PRIVACY POLICY

Welcome to the privacy policy of Fluence Group Ltd (“Fluence”).

Fluence is committed to protecting your personal data and respecting your privacy. This policy will inform you on how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

WHO IS POLICY INTENDED FOR?

Any individual whose personal data may be processed by us as further detailed in this policy. If you are an existing business customer of Fluence, the relevant contract between you and us (or your employer and us if you are acting in a business capacity) will govern the processing relationship between us.

PURPOSE OF THIS NOTICE

This policy sets outs the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following privacy policy to understand how we collect and use your personal data, for example when you contact us, visit our website, or use our products and services. 

This website is not intended for children, and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

This website is operated by Fluence Group Ltd. This privacy policy applies to all websites, products, and services operated by Fluence Group Ltd, including AI Infrastructures (the “Websites”). References to “Fluence”, “we”, “us” or “our” in this privacy policy refer to Fluence Group Ltd and its websites, products, and services.

Our privacy team is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the team at [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office, the United Kingdom (“UK”) regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance.

THIRD-PARTY LINKS

Our Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Websites, we encourage you to read the privacy policy of every website you visit . If you follow a link to any of these websites, please note that Fluence does not accept any responsibility or liability for these policies.

THE DATA WE MAY COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Fluence may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data. Information that you provide by filling in forms out on our Websites, providing details by registration or other means (e.g., giving business cards) at a marketing event, or when setting up accounts in our product or services.

Contact Data. Information that you provide us and may include personal information such as email addresses and phone numbers.

Usage Data. Information you provide us through inquiries and/or feedback. Fluence may ask you for information when you report a problem with our Websites.

Profile Data. Details of your visits to our Websites including, but not limited to, traffic data, location data and other communication data, and the resources that you access.

HOW IS YOUR DATA COLLECTED?

COOKIES

Cookies are small text files that websites save to your computer. These pieces of information are used to improve services for you through, for example:

Remembering settings, so you don’t have to keep re-entering them whenever you visit a new page;

Remembering information you’ve given (e.g. your postcode) so you don’t need to keep entering it.

Session cookies allow us to track your actions during a single browser session, for example to remember the items returned from a search. They do not remain on your device beyond your session.

Persistent cookies remain on your device between sessions and allow us to authenticate you and to remember your preferences.

Session and persistent cookies can be either first or third-party cookies. A first-party cookie is set by the website being visited. A third-party cookie is issued by a different website to that being visited.

Our Websites may use a third-party cookie provided by Google Analytics to gather anonymized information for the benefit of all web users. We do not currently use behavioural targeting cookies.

If at any time you wish to disable our cookies you may do so through the settings on your browser, but if you do so you will not be able to use certain important features of our service.

PROVIDING PRODUCTS AND SERVICES

If you purchase or use our products or services, we may use your personal data for purposes which include but are not limited to:

Verifying your credentials.

Providing access to our platforms, infrastructure, and services.

Providing training sessions for which you have registered.

Providing maintenance and technical support.

Providing information about product upgrades, updates and renewals.

Developing and enhancing products, services, and our infrastructure.

Managing service delivery, including cloud, hosting, AI infrastructure, and related technical services.

Processing orders and generating billing information.

Certain products and services may include features that collect additional personal data for other purposes, as described in the applicable customer agreement. For detailed information, please also refer to the applicable product or service description.

WHERE IS YOUR PERSONAL DATA STORED?

Your personal data is securely stored by Fluence Group Ltd using its systems and the systems of trusted third-party providers, including cloud, hosting, CRM, and infrastructure service providers.

Fluence Group Ltd has implemented appropriate technical and organizational measures to safeguard personal data and to prevent unauthorized access, disclosure, alteration, or loss.

HOW WE USE YOUR PERSONAL DATA?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following ways:

To provide you with information, products or services that you request from us, or which we feel may interest you.

To carry out our obligations arising from any contracts entered into between you and us.

To allow you to participate in interactive features of our products or service, when you choose to do so.

To notify you about changes to our products and services.

Where we need to comply with a legal obligation.

Please see the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Communication purposes

Personal information may be collected so we can:  

Respond to requests and enquiries.

Send technical alerts, updates, security notifications, and administrative communications. 

Provide you with information you have requested about our services, tailor communications to your interests, or to provide you with information on services we think might be of interest to you.

Send you product recommendations and other non-transactional communications.

Send information related to processing or completed transactions, including transaction confirmations and invoices. 

The lawful basis we rely on to process your personal information for the purposes described above is either consent or our legitimate interests in ensuring we respond to enquiries, provide helpful communications, and tailor communications.

Managing our Websites

Fluence uses the personal information we collect to effectively manage our Websites, enhance functionality, understand user behaviour, identify trends, deliver relevant content, and improve your overall experience. We may also process your personal information as part of our efforts to keep our Websites secure.

The lawful basis we rely on to process your personal information for the purposes described above is either consent or our legitimate interests in ensuring the effective operation, improvement, security, and personalization of our Websites, while providing relevant content and services based on user interactions and requests.  

Sales and marketing

We process your personal information to advertise or market to you, conduct market research, and provide you with personalized content.

Our sales and marketing teams may use your information to offer more bespoke services/tools based on your interest in our products, services, or solutions. We may also provide you or your employer with information and services associated with events you have registered for.

In addition, we may process your personal information for purposes made clear to you at the time you submit your personal information, for example to provide you with access to one of our downloadable resources and contact you in relation to similar products/services.

The legal basis for the above is either your consent, for example when you agree to receive marketing communications after an event, or our legitimate interests, for example to contact you to offer related services that may be of interest to you based on the services that you may have bought from us, or related to the resource or a demo that you have requested from us.

You always have the right to opt out of marketing communications by using the unsubscribe link included in our emails or by contacting us directly using the contact details provided in this Privacy Policy.

Providing and improving our services

We use the personal information we collect from our customers in connection with the services we provide in order to:  

Set up a user account. 

Provide, operate, maintain, and improve our services. 

Process and complete transactions.

Manage payments.

Provide customer service and support. 

Investigate and prevent fraudulent activities, unauthorized access to the services, and other illegal activities. 

Tailor the services to interests and needs.

For any other purposes about which we notify customers and users. 

The legal basis under applicable data protection law for the above processing is either based on performance of a contract (i.e., the agreement that we have in place with you), consent, or our legitimate interests, typically, either for security purposes or business practice improvement such as the prevention and investigation of fraudulent activities.

Some of the activities described in this section may be performed using artificial intelligence (AI) and automation technologies. For more information, please see the section “Use of Artificial Intelligence and Automation” below.

Use of Artificial Intelligence and Automation

We use AI and automation technologies to enhance user experience, streamline internal operations, and provide personalized support. These technologies may:

Support business operations and customer interactions: These tools may process customer-related information (such as contact details and other personal data stored in our internal systems) and recordings of customer calls (including audio, video, and transcripts) to generate insights, summarise discussions, identify action items, answer queries, or facilitate support and sales activities. 

Analyze customer engagement and improve services: These technologies may orchestrate and analyze data collected regarding how customers interact with our platform (such as product analytics, customer relationship management, feedback and surveys) to power interactive features such as chatbots, which recognize users once logged in and provide tailored guidance, tutorials, and recommendations to encourage effective use of our products. 

For compliance with legal obligations

We process your personal information where needed in accordance with our legal obligations under applicable laws, legal processes, or government regulations, and to cooperate with public or government authorities, courts or regulators. 

The legal basis under data protection law for the above processing is complying with legal obligations or legitimate interest. 

To engage in these uses of your personal information, we may use tools such as large language models and other forms of artificial intelligence in accordance with applicable law.

TRANSFERRING PERSONAL DATA

As a global company, we have international sites and users all over the world. Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. When you give us personal data, that data may be used, processed or stored anywhere in the world, including countries outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers.

Fluence places substantial importance on protecting the confidentiality of personal information and seeks the cooperation of all its suppliers in furthering this goal. Fluence will only transfer personal information to a supplier where the supplier has provided assurances that they will provide at least the same level of privacy protection as is required by this policy. Where Fluence has knowledge that a supplier is using or sharing personal information in a way that is contrary to this policy, Fluence will take reasonable steps to prevent or stop such processing.

We take appropriate safeguards to protect your privacy, your fundamental rights and freedoms, and the ability to exercise your rights. Where personal data is transferred outside the UK and/or the EEA, to service providers located in the United States, we ensure that appropriate safeguards are in place. These safeguards may include the use of standard contractual clauses approved by the European Commission, reliance on adequacy decisions, participation in the EU-U.S. Data Privacy Framework, or other lawful transfer mechanisms, where applicable.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

SECURITY

Fluence endeavours to hold all personal data securely in accordance with our internal security procedures and applicable law.

We update and test our security on an ongoing basis. Fluence will do its best to protect your personal data, but Fluence cannot guarantee the security of your data transmitted to our site through the internet; any such transmission is at your own risk. Once we have received your information, we will maintain the appropriate administrative, physical, technical and organizational measures to protect your personal data accessed or processed by us against unauthorized or unlawful processing or accidental loss, destruction, damage or disclosure.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If you receive an email which claims to come from us but does not use our domain, or if you are suspicious that an email may not be approved by us, then please send a copy of the email to [email protected] so we can investigate.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your personal information in the following limited circumstances: 

Vendors, consultants, and other service providers

We may disclose your personal information to vendors, consultants, and service providers who perform services on our behalf. These services include processing payments, analyzing website usage/analytics, preventing spam and security threats related to abusive automated software, managing online activities, gathering product feedback, providing help desk support, operating our CRM, e-learning services, facilitating transactions, tracking marketing campaigns, and handling email communications. 

Fluence may also share your personal information with banking, legal, insurance and accounting services (who may act as processors or controllers) to the extent we are legally obliged to share or have a legitimate interest in sharing your personal information.

If Fluence receives your personal information and subsequently transfers that information to a processor for processing, Fluence remains responsible for ensuring that such processor processes your personal information to the standard required by the applicable data protection law, including the General Data Protection Regulation (‘GDPR’). These transfers will be governed by an agreement. 

Corporate transactions

We may choose to buy or sell assets and may share and/or transfer customer information, including personal information, in connection with the evaluation of, and entry into, such transactions, based on our legitimate interests. Also, if we or our assets are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information may be one of the assets transferred to or acquired by the third party.

Protection of Fluence and others

We reserve the right to access, read, preserve, and disclose any personal information as necessary to i) comply with a law or a court order, ii) enforce or apply our agreement with you and other agreements, or iii) protect the rights, property, or safety of Fluence, our staff, our users, or others. 

Disclosures for national security or law enforcement

Under certain circumstances, we may be compelled to share personal information in response to a valid government or law enforcement request. 

HOW LONG DO WE STORE YOUR PERSONAL INFORMATION 

We store your personal information for different time periods depending on the category of personal information and the nature of relationship that you have with us. Our goal is to keep your personal information for as short of a period as possible to achieve the purpose for which personal information was collected. We consider the following criteria when determining how long we will retain your personal information: 

The category of personal information.

Whether the personal information is typically deleted based on specific schedules, such as marketing information.

Whether the personal information is necessary to operate or provide our services. For example, account information may be retained for a longer period of time based on the agreement you have with us. 

How long we need to retain the personal information to comply with our legal obligations.

Our legitimate interests or legal purposes, such as network improvement, fraud prevention, record-keeping, promoting safety, security and integrity, or enforcing our legal rights.

YOUR RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary to find out more on how the rights listed below:

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you?

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

CHANGES TO OUR PRIVACY & DATA PROTECTION POLICY

We may update this policy from time to time. The latest version will always be available on our Websites.

This policy was last amended on 12 March 2026.

GLOSSARY

LAWFUL BASIS

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.