Privacy Policy

Last updated: July 23, 2026

Fluid Mobility Inc. (“Fluid Mobility,” “we,” “us” or “our”) is committed to maintaining the accuracy, confidentiality and security of Personal Information entrusted to us.

This Privacy and Security Policy explains how we collect, use, disclose, retain and safeguard Personal Information. It is based on the fair information principles established under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian Standards Association’s Model Code for the Protection of Personal Information.

For the purposes of this Policy, “Personal Information” means information about an identifiable individual.

1. Accountability

Fluid Mobility is responsible for Personal Information under its control. We have designated a Privacy Officer who is responsible for overseeing compliance with this Policy and applicable privacy requirements.

2. Identifying Purposes

Fluid Mobility may collect, use and disclose Personal Information for purposes including:

• Providing, supporting and administering requested products and services.
• Processing orders and managing customer accounts.
• Communicating with customers and responding to inquiries.
• Providing technical and customer support.
• Protecting the security and integrity of our systems and services.
• Meeting legal, regulatory and contractual obligations.
• Providing information about additional products or services where permitted by law and with any required consent.

The purposes for collecting Personal Information will be identified before or at the time the information is collected. In some circumstances, the purpose may be reasonably understood, such as when a customer provides their name, contact information and payment information as part of an order or service request.

3. Consent

Knowledge and consent are required for the collection, use or disclosure of Personal Information, except where otherwise required or permitted by law.

Providing Personal Information is generally your choice. However, choosing not to provide certain information may limit our ability to provide requested products or services.

We will not require consent to the collection, use or disclosure of Personal Information as a condition of providing a product or service, except where the information is reasonably necessary to provide that product or service or where otherwise permitted by law.

4. Limiting Collection

We limit the collection of Personal Information to what is reasonably necessary for the purposes identified by Fluid Mobility.

Depending on your interactions with us, we may collect Personal Information in person, by telephone, through email, through our website, through customer-support channels or through the use of our products and services.

5. Limiting Use, Disclosure and Retention

Personal Information will only be used or disclosed for the purposes for which it was collected, unless an individual provides additional consent or the use or disclosure is required or permitted by law.

Personal Information will only be retained for as long as reasonably necessary to fulfill the identified purposes, satisfy contractual requirements or meet legal and regulatory obligations. Information that is no longer required will be securely deleted, destroyed or anonymized in accordance with Fluid Mobility’s retention practices.

6. Accuracy

Fluid Mobility takes reasonable steps to maintain Personal Information in an accurate, complete and up-to-date form as necessary for the purposes for which it is used.

Individuals are encouraged to contact us if they believe their Personal Information should be corrected or updated.

7. Safeguarding Personal Information and Customer Data

Fluid Mobility uses administrative, technical and organizational safeguards appropriate to the sensitivity of the information under its control. These safeguards are designed to protect Personal Information and customer data against loss, theft, unauthorized access, use, disclosure, alteration or destruction.

7.1 Encryption

Personal Information and customer data transmitted between supported applications, services and Fluid Mobility’s production environments are protected using TLS 1.2 or higher.

Customer data stored within Fluid Mobility’s in-scope AWS production systems and backups is encrypted at rest using AWS-supported encryption capabilities. Access to encryption and key-management functions is restricted to authorized personnel.

7.2 Logical access controls

Access to production systems, administrative functions and customer data is restricted to authorized personnel based on job responsibilities, least-privilege and need-to-know principles.

Fluid Mobility’s logical access practices include:

• Unique user accounts and role-based permissions.

• Management approval for access requests.

• Multi-factor authentication for privileged administrative access where supported.

• Periodic reviews of user and privileged access.

• Logging and monitoring of administrative and security-relevant activities.

• Revocation of access within one business day following employee or contractor termination.

7.3 Security monitoring and incident response

Fluid Mobility maintains documented vulnerability-management and incident-response procedures. System events, administrative activities and identified security concerns are logged, monitored and assessed based on risk.

Fluid Mobility performs periodic vulnerability assessments, security testing and reviews of relevant technical controls. Suspected security incidents are documented, investigated and escalated in accordance with established incident-response procedures.

Where required by applicable law, Fluid Mobility will notify affected individuals, customers, regulators or other appropriate parties of a confirmed privacy or security breach.

8. Openness

Fluid Mobility makes information available about its policies and practices concerning the management and protection of Personal Information.

Additional information about our privacy and security practices may be requested by contacting the Fluid Mobility Privacy Officer.

9. Individual Access

Upon written request, an individual will be informed of the existence, use and disclosure of their Personal Information and will be provided with access to that information, subject to applicable legal restrictions.

Individuals may verify the accuracy and completeness of their Personal Information and request that it be corrected where appropriate.

In certain circumstances permitted by law, Fluid Mobility may be unable to disclose some or all of the requested information. For example, information may be withheld where it references another individual or is subject to legal, security or commercially confidential restrictions. Where permitted and appropriate, Fluid Mobility will explain the reason access was denied.

Fluid Mobility may take reasonable steps to verify an individual’s identity before responding to an access or correction request.

10. Privacy Complaints, Security Concerns and Inquiries

Questions, complaints or inquiries regarding this Policy or Fluid Mobility’s privacy and security practices may be submitted through the Get in Touch form on the Fluid Mobility website or by contacting:

Privacy Officer: Jesse Duggan
Email: jesse.duggan@fluid-mobility.com
Phone: +1 647-347-6216
Mailing address: [Insert Fluid Mobility business mailing address]

Security concerns submitted through the Get in Touch form are routed to designated Fluid Mobility personnel and retained in the company’s monitored email or ticket queue. Reported concerns are documented, reviewed and escalated under Fluid Mobility’s security-incident process where appropriate.

Fluid Mobility will investigate privacy complaints and security concerns in a fair and timely manner and will take appropriate corrective action where warranted.

Additional Information

Cookies

A cookie is a small computer file or piece of information that may be stored on your device when you visit a website.

Fluid Mobility may use cookies to support website functionality, understand website usage and provide visitors with an improved experience.

Most web browsers are initially configured to accept cookies automatically. You may change your browser settings to prevent cookies from being accepted or to notify you before a cookie is stored. Disabling cookies may prevent certain portions of the Fluid Mobility website from functioning optimally.

Other Websites

The Fluid Mobility website may contain links to third-party websites that are not governed by this Policy.

Although we endeavour to link to websites with appropriate privacy and security practices, this Policy no longer applies after you leave the Fluid Mobility website. Fluid Mobility is not responsible for the privacy practices or content of third-party websites.

We encourage you to review the privacy policies of third-party websites to understand how they collect, use, disclose and protect Personal Information.