Personal data privacy policy

1. Identification and introduction

Fluicity is a French simplified joint stock company with share capital of Euro 24,042, registered in the company register of Paris, at number 812 620 318, with registered office  at 53, rue du Caire, Paris, France (« Fluicity » or « Us ») and which proposes online services of civic transformation of companies and organizations through collective intelligence and inclusive governance, including a network platform, following the general terms and conditions of use ( (the « Services »).

As a (Data) Controller, Fluicity, processes your personal data within the framework of the use of the mobile application which it runs and markets. The application is accessible on mobile phones and tablets and can be downloaded from the platform Playstore and App Store (« the Application ») and from its website accessible through the following URL: (the « Website ») within the framework of the Services.

Fluicity respects the privacy and protects the personal data of the users of the Services (the « Data »).

Fluicity is aware of the importance of guaranteeing the confidentiality of your Data and is strongly committed to protecting these Data, as described in the present document (the « Privacy Policy »). The Privacy Policy can evolve under the conditions specified under paragraph 15 hereafter.

2. Purpose

This policy aims, in particular, to explain to you the methods of collection, processing and use of your Data and your rights as regards the protection of your Data concerning the provisions applicable in this area.

3. When do we collect your data ?

Your data are collected and processed when you use the Services, and more specifically:

  • Upon  the creation of, the access to and the management of your personal space on the Website and the Application;
  • Upon your identification to access to the Services of Fluicity;
  • Upon the processing of your requests and complaints;
  • And during the geolocation of your position.

We collect your Data directly from you, at your request and during the use of the Services.

4. Which Data do we collect ?

When you use the Services, we can be compelled to collect the Data listed below:

  • Identity and address: it concerns your title, last and first name, profile image, description (the data communicated to present yourself), e-mail-address, residence address, residence neighborhood, date of birth and socio-professional group;
  • Activity and use of the Services: these Data refer to your activity on the Website or Application, such as the type of content that you consult, the content which you publish, the frequency and duration of your activities, the data resulting from the analysis of the user profile;
  • Location data: if you choose to be geolocated, we collect your GPS coordinates;
  • Technical information: it regards the version of the used Fluicity App, the type of your operating system, the model of your smartphone, the browser used and its version, the time zone used, the language used, your notification preferences and the IP-address; and
  • Browsing history and your activity within the framework of your use of the Services.

The data which you have to notify us on a mandatory basis in order to benefit from the Services are indicated, as such, in the (data) collection forms. If you do not provide such data, you will not be able to access the Services.

5. Why do we collect your Data ?

Purpose of the processing Basis for the  processing

Services to users

  • To enable access to the Services and to use the proposed functions
  • To customize the experience on the interface

Execution of a contract (the General Terms and Conditions of Use or « GTCU »). Consent of the user: to activate the geolocation functions


Management of the user accounts

  • To create the user account and to secure the access to the services
  • To process requests and complaints
  • To communicate with users
  • To intervene in case of non-compliance with the general terms and conditions of use and the principles of ethics
Execution of a contract (the GTCU). Legitimate interest: to make the users more familiar with the products and services of Fluicity in order to improve their user experience

Services to client organizations

  • To provide aggregated data on the engagement of the users and results of the consultations
  • To target communications to the users in accordance with  criteria established by the organization
  • To authenticate the identity / addresses of the participants to consultations
  • To provide live data on the users
Execution of a contract (the contract concluded between Fluicity and its client organizations). Legitimated interests of Fluicity: provide aggregated data and communication tools which are useful to  client organizations. Consent of the user: before the authentications of identity / addresses; before the supply to client organizations of  live data concerning users.

Improvement of the services

  • To elaborate statistics on the use of our Services
  • To measure the satisfaction, quality, as well as the improvement of the Services
  • To develop new functionalities
Legitimate interests of Fluicity:  statistics, measurements of satisfaction and quality, etc. To contribute, in particular, to the improvement of the products and services of Fluicity, to improve the user experience, and to generate innovations. In general, this contributes to the promotion of the social, economic and financial interests of Fluicity and benefits to all stakeholders.

Acquisition of new users

  • To present the Services to potential users
  • To identify these potential users in order to be able to present them the Services
Legitimate interest (to develop the user base of the  platform)

6. Do we collect your geolocation data ?

We, sometimes, propose that you tell us your exact geographical position. At the moment of the creation of your account, this information allows us to propose to you the most relevant participatory spaces for you. We also give you the opportunity to geolocate your ideas or messages, in order to contextualize them.

The data that we collect include your GPS coordinates and the IP-address of the used terminal. You can disable this service, at any time,  from your smartphone, tablet, portable computer.

7. To whom are your Data transmitted ?

Your Data are intended for:

  • The authorized services and persons of Fluicity;
  • Other users to whom you communicate data voluntarily;
  • The services providers of Fluicity acting as subcontractors;
  • Our client organizations, only if you consent to it.

When you communicate through our Services, the information you have mentioned in your public profile (such as your last name and first name, your photo) can only be seen by the person with whom you communicate. It should, nevertheless, be noted that when you take part in surveys, your identity is not unveiled to the organizations who prepare the surveys and the persons who take part in them.

However, the data can be communicated to any authority which is legally authorized to take note of them, in particular in case of a judicial request by the judicial, police or administrative authorities.

8. How long do we keep your Data ?

Fluicity keeps your data during the use of the Services, as long as you have a user account. Please note that after 36 months of inactivity, and without any reply to a reminder from us, we will cancel your account.

The data of cancelled accounts can be subject to an intermediary filing during a term of 10 years in order to safeguard our rights in the event of a dispute.

9. Where do we store our databases ?

Our production base is stored on the servers of our subcontractor which are located necessarily in the territory of the European Union.

Fluicity ensures that the security and privacy policies of the service providers with whom it works are in line with the present Privacy Policy in order to guarantee the security of your Data.

10. What are your rights concerning your Data ?

You have the following rights, under the conditions established by applicable law: the right to access all your Data, the right to correction or deletion of, the right to object, the right to restrict and the right to portability. You also have the right to define the guidelines relating to the storage, deletion and disclosure of your data after your death.

You may exercise these rights or ask any question relating to your Data and their processing by writing to us at the following e-mail-address: or by letter at the following address: in France – Fluicity SAS, 53, rue du Caire, 75002 Paris, France or in Belgium – 523, avenue Louise, 1050 Brussels.

To ensure the  confidentiality and protection of personal data, we have to ascertain the identity of the user before replying to his/her question; please add a signed copy of your identity document.

Moreover, you can also directly and through your personal space:

  • Cancel the non-compulsory data; and
  • Visualize, modify, rectify, update the data that you have communicated (with the exception of the information notified to Fluicity through a third party identification module, such as Facebook, Twitter, G+ or Itsme).

You can also cancel your account by addressing to us a request at the following address:

Finally, you have the right to file a complaint with the competent supervisory authority.

11. Which analysis tools/cookies do we use ?

When you use the Services, cookies can be installed automatically on your browser software and terminal. The cookies are data blocks which are used to register information relating to your navigation and use of the Services. Fluicity uses the cookies listed below in order to analyze the way you use the Services and to be able to provide you with personalized  Services and to improve the relevance of the information which is proposed to you. Fluicity also uses the sharing buttons enabling you to share the content of the Services on the other existing social networks.

  • Technical/strictly necessary cookies

These are cookies which are essential for the operation of the Application and Website, they enable you to navigate seamlessly on the Application and the Website, and to use its functions . When you are connected, these cookies allow us to identify yourself (sessions cookies), to propose and show you the good/relevant information and to personalize your experience.

  • Statistical / analytical cookies (Amplitude. com, provided by Amplitude)

These cookies allow us to recognize and count the number of visitors and to see their surfing behavior when they use the  Application and the Site. This helps us to improve your user experience, navigation and enables you to find more easily what you are looking for.

  • Ad serving cookies (Facebook, Google, LinkedIn)

Cookies from our advertising partners can be activated on our Website and Application. They allow us to advertise our Services on the websites or applications of third parties after you have consulted our Website or Application (« retargeting »). They also enable our advertising partners to set up a profile of your interests on the basis of your navigation, in order to send you targeted advertisements.

  • Performance cookies

These cookies obtain the information relating to the way you use Fluicity. They allow us to understand how you interact with Fluicity, the possible causes of some mistakes, and enable us also to test new functions. We only use this information to improve the performance of Fluicity.

  • Functional cookies

These cookies allow for the activation of specific functions on Fluicity in order to improve your user experience, such as, for example, to remind you of your choices and preferences (such as the language) or to retain more complex information (such as the  location).

  • Security cookies

We use these cookies in order to activate and assist our security functions, but also to help us detect malicious activities and violations of our General Terms and Conditions of Use.

With the exception of the so-called « essential » cookies, the installation of these cookies requires your express consent. In this respect, you acknowledge by continuing to surf on the Website, after having taken note of the cookies banner, that you have acknowledged and accepted the installation of the said cookies. Furthermore, the cookies can be disabled, at any moment, individually or totally, by modifying the appropriate settings of your browser. Nevertheless, this would prevent the application from accessing certain functions of the Services. You may manage, disable or allow cookies by modifying the settings of their Internet browser by consulting the links below:

Internet Explorer:





The use of the Website may entail the installation of some cookies placed by third parties (communication agencies, audience rating companies, social networks, YouTube, …) which are not monitored by Fluicity. The placement and use of cookies by third parties are subject to the privacy policies of these third parties.

12. Can you share content on the social networks ?

The Services integrate social plug-ins or sharing buttons of the main social networks (Facebook, Twitter, G+, Instagram). These plug-ins allow you to share and publish, through cookies on your profiles of these networks, content published within the framework of the Services (see above).

Only the members connected to such networks can benefit from these functions. If you are not connected to a social network, you will be asked to connect to the same in order to be able to interact with these plug-ins.

13. Which security measures have been implemented ?

In order to guarantee the security of your data, Fluicity takes all useful precautions, whether they are physical, logical, administrative or organizational, with regard to the nature of your data and the risks presented by the different data processing measures/tasks, to safeguard the security of the data and to prevent the risk that they may be garbled, damaged or that unauthorized third parties may gain  access to them.

In this respect, we use an encryption protocol of the SSL type for the transmission of data between the terminals and  servers of our service providers and provide a framework for and manage the accesses to your information within Fluicity.

Moreover, the password of your login to access to the Services must, on a mandatory basis,  be comprised of, at least, 8 characters and contain a capital letter, number and special character.

14. And what about sites belonging to third parties ?

Links which are present on the Services can refer you to external websites. In this respect, you will note that the protection policies of the personal data of these websites can differ from the present policy. It is, thus, advised, in all cases, to take note of the personal data protection policy of each of the websites in question.

In any case, Fluicity cannot be held liable in the event that the content of one of the websites would be contrary to the legal and regulatory provisions in force.

15. Updates to the Privacy Policy

We reserve the right, at any moment, to change the present Privacy Policy, in particular, in line with the legal and regulatory context and the doctrine of the supervisory authorities (e.g. the Commission Nationale de l’Informatique et des Libertés (CNIL) in France, and the Commission de la Protection de la Vie Privée (CPVP) or the future data protection authority in Belgium). If the changes are important, we will notify you beforehand by e-mail or through a pop-up message on the Website and Application, so that you may consult the revised Privacy Policy before continuing to use the Services.

Last change: on November 8th 2019