Effective Date: October 10, 2025
1. Introduction / Scope
Welcome to Fluent Capital / Fluent Advantage (the “Company,” “we,” “us,” or “our”). Your privacy is important to us. This Privacy Policy describes how we collect, use, disclose, and protect the personal information of users (“you,” “your”) in connection with your use of our websites (e.g. fluentadvantage.com, fluentcapital.ca) and related services (the “Site” or “Services”).
This Policy is intended to satisfy legal requirements in Canada (e.g. PIPEDA and applicable provincial laws) and the United States (federal and state privacy rules), to the extent applicable. If you are a visitor or user from another jurisdiction, local laws may also apply.
By using or accessing the Site or providing us with personal data, you accept the practices described in this Privacy Policy.
2. What Personal Information We Collect
We collect personal information that you voluntarily provide, as well as information collected automatically. Types include, but are not limited to:
Contact / identity information: name, email address, postal address, phone number, date of birth (if relevant), professional / investor status (e.g. accredited investor status)
Financial / investment information: in some cases, when you engage deeper (e.g. for investing), we may collect information such as net worth, financial assets, income, bank / payment details, KYC / accreditation documents
Usage & technical information: IP address, browser type, device type, pages visited, time stamps, referral URL, analytics data, cookies, tracking, clickstream
Communications: records of correspondence, emails, support tickets, surveys, feedback
Other information: any other information you choose to provide (e.g. free-form fields, comments, uploaded documents).
We only collect the personal information necessary for the purposes described below.
3. How We Use Personal Information
We use your information for the following purposes (and those reasonably related):
To provide, maintain, and improve our Site, services, and user experience
To respond to your inquiries, support requests, and communications
To send you marketing, newsletters, investment updates, event invitations (where permitted)
To administer webinars, events, onboarding, educational content
To evaluate eligibility for investment / participation in our debt fund or related opportunities
To comply with legal, regulatory, KYC / AML / accreditation checks
To analyze usage, monitor and improve performance, run analytics, detect fraud, protect security
To enforce our terms, protect rights, detect and prevent misuse or unauthorized access
Other purposes to which you expressly consent.
Unless restricted by law, we may combine or aggregate non-identifiable information for internal analysis, trends, and improvements.
4. Legal Basis / Consent (U.S. / States / Canada)
Canada: Under PIPEDA, we rely on your knowledge and consent for the collection, use, or disclosure of your personal information (except in limited circumstances where law allows). We collect only what is necessary, limit use/disclosure to the original purpose (unless you consent otherwise), keep data accurate, protect by safeguards, and provide openness about our practices. Privacy Commissioner of Canada+2OneTrust+2
United States / state laws: Where applicable, we rely on consent, contractual necessity, legitimate interests, or legal obligation, subject to applicable state privacy laws (e.g. California’s CCPA/CPRA, Virginia CDPA, etc.). In states that require explicit consent or opt-outs, we will comply accordingly.
If you withdraw consent, we may no longer be able to provide some services to you.
5. Disclosure / Sharing of Personal Information
We may share your personal information with:
Service providers / vendors / subcontractors: who help us run the Site, analytics, email delivery, CRM, payment processing, webinar platform, hosting, security, etc.
Affiliates / partners / joint ventures: where applicable and with your consent
Regulators / legal authorities: when required by law, court order, subpoena, or to protect rights, safety, or property
Successors / in connection with a merger, acquisition, sale, or reorganization: we may transfer your personal information as part of business transitions
Other users / public: when you publicly post content (e.g. in forums, chat) and it becomes visible
Anonymous / aggregated data: we may share de-identified or aggregated data that cannot reasonably identify you.
We require that third parties comply with adequate confidentiality and security standards, and use the data only for the purposes we authorize.
6. Cookies, Tracking & Analytics
We and our service providers use cookies, web beacons, pixel tags, local storage, session storage, and other tracking technologies to collect usage data, measure performance, deliver content and advertising, analyze traffic, and personalize your experience.
You may choose to disable cookies via your browser settings; however some features of the Site may not function properly if cookies are disabled.
We may also use third-party analytics (e.g. Google Analytics, etc.). Where applicable, we may utilize IP anonymization, opt-out options, or suppression if legally required.
7. Retention of Personal Information
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected (or as required by law, regulation, or legitimate business purpose). After that, we delete, anonymize, or securely destroy the information.
8. Data Security / Safeguards
We adopt reasonable technical, organizational, and administrative safeguards to protect against unauthorized access, disclosure, alteration, or destruction of personal information. Measures may include encryption, secure servers, access controls, regular audits, staff training, and monitoring.
However, no system is completely secure — we cannot guarantee absolute security. In the event of a breach, we will comply with applicable law regarding breach notification.
9. Access, Correction, Deletion, and Other Rights
You may, subject to applicable law:
Request access to your personal information that we hold
Request correction or amendment of inaccurate/incomplete information
Request deletion or anonymization (where permissible)
Withdraw consent (to future processing)
Object or restrict certain processing
Request a copy of the data (data portability)
Lodge a complaint with a supervisory authority (e.g. Privacy Commissioner of Canada, U.S. state regulator)
If you wish to exercise any of these rights, please contact us [insert contact method]. We may ask you to verify your identity before acting on a request.
10. Cross-Border / International Transfers
Because we operate in multiple jurisdictions, your personal information may be transferred to, stored, or processed in Canada, the U.S., or other jurisdictions with different privacy protections. By using the Site or consenting to this policy, you agree to such transfers, provided we ensure appropriate safeguards (e.g. contracts, standard clauses, encryption).
11. Minors / Age Restrictions
The Site is intended for users who meet the age of majority in their jurisdiction (e.g. 18+ or 19+). We do not knowingly collect personal information from minors without parental consent. If we become aware of such data, we will take steps to delete it.
12. Changes to This Privacy Policy
We may update this Policy from time to time. When changes are material, we will provide notice (e.g. via email or banner). Continued use after changes constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically.
13. Contact Information
If you have questions, requests, or complaints about this Policy or our practices, you can contact:
Fluent Capital/ Spark Financial / Michael Succurro
101A - 180 Bass Pro Mills Drive
Vaughan ON L4K 0B9
Phone: 416-303-9300