the
website. If you choose to upload your contacts to the Service, we will receive and store those contacts’
information and use it to send invitations on your behalf when you choose to do so. When you refer someone
via our Site, your referral will include your name.
Third Party Websites
Our Site may contain links to third party websites. When you click on a link to any other website or
location, you will leave our Site or Services and go to another site, and another entity may collect
personal information or anonymous data from you. We have no control over, do not review, and are not
responsible for, these outside websites or their content. Please be aware that the terms of this Privacy
Policy do not apply to these outside websites or content, or to any collection of your personal
information after you click on links to such outside websites. We encourage you to read the privacy
policies of every website and App you visit. The links to third party websites or locations are for your
convenience and do not signify our endorsement of such third parties or their products, content or
websites.
Your Choices Regarding Information
You have several choices regarding the use of information on our Services:
Choices
We offer you choices regarding the collection, use, and sharing of your personal information. We will
periodically send you newsletters and emails that directly promote the use of our Services. When you
receive newsletters or promotional communications from us, you may indicate a preference to stop receiving
further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe
instructions provided in the email you receive or by contacting us directly (please see contact
information below). Despite your indicated email preferences, we may send you service-related
communications, including notices of any updates to our Terms of Use or Privacy Policy.
Cookies
If you decide at any time that you no longer wish to accept cookies from our Services for any purposes
described above, then you can instruct your browser, by changing its settings, to stop accepting cookies
or to prompt you before accepting cookies from the websites you visit. Consult your browser’s technical
information. If you do not accept cookies, however, you may not be able to use all portions of the
Services or all functionality of the Services. If you have any questions about how to disable or modify
cookies, please let us know at the contact information provided.
Changes to Personal Information
You may change your personal information in your Account by editing your profile within your Account. You
may request that we delete your personal information in your Account, but please note that we may be
required to keep this information and not delete it (or to keep this information for a certain time, in
which case we will comply with your deletion request only after we have fulfilled such requirements). When
we delete any information, it will be deleted from the active database, but may remain in our archives. We
may retain your information for fraud prevention or similar purposes.
While we and others give you the choices to control the information collected and used as described in
this Privacy Policy, there are many web browser signals and other similar mechanisms that can indicate
your choice to disable tracking, and we may not be aware of or honor every mechanism.
Information Disclosed to Third Parties
This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you
on the Services. If you disclose information to others or authorize us to do the same under this Privacy
Policy, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third
party. We do not control the privacy policies of third parties, and you are subject to the privacy
policies of those third parties where applicable.
Your California Privacy Rights
Access and Deletion Requests
If you are a resident of California, under the California Consumer Protection Act (“CCPA”) you may request
that we:
- provide you the categories of personal information we collect, disclose or sell about you, the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Privacy Policy;
- provide access to and/or a copy of certain information we hold about you;
- delete certain information we have about you; or
- provide you with information about the financial incentives that we offer to you, if any.
If you sign up as a client of Fluency Pay, you may update or correct your profile information through your
Account settings, or request that we delete your profile information and preferences at any time by
contacting us at [email protected]. If you would like further
information regarding your legal rights
under applicable law or would like to exercise any of them, you may contact us by email at
[email protected]. We do use third-party cookies and related
technologies to send targeted ads and this
may be deemed a “sale” under the CCPA. To opt out of these “sales” contact us at [email protected]. If
you are a California resident, you may designate an agent to exercise your rights under the CCPA. We will
take steps to verify the identity of the agent, and that your agent has been authorized to make a request
on your behalf. Such steps may include requiring that the agent submit a signed written authorization or a
copy of a power of attorney.
Please note your rights and choices vary depending upon your location. Certain information may be exempt
from such requests under applicable law. We will take reasonable steps to verify your identity.
Shine the Light Disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances
to request information from us regarding the manner in which we share certain categories of personal
information (as defined in the Shine the Light law) with third parties for their direct marketing
purposes. We do not share your personal information with third parties for their own direct marketing
purposes.
California Consumer Protection Act
The CCPA provides California residents with certain rights as described therein and in this Privacy
Policy. The terms in this section use the definitions set forth in the CCPA.
The CCPA provides California residents with the right to not be discriminated against (as provided for in
applicable law) for exercising rights to access and delete your personal information (as referred to in
Access and Deletion Requests, above). Please note that certain information may be exempt from such
requests under California law. For example, we need certain information in order to provide the Services
to you or we may need to retain it to comply with our own legal obligations.
Notice of Collection for California Residents
The CCPA, and its accompanying regulations, specify that we should identify the categories of personal
information we collect and purposes for which we may use it and the parties with whom we share it. The
following information is offered in addition to the disclosures made elsewhere in this Privacy Policy.
Categories of Personal Information We Collect About You
Summarized in the table below are the categories of personal information we may collect about you,
depending on how you interact with us. The following table also describes how we collect and use such
categories of information.
Categories of information collected | Purposes of use | Sources of personal information |
Identifiers and Contact Information, e.g., name, e-mail address, postal address, phone number, and password |
|
|
Demographic information, e.g., age, employment, and lifestyle information |
|
|
Physical Characteristics and Audio Data, e.g., height, weight, and audio recordings when you call customer support |
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Financial and Transactional Information, e.g., payment card information, delivery information, and information about your transactions and purchases with us |
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User-Generated Content, e.g., photos, videos, any information you submit in public forums or message boards, and feedback or testimonials you provide about our Services |
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|
Device Information and Device Identifiers, e.g., IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers |
|
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Usage Data, e.g., information about content viewed or download, domain names, landing pages, browsing activity, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, whether you open an email and your interaction with email content, access times, error logs, and other similar information |
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Geolocation, e.g., city, state and ZIP code associated with your IP address |
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Other Information, e.g., any other information you choose to directly provide to us in connection with your use of the Services |
|
|
Purpose of Use
The following chart provides additional information about the business or commercial purposes for
collecting and using your information.
Communicate with you, for example, to:
- Process and deliver orders;
- Respond to comments, requests and questions and to provide customer service;
- Send you administrative e-mail notifications, such as security or support and maintenance advisories;
- Send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes;
- Respond to your inquiries related to employment opportunities or other requests.
Provide the Services, for example, to:
- Identify you as a user in our system;
- Personalize your experience with our Services;
- Develop, improve, and deliver marketing and advertising for the Services.
Secure our Services and users, for example, to:
- Resolve disputes and/or troubleshoot problems;
- Monitoring, preventing, and detecting fraud, such as through verifying your identity;
- Combatting spam or other malware or security risks;
- Detecting security incidents;
- Debugging to identify and repair errors that impair existing intended functionality;
- Monitoring, enforcing, and improving the security of our Services.
Defending our legal rights and compliance with the law, for example, to:
- Comply with any applicable procedures, laws, or regulations and to protect our legitimate interests or those of others;
- Protect or exercise our legal rights or those of others (e.g., to enforce compliance with our Terms and Conditions, Privacy Policy, or to protect our Services, users, or others).
Defending our legal rights and compliance with the law, for example, to:
- Comply with any applicable procedures, laws, or regulations and to protect our legitimate interests or those of others;
- Protect or exercise our legal rights or those of others (e.g., to enforce compliance with our Terms and Conditions, Privacy Policy, or to protect our Services, users, or others).
Defending our legal rights and compliance with the law, for example, to:
- Comply with any applicable procedures, laws, or regulations and to protect our legitimate interests or those of others;
- Protect or exercise our legal rights or those of others (e.g., to enforce compliance with our Terms and Conditions, Privacy Policy, or to protect our Services, users, or others).
How We Share and Disclose Your Information
We may share all the categories of personal information identified in this Privacy Policy for our
operational or business purposes where the use of such personal information is reasonably necessary and
proportionate to achieve the purpose for which it was collected or for another operational or business
purpose that is compatible with the context in which the personal information was collected. We may share
such information with the following categories of entities and third parties:
- Service Providers.
- Third parties designated by you.
- An entity that is part of corporate restructuring, including a successor-in-interest or assign.
- Governmental entities.
- Third parties who are involved in a legal investigation or in protecting or defending the rights or property of Fluency Pay or users of the Services; and/or investigating or assisting in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms and Conditions.
Verification
To protect your privacy and security, we take reasonable steps to verify your identity and requests before
granting the rights above, including account access or making corrections to your information. You are
solely responsible for maintaining the secrecy of your unique password and account information at all
times.
How We Respond to Do Not Track Signals
We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to
opt out of tracking on our Services.
A Note About Children
Our Services are not directed to children under the age of 16 and children under the age of 16 are not
eligible to use our Services. We do not collect or maintain personal information from children we actually
know are under the age of 16. If a child under 16 submits personal information to us and we learn that the
personal information is the personal information of a child under 16, we will take steps to remove the
personal information from our databases. If you believe that a child under 16 provided us with personal
information, please contact us at [email protected].
Users Outside of the United States
If you are a non-U.S. user of the Services, by using the Services and/or providing us with information,
you acknowledge and agree that your personal information may be processed for the purposes identified in
this Privacy Policy. In addition, your personal information may be processed in the country in which it
was collected and in other countries, including the United States, where laws regarding processing of
personal information may be less stringent than the laws in your country. By providing your information,
you consent to such transfer.
Contact Information
We welcome your comments or questions about this Privacy Policy. You may contact us at
[email protected].
Changes to this Privacy Policy
This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we
use your personal information, we will notify you by sending you an e-mail to the last e-mail address you
provided to us and/or by prominently posting notice of the changes on the Services and updating the “Last
Update” date above. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30)
calendar days following our dispatch of an email notice to you or thirty (30) calendar days following our
posting of notice of the changes on the Services. These changes will be effective immediately for new
users of our Services. Please note that at all times you are responsible for updating your personal
information to provide us with your most current email address. In the event that the last e-mail address
that you have provided us is not valid, or for any reason is not capable of delivering to you the notice
described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective
notice of the changes described in the notice. If you do not wish to permit changes in our use of your
personal information, you must notify us prior to the effective date of the changes that you wish to
deactivate your Account with us. Continued use of our Services, following notice of such changes shall
indicate your acknowledgment of such changes and agreement to be bound by the terms and conditions of such
changes.