Fluidmesh is committed to the privacy of its website visitors and the users of its products and services. This privacy policy (“Privacy Policy”) describes the collection, use and disclosure of information by Fluidmesh Networks, LLC, (“Fluidmesh,” “we,” or “us”) from users of our web site at www.fluidmesh.com (the “Site”), as well as all applications, devices, widgets, software, tools, and other services provided by us to customers, including our Fluidmesh Partner Portal at partnerns.fluidmesh.com (collectively, together with the Site, our “Services”). If you choose to use our Services, you agree to this Privacy Policy. The terms “you,” “your,” and “user” refer to the user visiting the Site or accessing or using the Services. Other capitalized terms used but not defined in this Privacy Policy have the meanings given to them in Fluidmesh Terms of Use. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.

Any information that is collected via our Services is covered by the Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification, and we’ll update the “Last Updated” date above to indicate when those changes will become effective.

For purposes of this Privacy Policy, we are the Data Controller only with respect to our sales and billing operations and any interactions with customers via our websites and portals.

Information collected

Tracking Information
When you interact with our Site, we receive and store information to track customers, potential customers and people who access our websites, using cookies.

Cookie Policy
In addition, like many other website owners, we use automated data collection tools such as Cookies to collect certain information when you visit the Site. “Cookies” are small text files that are placed on your hard drive by a Web server when you access our Site. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services using Google Analytics.

We also use Zopim to place cookies to track your IP address and pages visited to link with information so that we can provide customer support for you.

If you do not wish to receive Cookies, or want to be notified when they are placed, you may set your browser to do so, if your browser allows it.

Personal Data
If you create an account to use our Services or request information from us, we’ll collect certain information that can be used to identify you, such as your name, email address, postal address and phone number (“Personal Data”). In order to answer your questions or fulfill your requests, we may need to ask you for your Personal Data.

We also may collect your IP Address and location (“Log Information”).

Fluidmesh Partner Portal
When you apply for an unlock code to operate certain Fluidmesh devices, we will collect information about you and your device. This information includes, for example, Personal Data about you and your location and the serial number and MeshID of the device. Additionally, you may elect to use any of the network planning and management services offered on our Site, including RACER™ by establishing an account with us.

Fluidmesh Partner Portal collects and stores the name, address, email address, phone number for the account contact accessing the Fluidmesh Partner Portal and stores the IP addresses operated by the customer.

Fluidmesh Partner Portal collects, information about the device administrator such as user name and password. It will also collect information regarding the ISP network and the network devices attached to it, such as the following: (i) MeshID and serial number, (ii) device type, (iii) operating system, (iv) geo-location information, (v) network traffic information (e.g., hostnames, protocols, port numbers, and IP addresses); and (vi) aggregate device data usage (“Network Provider Data”). For Fluidmesh devices that use Global Positioning System (GPS) technology, we may transmit certain geo-location information about those network devices (and the network(s) on which they are running) to Google and other third party geo-location services, which in turn provides us with related geo-location information that we store and make available to you as described above.

For customers serving the European Economic Area, we enter into agreements with your company to ensure that we treat Personal Data of the network administrators and any other data in accordance with applicable law, including, but not limited the General Data Protection Regulation (“GDPR”), including the incorporation of EU Model Contractual Clauses for data export.

How Do We Use The Information We Collect?
Non-Personal Information collected by the Site
Any non-personal information we collect from your use of the Site, whether through Cookies or otherwise, may be de-identified, aggregated and pooled with other information to track trends involving the use of our Services, such as the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors’ internet service providers, and how our users use and interact with the Site. We may provide aggregate statistics about our customers, traffic patterns and related site information to reputable third parties, but these statistics will include no personally identifying information.

Personal Data and Device and Network Provider Data
Fluidmesh and its subsidiaries and affiliates may use your Personal Data and Log Information or the device and Network Provider Data collected through Fluidmesh Partner Portal (i) provide the Services or process payment for the Services, (ii) validate the identity and geo-location of the customer seeking to unlock devices (i) for regulatory purposes, (iii) provide customer support or respond to inquiries (iii) to contact you to tell you about services that may be available in the future, (iv) to help you resolve network issues we may detect through Fluidmesh Partner Portal, (v) investigate fraud, illegal activity or activity that may affect the legality, quality, security or stability of the Services, or (vi) otherwise as described in this Privacy Policy or as disclosed by us when we collect such information provided such use is permitted by law.

We use Cookies and Log Information to learn about how the Site and Services are used, to improve the Services, and to provide customer support or respond to inquiries and investigate fraud, illegal activity or activity that may affect the quality, security or stability of the Services.

Network Provider Data
Fluidmesh and its subsidiaries and affiliates may share Network Provider Data with the customer using the device and Fluidmesh Partner Portal to assist them with managing the device and ensuring security and safety of the network accessing it. In our opinion, the data we collect regarding network use does not qualify as Personal Data as it cannot be used to identify any individual person. As a precaution, as a processor of data in general we enter into agreements with such customers to ensure that our processing is done in compliance with laws applicable to data processing, privacy and protection such as the EU Model Contract Clauses for data export to data processors. However, as the processor, we also have no control over how our customers use Network Provider Data. All inquiries regarding use, review, rectification or deletion of Personal Data should be directed to the network operator or other Fluidmesh customer that is the network operator using the device.

Disclosures of Your Personal Data and Other Information
Fluidmesh is not in the business of selling your information, and we do not sell our customer lists or any Personal Data you have disclosed to us to third parties. We consider this information to be a vital part of our relationship with you. We may, however, disclose information to certain third parties if you consent to us doing so, as well as in the following specific circumstances:
– network and system troubleshooting
– internal audit processes (eg. financial, security)

Service Providers
Fluidmesh, like many businesses, may serve as data controller and hire third party service providers to perform certain processing functions in order for us to administer and provide the Services. When we employ another individual or company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These third-party companies may use and disclose Personal Data and other information that we disclose to them in accordance with the privacy policies and procedures outlined herein.

We share Personal Data with project management software and customer service providers storing data in the United States, Canada or in the European Union in order to track or provide customer service support requests and manage our projects and link such information together securely and efficiently.

We store Personal Data, Log Information and Network Provider Data with cloud storage providers in the United States for record keeping information related to providing the Services.

We also share Personal Data we collect from you with third party providers in order to track sales leads and communicate with our customers for direct marketing and administrative reasons.

When working with third party providers we take care to ensure that your Personal Data is only shared with vendors who have agreed to protect personal data through a data processing addendum and either adoption of EU Standard Contractual Clauses, EU-US and Swiss-US Privacy Shield certification or Binding Corporate Rules filed by the vendor with and approved by data protection authorities.

We collect Personal Data from the following third party service providers:

Google Analytics. Google Analytics collects information about the use of the Services on our website. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics only to improve this Site, but in anonymous form. Google Analytics collects only the IP address assigned to you on the date you visit this Site and assigns a user ID code, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google uses this information to analyze your use of the Site, to generate reports about Site activities for website operators and to provide further services related to use of the Site and the internet. Google may also share such information with third parties to the extent it is legally required to do so and/or to the extent third parties process data on behalf of Google. Although Google Analytics plants a permanent Cookie on your web browser to identify you as a unique user the next time you visit this site, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy and Data Processing Amendment. You can prevent Google Analytics from recognizing you on return visits to this site by disabling Cookies on your browser. You may block Google Analytics on some browsers with the help of a browser add-on if you do not want us to use this website analysis. This add-on can be downloaded at: ‘http://tools.google.com/dlpage/gaoptout?hl=en. For more information on Google Analytics and Google’s privacy practices, please review their privacy policy at https://www.google.com/policies/privacy/

Google Tag Manager. Google Tag Manager, an event forwarding service provided by Google. Google Tag Manager uses Cookies.to analyze your use of the Site. Google Tag Manager allows the integration of service providers and forwards analysis data to us and Google Analytics. For more information on Google Tag Manager’s terms of service and privacy policy, please visit www.google.com/analytics/tag-manager/use-policy/. You may deactivate Google Tag Manager with the help of a browser add-on if you do not want this website analysis. This add-on can be downloaded at: www.ghostery.com/

Quickbooks (a product from Intuit). Intuit operates accounting platform that is used by Fluidmesh to assist it with planning and accounting of Fluidmesh.  Mimosa and its channel partners share customer and potential customer name, address, email address, phone number and needs with Quickbook’s online platform.  Intuit is self-certified under the EU-U.S. and Swiss-US Privacy Shield and data transfers and protection are subject to a Data Processing Addendum. Processing takes place in the United States. For more information on Intuit’s privacy practices please read their privacy policy.


Salesforce.  Salesforce provides a set of tools for Customer Relationship Management (including Pardot) .Pardot is a cookie based solution that collects page visit behaviors and IP address Pardot saves all the information a user inputs into a form and associates it with a cookie for use later as well as tying the visitor tracking. Pardot by itself isn’t collecting Personal Data but associates the cookie with form data that we store for Customers. Salesforce is provided with customer name, address, email address, phone number and customer needs in order to move the sales forward and maintain the relationship with the customer and potential customers.  Salesforce is self-certified under the EU-U.S. and Swiss-US Privacy Shield and data transfers and protection are subject to a Data Processing Addendum and Binding Corporate Rules. Processing takes place in the United States. For more information on Salesforce’s privacy practices please read their privacy policy.

Zopim.  Zopim is a cookie-based Zendesk tool that tracks the pages a Customer visits and their IP address and location and attempts to tie that to a Salesforce user so that we can offer customer support.  Processing takes place in the United States, and if you do not wish to use this service you may turn off Cookies on your browser. Turning off Zoplm will reduce the amount of information our support teams can use to help you and solve your problems.

ZenDesk. Fluidmesh uses ZenDesk to provide customer support, including chat support. ZenDesk collects your name, address and IP address of the person contacting Fluidmesh for support.  ZenDesk is self-certified under the EU-U.S. and Swiss-US Privacy Shield and data transfers and protection are subject to a Data Processing Addendum and Binding Corporate Rules. Processing takes place in the United States.  For more information check out ZenDesk’s privacy policy and other policy documents.

Channel Partners:
We may disclose Personal Data such as customer identity and contact information, as well as other information to our channel partners, such as distributors or resellers, in connection with the provision of and billing for the Services. Except as provided under the Business Transfers section, we do not sell Personal Data to third parties.

Information Disclosed for Our Protection or the Protection of Others:
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you or Network Provider Data to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, or as part of a legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to investigate or stop any activity that we consider an illegal, fraudulent, unethical or legally actionable activity.

Business Transfers:
Information about our users, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Data is transferred to one or more third parties as one of our business assets. We will take steps to inform you should such a transfer occur by contacting you at the email address we have on file in your account.

Your Choices and Digital Rights
We offer you choices regarding the collection, use and sharing of your Personal Data and we will respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.  If you have any questions, requests or wish to object to any use of Personal Data detailed in this Privacy Policy, please contact us at privacy@fluidmesh.com.

Marketing Communications

We may periodically send you free newsletters and e-mails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications, e.g., communications regarding updates to our Terms of Service or this Privacy Policy or information about billing.

Reviewing and Correcting Your Personal Data

In the event you would like view or correct data we store about you, you may contact us at privacy@fluidmesh.com with your request so that we may initiate proper procedures to respond to your request. We reserve the right to charge for copies of personal data undergoing processing.

You can access and modify the Personal Data associated with your account by emailing us at privacy@fluidmesh.com.

Removing, Objecting to or Withdrawing Your Personal Data

If you would like to remove your Personal Data as an administrator and add a replacement, you may change such information through your account. However, if all administrator Personal Data or all administrators are removed, we cannot verify the account or conduct billing, and we shall discontinue the Services that we provide.

If you want us to delete your Personal Data and your account, please contact us at privacy@fluidmesh.com. We will take steps to delete Personal Data unless we are permitted or required to retain such data by law.

Data Portability

If you would like your data made available for portability, please contact us at privacy@fluidmesh.com to specify what data you would like made portable, and we will send it to you or another controller in a machine readable form.

Grievances

If you live in the European Economic Area, and believe we are violating your digital rights, you have the right to file a grievance with the Information Commissioner’s Office in the United Kingdom.

Your California Privacy Rights

In the United States, California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their personally identifiable information for direct marketing purposes during the preceding calendar year and the categories of personally identifiable information shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email at privacy@fluidmesh.com with “California Privacy Rights” in the subject line or by writing to us at Fluidmesh Networks, 81 Prospect St, Brooklyn, NY, 11201, Attn: Privacy Policy Request.

Data Retention
Fluidmesh takes steps to regularly delete data when we no longer have legitimate business purposes to retain it.  However, we are required by law and/or our contractual obligations with our customers to retain some data for reporting purposes or to protect against legal claims.

Security
Fluidmesh takes reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure, including protecting your Personal Data with encryption, passwords and SSL technology.  We train our staff regarding security procedures and restrict access to the Personal Data we store to those who need to access it to provide Services to you. Our devices also have security measures to help ensure that data is securely transmitted. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

Do Not Track
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Data.

Links to Other Sites
Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

Children
Fluidmesh does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data through this Site, please contact us at privacy@fluidmesh.com, and we will endeavor to delete that information from our databases.

International Visitors
Our servers and data centers are located in the United States. If you choose to use the Services from outside the U.S., then you should know that you may be transferring your Personal Data outside of your region and into the U.S. for storage and processing in connection with the services we supply to our customers. When we receive Personal Data data from the European Economic Area we treat it in accordance with the GDPR and work with our customers to ensure that such Personal Data is processed in compliance with GDPR.

Questions?
Please contact us at privacy@fluidmesh.com, with “Privacy Policy Question” in the subject line if you have any questions about our Policy or contact us at:

Fluidmesh Networks LLC

81, Prospect St.

Brooklyn, NY 11201

Att.on Umberto Malesci, CEO