Privacy Statement for FLUID Products and Services

At FLUID, we take your privacy seriously.

This Privacy Statement for FLUID Products and Services (“Privacy Statement”) describes information that FLUID Labs, Inc. and its subsidiaries and affiliates (collectively, “FLUID”) collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information).

This document focuses on information related to the operation of FLUID products and services, including FLUID the Learning Water Meter™ and other products from FLUID (collectively, “FLUID Products”). In this Privacy Statement, the expression “FLUID Products” also includes our Web Apps, Mobile Apps, and Subscription Services as defined in our Terms of Service.

We provide additional details about how we collect and use information from our public web sites in our Privacy Policy for FLUID Web Sites.

Our Pledge:

  1. We will be transparent about the different types of information we collect and how we use them.
  2. We will ask your permission before sharing your personal information with third parties for purposes other than at your request or to provide FLUID’s Products, and to do so only when we think they will provide you with a welcome additional service.
  3. We will use data security tools to keep your data safe and protect the FLUID Products from unauthorized access.

Your Permission: Permission for data collection and processing. By using FLUID Products, you agree to allow us to collect and process information as described in this Privacy Statement.

International data transfers. Your personal information may be collected, processed and stored by FLUID or its service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using FLUID Products in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, you agree to the transfer of your personal data to the United States and other countries where FLUID operates. 

What information does the FLUID the Learning Water Meter collect?

FLUID the Learning Water Meter collects:

  • Setup information you provide
  • Flow measurement and temperature data from FLUID’s sensors
  • Device details and settings, alerts, goals, sharing
  • Technical information from the device

Setup information you provide: When you install the FLUID the Learning Water Meter, you’ll be asked several questions in order to help us associate your device with your household and home. For example, we’ll ask for information like the location and size of your home, number of bathrooms and occupants, ages of occupants, what appliances and fixtures you have in your home (including dishwashers, clothes washers, sinks, toilets, showers & tubs, lawn irrigation and more). You will not be required to answer these questions, however, answering these questions helps us to understand your usage habits and behaviors as well as helps us develop and provide comparative data sets that are completely anonymous – allowing you to see your own water usage compared to other similar households. 

Flow measurement and temperature data from FLUID’s sensors: We collect data from several sensors built into FLUID the Learning Water Meter. These sensors collect data such as current water flow in the home. They can also sense whether the pipe temperature has dropped to unsafe levels where freezing and bursting may occur. This helps your FLUID give you peace of mind that you don’t have any leaks or freezing pipes when you are away. 

Device details and settings, alerts, goals, sharing
If you create an alert, goal or share your meter with another user FLUID the Learning Water Meter records and feeds that information to the FLUID servers so these features are always on and available to you in real-time. 

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with FLUID the Learning Water Meter, we record your FLUID’s model and serial number, software version, and technical information such as if it is online, has successfully completed any remote over-the-air software or firmware updates, if it has been unplugged or reset, as well as the ultrasonic signal strength. 

What additional information does FLUID collect and store when a user connects a FLUID Product to the Internet or creates an account?

Wi-Fi Network Information: To connect your FLUID Product to our Services, or to access your FLUID Product over the Internet from a computer, a smartphone or a tablet, you will need to connect it to your Wi-Fi network. During setup, the FLUID Product will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the device, along with your IP address, so that you can access it and control it from your computer, smartphone or tablet, and so that it can communicate with FLUID servers and download software updates.

Once connected to your Wi-Fi network, your FLUID Product regularly sends the data described in this Privacy Statement (excluding your Wi-Fi password) to FLUID to provide you with the Services.

Additional Authorized Users: FLUID may provide you with the ability to enable additional authorized users to access your account. If you do so, the additional authorized users may edit settings like alerts and goals as well as view all of your water usage data. Invited users may also add additional authorized users to your account, so be careful to add only those you trust. An invited user must have or create a FLUID account, and information about invited users (like email address, name or changes to product settings) will be stored with your account.

Email Addresses: When you create a FLUID account, we collect and store your email address. From that point forward, your email address is used for communications from FLUID. In addition, FLUID may provide you with the ability to enable individuals to access your account as additional authorized users, or to invite other individuals such as friends or family to share access to your water usage data. We will ask you for the email address of any such individuals and automatically send an email invitation. FLUID stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation services.

Basic Profile Information: Your account allows you to provide certain basic profile information like your name and profile photo. Names and profile photos may be shown to others in connection with the Services. In addition, if you download the FLUID Mobile App, we may collect and store your mobile device identifiers (such as IDFA, AAID, or other device identifiers). For example, if you invite someone as an additional authorized user, he or she will be able to see your name and photo. You should only use photos you are willing to make public.

Bluetooth data: Bluetooth-enabled FLUID Products (such as FLUID the Learning Water Meter) may broadcast an identifying signal wirelessly. This is used to connect with your Bluetooth-enabled devices (such as a smartphone or tablet) in order to deliver features like easy setup.

Remember that when you visit our Sites, we collect personal information as described in our separate Privacy Policy for FLUID Web Sites. Like most Internet sites, we routinely record log entries (including information such as your IP address) and technical information (such as your browser type and version) when your browser, mobile device or FLUID Product contacts our servers.

How does FLUID use the information it collects?

We use this information to provide, develop and improve FLUID Products and services, including to make assessments and recommendations about products, safety, or water use. We may use your contact details to send you this information, or to ask you to participate in surveys about your FLUID use, and to send you other communications from FLUID.

We may also use this information in a non-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we use aggregated user information about the number of active smart water meter users in a particular state to help us decide what water utility companies might be good partners, and aggregated water usage and leak alert data to study water damage insurance claim rates across our customers.

We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our servers. Depending on your location and type of data, FLUID may process your personal information on servers that are not in your home country.

In general for purposes of applicable law (e.g., GDPR), FLUID is a controller of the information collected in connection with the Products and Services. 

If European data protection law applies to the processing of your information, we process your information for the purposes described in this Privacy Statement, based on the following legal grounds:

When we’re providing a product or service

We process your data to provide and support a product or service you’ve asked for under a contract, including but not limited to delivering our Terms of Service.

When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:

  • offering and improving FLUID Products and services
  • developing new products and features
  • understanding how people use our products and services
  • performing research that improves our services for our users and benefits the public
  • sending you direct marketing and other communications from FLUID
  • protecting against harm to the rights, property, and safety of FLUID, our users, and the public
  • detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our services
  • maintaining and improving the integrity of our computing systems, and protecting our users’ data security
  • enforcing legal claims, including investigation of potential violations of applicable Terms of Service

When we’re complying with legal obligations

We process your data when we have a legal obligation to do so, for example, if we’re responding to a legal process or an enforceable governmental request.

We ask for your consent to process your information for certain specific purposes and give you the right to withdraw that consent at anytime.

In what circumstances does FLUID share my information?

Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the activation and delivery of FLUID Products and services without asking you first. Period. We do not rent or sell our customer lists. The following are the limited situations where we may share personal information:

  • With your permission: We may share personal information when we have your permission. One example of this would be if you invite another user to access the Products on your account as an additional authorized user. Another example is if you sign up for programs offered by our partners (e.g., water or insurance companies); if you do this, we may share certain information with the partner. This could include things like your enrollment information and the activation status of your device.  
  • For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage,including helping to answer your questions. They may also assist with monitoring our servers for technical problems.
 These technicians (as well as FLUID employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-FLUID purposes. 
  • As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.
  • For legal reasons: We will share personal information with third parties if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to (i) meet any applicable law, regulation, legal process or enforceable government request; (ii) enforce FLUID policies or contracts, including investigation of potential violations; (iii) detect, prevent or otherwise address fraud, security or technical issues; (iv) protect against harm to the rights, property or safety of FLUID, our users or the public as required or permitted by law.

We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. For example, we may publish trends about water use in the home. This information may also be shared with other users to help them better understand their energy usage compared to others in the FLUID community, raise awareness about safety issues, or help us generally improve our system. We may also share non-personal information with our partners, for example, if they are interested in providing demand-response services or other incentive programs. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.

If you select an outside party for the purchase, installation or service of your FLUID device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a FLUID the Learning Water Meter from a retailer, the retailer may collect personal information as part of the transaction. Or the party that installed the device may retain information that you provided to them to assist them in servicing the device if needed. Always check the privacy policies for any company that collects your personal information.

What choices do I have and how can I delete my personal information?

FLUID generally stores your personal information on FLUID’s servers until you delete or edit it, or for as long as you remain a FLUID customer in order to provide you with FLUID Products. In addition, FLUID may store your personal information to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

As described above, some information is processed and stored directly on the FLUID device. Personal information from FLUID devices is encrypted while it is being transmitted to FLUID.

You can access, amend or delete your personal information from FLUID’s servers through the controls in your account. FLUID customers can also request their FLUID data by emailing privacy@fluidwatermeter.com. Learn more about our data retention practices here.

Individual Rights in the European Economic Area.

If you are located in the European Economic Area, you may seek confirmation regarding whether FLUID is processing personal information about you, request access to your personal information and ask that we correct, amend or delete your personal information. In addition, you may object to FLUID’s processing of your personal information at any time. However doing so may impact your use of the Products and Services.

If applicable law provides you the right to request access to, (receive) port, object to or restrict processing, seek rectification or request erasure of personal information held about you by FLUID, you may do so, as applicable, through controls in the FLUID application or by contacting FLUID. To protect your privacy, FLUID will endeavor to take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information. Learn more at fluidwatermeter.com/privacy.

How does FLUID protect my personal information when it is transferred internationally?

When we transfer personal data from the European Economic Area and Switzerland to other countries, including to the United States, we use a variety of mechanisms to help ensure your data is appropriately protected.

We may share, as described in this Privacy Statement, information with our affiliates and subsidiaries, and third parties. We may disclose information in response to legal process and lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security.

Minors.

Only individuals aged 18 and older are permitted to act as Owners of FLUID Accounts. Authorized Users must be over the age of 13 (or equivalent minimum age in the jurisdiction where they reside) and may use the Products and Services under the supervision of a parent or legal guardian and only if they agree to be bound by these Terms on your behalf. FLUID Products and Services do not knowingly collect or store any personal information from anyone under the age of 13.

Can the Privacy Statement be changed?

Please note that this Privacy Statement may change from time to time. We will provide notice of any changes on the website or by contacting you.

How can I contact FLUID?

For users in the United States and other countries outside of the European Economic Area:  FLUID Labs Inc., Suite B103 2380 Wycliff Street, Saint Paul, MN 55114

For users in the European Economic Area: FLUID Services Ltd., 298 Langley Road, Salford, Manchester, England M6 6ST

If you have any questions, you may submit an inquiry to, by emailing privacy@fluidwatermeter.com.