Dated April 2022
We are Flux Systems Limited. Our company details and our registration with the UK’s data protection regulator are available here.
We know it can be difficult finding the right offers when you need them. Flux Offers is here to change that. Our offers are tailor-made for you based on your shopping preferences so that you can save money on the products you love. Being tailored to you, means we need to process your personal data in order to do this, so we want to be super clear as to what we process and how we do this.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at DPO@tryflux.com.
2. How do we use your data?
When you register to use the WebApp and link your bank account (including Monzo & Starling) we will collect your email address (in order to provide you with a magic link to access the WebApp) and which bank you are a customer of. We do this in order to take steps to enter into a contract with you and provide you with the Flux service.
If you have already signed up to use Flux via your banking app, we will use your email to pull across the relevant information needed to set up your account – you don't need to fill in your details twice!
Where you register to use our app as a customer of Fidel we will link your account directly and receive your email address (to provide you with a magic link to access the WebApp) and which bank you are a customer of. We do this in order to take steps to enter into a contract with you and provide you with the Flux service.
Please note: If you choose to register a payment card in connection with transaction monitoring, you authorise us to share your payment card information with Mastercard so they know you enrolled. You authorise Mastercard to monitor transactions on your registered card(s) to identify qualifying purchases, and for Mastercard to share such transaction details with us to enable your card-linked offer(s) to be implemented, and to target other offers that may be of interest to you. You may opt-out of transaction monitoring on the payment card(s) you have registered by contacting us at: DPO@tryflux.com.
We receive the following information which may identify you directly or indirectly when you make a transaction with:
A linked Flux bank account
A Merchant that's partnered with “Flux”
Your account ID, your email, the last 4 digits of your card number, your account number, your sort code, the merchant's name, the authorisation code of the transaction, the time of your transaction, the transaction amount, the currency used, the merchant identification (MID), any relevant linked transactions, your payment method, your payment scheme (e.g. Visa, Mastercard), and the Bank's Identification Number (BIN).
The last 4 digits of your card number, the merchant's name, the authorisation code of the transaction, the time of your transaction, the transaction amount, the transaction location, the currency used, the items purchased, the offers benefitted from, any discount charges, VAT on the transaction, VAT number of the Merchant, the merchant identification (MID), any relevant linked transactions and your payment method.
We collect this information in order to fulfil our contract with you in relation to the Flux services that are provided. We also collect information to create analytics to continue to improve our WebApp and we collect this based on our legitimate interests. We do not at any point aim to collect cardholder information.
Where you wish to add additional cards via Fidel, in addition to the above we will receive from Fidel the first six digits of your card number, the last four digits of your card number, the card scheme provider (e.g. Visa or American Express), your card expiry date and its country of issue. We will only receive this where you have provided Fidel with your consent to share this with us.
When we send you our news updates we will handle your personal information (such as your name and email address) to provide you with our news updates in line with any preferences you have told us about. This includes using our third party trackers to provide you with personalised discounts via the WebApp.
When we send you our news updates because you have opted-in to receive them, we rely on your consent to contact you. You can unsubscribe from our updates at any time by clicking the unsubscribe link at the bottom of any of our emails, or by contacting us at DPO@tryflux.com.
When you contact us either by phone, email, via social media (e.g. on LinkedIn), we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query.
If our business is sold. We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the buyer of our business may not be able to provide services to you.
3. Who do we share your data with?
Your linked bank in relation to offers you've used and revenue we need to pay them as a result. We do this in order to perform our obligations under the contracts we enter into with them or you. Where you use Fidel to connect your account/card, we share information with Fidel in order to fulfil our contractual obligations with you.
The Merchants you visit to help them understand how you use the Flux platform, your top purchased products and the offers you use. Where we share aggregated and anonymised data about your purchases, we do so as we have a Legitimate Interest in ensuring both we and merchants you visit can understand how you use the platform, what your top purchased products are and what offers you use. We may also share the same information with individual companies, where their products are offered via multiple channels and merchants, such as Ben & Jerrys.
When you redeem an offer with a merchant, we will only share limited information back with them, which will be in the form of Order ID and/or Payment Reference. If we are to share this information back with a merchant, you will see this is clearly noted in the terms and conditions of the offer you activate. By activating an offer, you are agreeing to the terms and conditions, which can include sharing of the above limited information.
Regulators/ Authorities/ Enforcement Agencies where we’re required to share your personal data to:
- comply with a legal obligation,
- protect the rights, property, or safety of our clients or others, or
- to protect against fraud.
Prospective buyers of Flux to make sure they can continue our business (this is under our legitimate interest).
4. Where is my data stored?
We store your data on third party Amazon cloud servers based in Ireland.
Whenever we transfer your personal information outside of the UK and the EU, we ensure it receives additional protection as required by law. To keep this privacy notice as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at DPO@tryflux.com for more detail on this.
To find out more about how your personal information is used by Fidel, please visit their website at Fidel.uk.
5. Cookies Policy
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer's browser or hard drive if you provide your consent.
Allow us to count visits and monitor performance of our site
Allows us to track user interaction with our site
Allows us to store a user's access token so they can make requests to our API, as well as tracking whether they have gone through onboarding already.
Allows us to track user interaction with our site
Allows us to track application performance and report errors
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our WebApp.
7. How long do we keep your data for?
We will only retain your personal information for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements. The time in which we retain your data will be dependent on the bank you are with, however usually this is between 2 and 6 years.
If you are a:
- Starling customer, we will retain your transactional data for 2 years; and
- If you are a Monzo customer, we will retain your Flux relevant transactional data for 6 years.
- If you are connecting your account/card information using Fidel, we will retain your transaction data for 7 years. We will retain your banking details until you terminate your agreement with us i.e. wish to stop using this service.
In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to analyse our programmes and support other similar programmes around the world.
8.What are my rights under data protection laws?
You have various other rights under applicable data protection laws, including the right to:
- access your personal data (also known as a “subject access request”);
- correct incomplete or inaccurate data we hold about you;
- ask us to erase the personal data we hold about you;
- ask us to restrict our handling of your personal data;
- ask us to transfer your personal data to a third party;
- object to how we are using your personal data; and
- withdraw your consent to us handling your personal data.
You also have the right to lodge a complaint with your relevant supervisory authority, you can find which one applies to you here.
Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.
9. Questions, comments and more detail
Your feedback and suggestions on this notice are welcome.
We’ve worked hard to create a notice that’s easy to read and clear. But if you feel that we have overlooked an important perspective or used language which you think we could improve, please let us know by email at DPO@tryflux.com.
This privacy notice was last updated on 8th April 2022.