Cookies and Similar Technologies Policy

Effective Date: May 11, 2026

Last Revised: April 14, 2026

The websites, logged-in training products, learning management system(s), credentialing pages (including directories), and mobile applications operated by Fluence International, Inc. (“Fluence,” “we,” “us,” or “our”) are our “Services.” This Cookies Policy explains how Fluence uses cookies and similar tracking technologies (including pixels, SDKs, and device identifiers) within the Services. 

This Cookies Policy should be read together with our Terms of Use and Privacy Notice (the “Privacy Notice”): 

For purposes of the EU/EEA/UK data protection laws, Fluence is the controller of personal data collected through cookies and similar technologies on Fluence-controlled Services. Our contact details are in Article 11. Where a partner controls the relevant website/app surface or decides which cookies are deployed, that partner may act as controller for its cookies (see Article 7).

Article 1: What Are Cookies and Similar Technologies?

Cookies are small text files stored on your browser or device when you visit a website. Cookies help websites and applications recognize your device and remember information about your visit and activity.

We and our service providers may use cookies and similar technologies, including:

• Cookies (first-party and third-party; session and persistent);

• Pixels / web beacons and tags;

• SDKs (software development kits) in mobile apps;

• Local storage (such as browser storage);

• Device identifiers and app identifiers (such as advertising IDs, where enabled).

Article 2: Why We Use These Technologies

We use cookies and similar technologies to:

• operate and secure the Services;

• enable core functionality (such as login and account access);

• remember preferences and settings;

• analyze traffic and usage to improve the Services;

• detect fraud and prevent abuse;

• support communications and marketing; and

• where permitted and enabled, deliver and measure advertising and personalize content.

When these technologies involve the processing of personal data, we process that data in accordance with our Privacy Notice and applicable law. In the EEA/UK, non-essential cookies (including analytics, advertising/targeting, and most functional cookies) are used only with your consent.

Article 3: Categories of Cookies We Use

Fluence is growing and changing, so the categories of cookies we use may change over time. As of the Effective Date, Fluence may use cookies and similar technologies in the following categories:

3.1. Strictly Necessary Cookies

These technologies are required to operate the Services and cannot be disabled in systems where they are essential. They help with:

• authentication and session management;

• security and fraud prevention;

• load balancing and network management;

• saving your cookie preference choices.

3.2. Functional Cookies

These technologies help the Services remember your selections and preferences, such as:

• language and regional preferences;

• display preferences;

• remembering non-security settings.

3.3. Performance and Analytics Cookies

These technologies help us understand how users interact with the Services, such as pages visited, time spent, clicks, feature usage, and error events. We use this information to improve user experience, reliability, and performance.

3.4. Advertising / Targeting Cookies (If Used)

If Fluence engages in targeted advertising or cross-context behavioral advertising (as described in the Privacy Notice), these technologies may be used to:

• deliver ads that are more relevant;

• measure ad effectiveness;

• limit the number of times you see an ad; and

• help prevent fraud in advertising.

If we do not use advertising cookies in a particular Service or deployment, this category may not apply to that context.

3.5. Cookie Details (Name, Provider, Purpose, and Retention)

We provide a current list of the cookies and similar technologies used on each Service (including cookie name, provider, category, purpose, and typical retention period) in our cookie preference center which can be found in the footer of the Fluence Webpage. If you cannot access the preference center, you may request the list using the contact details in Article 11.

Article 4: Your Choices: Consent, Opt-Outs, and Controls

4.1. Cookie Banner and Preference Center

Where required by law (such as in the EEA/UK), we will request your consent before placing non-essential cookies (including many analytics and advertising technologies). In the EEA/UK, we do not set non-essential cookies unless and until you have provided consent through our cookie banner or preference center.

You can change your cookie choices at any time by using:

• our cookie banner / preference center linked in the footer of the Fluence Webpage: or

• your account or app settings (if available).

Withdrawing consent will not affect the lawfulness of processing based on consent before it is withdrawn.

If you reject non-essential cookies, we will continue to set strictly necessary cookies to provide the Services.

4.2. Browser and Device Controls

Most browsers allow you to delete or block cookies and to control certain tracking technologies. Your mobile device settings may also let you limit ad tracking or reset your advertising ID. If you disable cookies, some features of the Services may not function properly.

4.3. Do Not Sell/Share; Targeted Advertising Opt-Outs (U.S. States)

Depending on your state of residence and our data practices, you may have the right to opt out of:

• targeted advertising; and/or

• the sale or sharing of personal information (as those terms are defined by applicable state privacy laws).

Where applicable, you may exercise those rights by clicking HERE.

4.4 Global Privacy Control (GPC)

Some browsers and extensions provide a Global Privacy Control (GPC) signal. Where required by law or where we choose to honor GPC, we will treat a valid GPC signal as a request to opt out of certain processing (such as sale/sharing and targeted advertising) for the browser/device that sends the signal. If you use multiple browsers or devices, you will need to set the signal on each.

4.5. EEA/UK: Legal Bases (GDPR)

In the EEA/UK, our legal bases for processing personal data collected through cookies and similar technologies are:

• Strictly Necessary cookies: our legitimate interests in delivering and securing the Services and/or performance of a contract (where applicable).

• Functional, Analytics, and Advertising/Targeting cookies: your consent (Article 6(1)(a) GDPR), except where a cookie is strictly necessary for a service you explicitly request.

For more information about the personal data we process, recipients, international transfers, and your rights, see our Privacy Notice.

Article 5: How Long Cookies Stay on Your Device

Cookies may be:

• Session cookies, which expire when you close your browser; or

• Persistent cookies, which remain for a defined period or until you delete them.

Retention varies depending on purpose and will not exceed what is reasonably necessary for the purposes described in this Cookies Policy, unless a longer period is required or permitted by law.

Where available, the retention (or expiry) for each cookie is described in the cookie list in our preference center linked in the footer of the Fluence Webpage.

Article 6: Cookies Set by Third Parties

Some cookies and similar technologies may be set by third parties that provide services to Fluence (for example, hosting, analytics, communications, payment processing, or advertising partners). These third parties may collect information about your online activities over time and across different websites or online services.

Third-party use of information is governed by their own privacy policies. Fluence is not responsible for third-party cookie practices.

Where appropriate, Fluence will maintain a list of key third-party cookie providers in the cookie preference center or within the Services.

Where third parties act as our processors (for example, analytics or hosting providers), they process personal data on our instructions and are subject to appropriate contractual protections. Where third parties act as independent controllers (for example, certain advertising/measurement partners), their processing is governed by their own terms and notices.

Article 7: Cookies in Partner or Embedded Environments

If you access Fluence Services through a partner (for example, via an employer, program sponsor, training provider, platform partner, or SSO-enabled environment), cookie placement and controls may differ depending on the integration. Where Fluence controls the relevant domain or app surface, this Cookies Policy applies.

Where a partner controls cookies on its own systems or domains, the partner’s cookie policy and settings may also apply.

In embedded, integrated, or white-labeled deployments, responsibility for obtaining consent and providing cookie notices may be allocated between Fluence and the partner depending on which party controls the relevant cookies/trackers and the user interface. Where required by law, you will be provided a way to access cookie choices within the relevant experience.

Article 8: Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect information collected through cookies and similar technologies. However, no method of transmission or storage is completely secure.

Article 9: Biometrics

If we collect, capture, purchase, receive through trade, or otherwise obtain biometric identifiers or biometric information (as those terms are defined under the Illinois Biometric Information Privacy Act, 740 ILCS 14/1 et seq. (“BIPA”)) from individuals located in Illinois in connection with the Services, we will do so only in accordance with BIPA and this section.

9.1. Notice and Written Release

Before collecting or otherwise obtaining any biometric identifier or biometric information, we will provide you (or, where applicable, your legally authorized representative) with a written notice that:

(a) informs you that a biometric identifier or biometric information is being collected or stored;

(b) informs you of the specific purpose(s) and length of time for which the biometric identifier or biometric information is being collected, stored, and used; and

(c) requests and obtains your written release (which may be provided electronically), as required by BIPA.

9.2. Purpose Limitation and No Sale

We will use biometric identifiers and biometric information only for the purpose(s) disclosed in the notice described above and will not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information.

9.3. Disclosure Restrictions

We will not disclose, redisclose, or otherwise disseminate biometric identifiers or biometric information to any third party except:

• with your consent (or the consent of your legally authorized representative);

• to complete a financial transaction you request or authorize;

• as required by state or federal law, or pursuant to a valid warrant or subpoena; or

• to our service providers who process such data on our behalf for the disclosed purpose(s) under a written contract that includes appropriate confidentiality and security obligations.

9.4. Retention and Destruction

We will retain biometric identifiers and biometric information only until the first to occur of:

• the satisfaction of the initial purpose for collecting or obtaining the biometric identifier or biometric information; or

• three (3) years after your last interaction with the Services,

and we will permanently destroy such data in accordance with BIPA.

9.5. Security Standard

We will store, transmit, and protect biometric identifiers and biometric information using a reasonable standard of care within our industry and in a manner that is the same as or more protective than the manner in which we store, transmit, and protect other confidential and sensitive information.

9.6. Additional Choices and How to Contact Us

If a biometric feature is optional, you will be offered a choice to enable or decline that feature without affecting your ability to access core Services, except to the extent the biometric feature is necessary to provide a Service you explicitly request.

For questions about our biometric practices or to exercise applicable rights, contact us at: info@fluencetraining.com or HERE.

Article 10: Updates to This Cookies Policy

We may update this Cookies Policy from time to time. If we make material changes, we will provide notice by updating the “Last Updated” date and, where required by law, by providing additional notice and/or obtaining consent.

Article 11: Contact Us

If you have questions about this Cookies Policy or how we use cookies and similar technologies, please contact us at:

Email: info@fluencetraining.com

Webform: HERE

Mail: Fluence International, Inc.

ATTN: Data Use & Privacy Policy 

132 West 169th St #3B

Bronx, NY 10452