Fluently procurement policy evidence
Only topics backed by verified findings appear below. Each row preserves the platform's exact policy words and capture provenance.
| Topic | Plan or tier | Risk | Their words | Source |
|---|---|---|---|---|
| DPA, audit rights & data residency | All applicable tiers | unknown | “ If you would like to exercise any of your rights under California law for your personal information, please submit your request by contacting us via [email protected] ” | Captured 2026-09-25Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ We will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, verifying your name and email address. You are also permitted to designate an authorized agent to submit certain requests on your behalf. We may also follow up with you to verify your identity before processing the authorized agent’s request.” | Captured 2026-09-25Open source →Finding permalink → |
| DPA, audit rights & data residency | All applicable tiers | unknown | “ Since Fluently is a company with a principal place of business in the United States, any Personal Information that we collect in and through the Fluently Services for the purposes outlined above may be transferred to, stored on servers in, and accessed from the United States and countries other than the country in which the Personal Information was initially collected. Laws in these countries may differ from the laws applicable to your country of residence. By using the Fluently Services you agree to your Personal Information being transferred outside your original territory and subject to the terms in this Privacy Policy.” | Captured 2026-09-25Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ Deletion: You can ask us to delete the Personal Information that we collected or maintained about you.” | Captured 2026-09-25Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ Voice and Video Recordings: Using Fluently Services involves processing audio and video recordings from meetings to analyze and provide English proficiency feedback. For seamless service across devices, Fluently may retain certain information. Fluently does not retain audio and video of any other individual in the recorded meeting.” | Captured 2026-09-25Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ Fluently will keep Your Personal Information in compliance with its data retention policy or until You request to delete it. Once this time period has expired, Fluently will delete all related data, including Your audio and video recordings from online meetings. Provide You with Fluently Services, for example, to set up and maintain your account, to process payments and orders, to verify user information, including to recording and providing analysis of Your audio and video presence during online video meetings;” | Captured 2026-09-25Open source →Finding permalink → |
| Data retention | All applicable tiers | unknown | “ Right to Erasure: you are entitled to have your personal information erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where personal information is unlawfully processed.” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Analytics Providers/Advertisers: We may share information with analytics providers and advertisers to assist us in implementing and evaluating relevant advertising. Typically, this information is collected from you through cookies and other tracking technologies on our Fluently Services.” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Information Collected from Third-Party Integrations. If you choose to connect Fluently Services to a third-party online communication platform (e.g Zoom, Teams, Slack, Google Meet, Microsoft Calendar, etc.), such third parties may allow us to have access to and store information about your interaction with those services as it relates to your use of our Fluently Services.” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Google and other third-party analytics (website and app usage analytics only; this does not include data obtained through Google APIs, such as Google Calendar data)” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve the performance of our Site and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout . ” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Information Collected from Third-Party Vendors. We may use third-party vendors, including Google, to serve ads to you when you access Fluently Services. Third-party vendors use cookies to serve ads based on your prior visits to Fluently sites or to other websites as further set forth in our Do we Use Cookies section;” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “ International Transfer of Your Personal Information. If your personal information is transferred outside the EEA or UK (whether within the Fluently group or to third parties as described above), we will take steps to ensure that your Personal Information receives the same level of protection as if it remained within the EEA or UK, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses. For transfers of personal information among Fluently group affiliates we have put in place European Commission approved Standard Contractual Clauses. Your Personal Information may be transferred to, including but not limited to, the United States or the Cayman Islands, which do not benefit from a decision of the European Commission determining that the country provides adequate protection to Personal Information. You have a right to obtain details of the mechanism under which your Personal Information is transferred outside of the EEA or UK by contacting us as set out in the How Contact Us section of this Policy” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “ Service Providers: Fluently may rely on third-party service providers to perform a variety of services on our behalf, such as our web hosting and data storage service providers, payment processors and marketing service providers. Fluently take steps to ensure that these service providers act only in line with our instructions and only use Personal Information as described in this Privacy Policy and data protection agreements with equivalent protections for Your Personal Information.” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “ We share the information collected with third-party service providers such as suppliers, vendors, business partners (e.g., advertising partners, consultants) to operate our business and provide the Services. We do not sell Personal Information that identifies you. We may sell or share de-identified or aggregated data that no longer constitutes Personal Information. You can opt out in your settings.” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | unknown | “ Fluently: Fluently may share Your Personal Information among Fluently representatives depending on where You are located and the Fluently Services that You use. Fluently representatives may include our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the website and/or software and their advisors; or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.” | Captured 2026-09-25Open source →Finding permalink → |
| Subprocessors & data sharing | All applicable tiers | medium | “ Fluently discloses Your Personal Information in limited circumstances to Fluently’s affiliates, our service providers, in order to provide our Fluently Services and to improve your online meeting presence. Where required by applicable law, Fluently will only share Your Personal Information for this very limited purpose. Provide You with Fluently Services, for example, to set up and maintain your account, to process payments and orders, to verify user information,including to recording and providing analysis of Your audio and video presence during online video meetings;” | Captured 2026-09-25Open source →Finding permalink → |
Informational only, not legal advice. Terms can change; verify every cited source and capture date during procurement review.
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