ZenPass is now Fluum !

Learn more

Fluum Data Protection Addendum

Effective Date: August 1st, 2025

1. Introduction

This Data Protection Addendum ("DPA") outlines the data protection policies and procedures for Fluum, distinguishing between Solopreneurs, their Clients, and Fluum Clients. This addendum supplements the Fluum Terms of Service and Privacy Policy and is designed to ensure compliance with applicable data protection laws.

2. Definitions

  • "Fluum" refers to the Fluum platform, including both the Business Software and the Marketplace. Fluum is the trading name of ZENPASS Ltd, a company registered in England and Wales (Company No. 15193625).
  • "Solopreneur" refers to individuals or entities providing services through Fluum, including but not limited to coaches, therapists, trainers, and wellness professionals.
  • "Solopreneur Clients" refers to all clients imported or newly added by Solopreneurs. These Clients are only available to paid subscribers on the GROW or PRO plan.
  • "Fluum Clients" refers to End Users who engage directly with the Fluum Marketplace or interact with Solopreneurs using the Business Software across any plan.
  • "Business Software" refers to the suite of tools and services provided by Fluum that enable Solopreneurs to manage their business, including scheduling, payments, client management, and communication features.
  • "Data Protection Laws" means:
    • in the European Union, the General Data Protection Regulation 2016/679 (the "GDPR"), and
    • in the UK, the UK General Data Protection Regulation 2016/679, as implemented by the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 and the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 (the "UK GDPR"), the Data Protection Act 2018, and the Privacy and Electronic Communications Directive 2002/58/EC (as the same may be superseded by the Regulation on Privacy and Electronic Communications,("ePrivacy Regulation")).
  • "Personal Data" refers to any information that relates to an identified or identifiable individual, in accordance with applicable data protection laws.

3. Data Roles & Responsibilities

3.1 Fluum as a Data Processor & Controller

Fluum acts as both a Data Controller and Data Processor, depending on the relationship:

  • For Fluum Clients, Fluum is the Data Controller and determines the purposes and means of processing personal data.
  • For Solopreneurs Clients, Fluum acts as a Data Processor on behalf of the Solopreneur, who remains the Data Controller.

3.2 Solopreneurs as Independent Data Controllers

Solopreneurs are responsible for ensuring their own compliance with applicable data protection laws regarding their Clients’ personal data. Fluum does not control how Solopreneurs collect, store, or process data outside of the platform.

4. Data Collection & Processing

4.1 Solopreneur Clients

  • Available only to paid subscribers.
  • Solopreneurs collect personal data & consent directly from their Clients.
  • Fluum only processes Solopreneur Client data as required to provide the Business Software platform to Solopreneurs and facilitate transactions between them and their Clients.
  • Solopreneurs must obtain necessary consent from their Clients.

4.2 Fluum Clients

  • Fluum collects and processes personal data directly from Fluum Clients for purposes including account management, billing, marketing, and service delivery.
  • Fluum is responsible for maintaining transparency and security of Fluum Client data.

5. Data Security & Confidentiality

Fluum implements appropriate technical and organizational measures to protect all personal data, including but not limited to:

  • Encryption of sensitive data
  • Access controls and authentication measures
  • Data minimization principles
  • Compliance with Data Protection laws

Solopreneurs are responsible for ensuring the confidentiality and security of their Clients' data within their own operations.

6. Data Subject Rights

Fluum and Solopreneurs must uphold the rights of data subjects, including:

  • Right to Access – Clients can request access to their personal data.
  • Right to Rectification – Clients can request corrections to inaccurate data.
  • Right to Erasure – Clients can request data deletion, subject to legal and contractual obligations.
  • Right to Data Portability – Clients can request their data in a portable format.
  • Right to Object & Restrict Processing – Clients can restrict or object to data processing under specific circumstances.

For Solopreneur Clients, data subject rights requests must be handled by the respective Solopreneur unless the request relates to Fluum’s processing activities.

7. Data Retention & Deletion

  • Solopreneur Clients: Fluum retains minimal data necessary to facilitate Marketplace & Business Software services but does not control Solopreneur Client data retention policies. Only available for GROW and PRO subscribers.
  • Fluum Clients: Fluum retains data as required for service provision, legal compliance, and security purposes.
  • Upon account closure or service termination, Fluum will delete personal data, except where retention is required by law.

8. Third-Party Processors

Fluum engages third-party service providers (e.g., payment processors, analytics services) who may process personal data on our behalf. These third parties are required to comply with data protection regulations and contractual obligations.

Solopreneurs who engage third-party processors for their own Clients’ data must ensure those processors comply with relevant legal requirements.

9. International Data Transfers

Fluum may process data globally. Where applicable, we ensure appropriate safeguards, such as Standard Contractual Clauses (SCCs), are in place for cross-border data transfers.

10. Breach Notification

Fluum and Solopreneurs must promptly report any data breaches affecting personal data.

  • Fluum Clients will be notified by Fluum if their data is compromised.
  • Solopreneurs Clients will be notified by the respective Solopreneur, unless the breach is related to Fluum systems.

11. Compliance & Changes to this DPA

Fluum reserves the right to update this DPA as needed to maintain compliance with evolving regulations. Solopreneurs are responsible for staying informed about data protection laws relevant to their services.

For questions or concerns regarding data protection, please contact Fluum Data Protection Officer at contact@fluum.ai.

By using Fluum, Solopreneurs and Clients agree to comply with this Data Protection Addendum.

Copyright © 2025 Fluum is the trading name of ZenPass LTD . All rights reserved.