PRIVACY POLICY

Effective date: August 21, 2026

Fluent Empire (“Fluent Empire,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, store, protect, and disclose personal information when you visit our website, book or receive our services, attend a consultation or class, request translation or interpretation services, communicate with us, or otherwise interact with Fluent Empire.

We process personal information in accordance with the Data Protection Act, 2013 of Antigua and Barbuda and other applicable laws.

1. Information We Collect

Depending on your interaction with us, we may collect:

• Contact details, including your name, email address, telephone number, mailing address, and organization.

• Booking and service information, including consultation details, schedules, service requests, correspondence, and attendance records.

• Billing and transaction information, including billing addresses, payment confirmations, transaction identifiers, invoices, and payment status. Payment-card information may be processed directly by our payment provider rather than stored by Fluent Empire.

• Identity and document information, including passports, government-issued identification, certificates, immigration documents, educational records, and other materials submitted for translation, interpretation, verification, or related services.

• Sensitive information, including health, disability, accessibility, or learning information, when reasonably necessary to provide requested services or accommodations.

• Translation and interpretation materials, including source documents, translated documents, notes, terminology, and related correspondence.

• Photos, audio, video, meeting recordings, testimonials, or other media, where you provide them or give the required permission.

• Technical and usage information, including IP address, device and browser information, website activity, cookie identifiers, referral information, and analytics data.

• Corporate-client information, including the names, roles, contact information, and service records of employees, representatives, students, or participants connected with an organization.

We may receive this information directly from you, from a parent or guardian, from your employer or organization, from an authorized representative, or through service providers used to operate our website and services.

2. Why We Use Your Information

We may use personal information to:

• Respond to inquiries and communicate with you.

• Schedule and conduct consultations, meetings, classes, training, translation, interpretation, and other requested services.

• Prepare for meetings and research requests submitted in advance.

• Verify identity and review documents where necessary.

• Process bookings, payments, refunds where applicable, invoices, and accounting records.

• Provide accessibility, educational, or learning accommodations.

• Deliver translated or interpreted materials and maintain required service records.

• Operate, secure, troubleshoot, and improve our website and services.

• Measure website performance and understand how visitors use our website.

• Send service-related communications and, with any consent required by law, promotional communications.

• Prevent fraud, misuse, security incidents, or unlawful activity.

• Comply with contracts, court orders, regulatory requirements, tax obligations, and other legal duties.

• Establish, exercise, or defend legal rights and claims.

We process personal information with consent or when processing is reasonably necessary to provide requested services, take steps toward a contract, perform a contract, comply with a legal obligation, protect vital interests, or exercise functions permitted by law.

3. Information You Must Provide

Providing information is generally voluntary. However, certain information may be required to book or receive a service, process payment, verify identity, complete a translation, provide an accommodation, or satisfy a legal or contractual requirement.

If required information is not provided, we may be unable to accept a booking, complete the requested service, provide an accommodation, verify a document, or meet a legal requirement. We will not request more information than is reasonably necessary for the stated purpose.

4. Sensitive Personal Information

Health, disability, learning, and similar information may constitute sensitive personal information. We will collect or use such information only when reasonably necessary and when we have explicit consent or another basis permitted by law.

Please do not submit sensitive information unless we request it or it is necessary for the service. Where sensitive information relates to a minor or a person unable to provide legally valid consent independently, consent must be provided by an authorized parent, guardian, or representative.

5. Children and Students

Fluent Empire provides certain services to students of different ages. A minor may not independently submit personal information, book a service, authorize a recording, or provide sensitive information unless permitted by applicable law.

A parent or legal guardian must make or approve the booking and consent to the collection and use of a minor’s information where required. We may ask for information necessary to verify the adult’s identity, authority, or relationship to the minor.

If we learn that a minor’s information was collected without required authorization, we will take reasonable steps to restrict its use and delete it unless retention is required or permitted by law.

6. Payments

Payments may be processed through an independent payment provider. That provider may collect payment-card and billing information under its own privacy policy and security practices.

Fluent Empire may retain transaction confirmations, billing details, invoices, payment status, and other accounting information required to administer services, handle disputes, prevent fraud, or satisfy legal, tax, and financial-record obligations.

7. Meetings, Photos, and Recordings

Consultations or classes conducted through Zoom, Google Meet, or another meeting service may involve the processing of names, email addresses, profile information, chat messages, technical information, and meeting content by that provider.

We will not intentionally record a private consultation or class without notice and any consent required by law. Photos, recordings, or testimonials will not be used for advertising or public promotion without separate permission where required.

You should not record, photograph, publish, or distribute another participant’s personal information without appropriate authorization.

8. Cookies, Analytics, and Advertising

Our website may use cookies and similar technologies to operate essential functions, remember preferences, measure traffic, analyze performance, and support advertising.

Where consent is required, non-essential analytics or advertising technologies should not be activated until the visitor makes a choice. Visitors may manage available cookie preferences through our cookie banner or browser settings. Disabling certain cookies may affect website functionality.

9. How We Share Information

We do not sell or rent personal information.

We may disclose information only as reasonably necessary to:

• Website-hosting, email, booking, payment, analytics, advertising, cloud-storage, security, and technical-service providers.

• Zoom, Google Meet, and other communication providers used for consultations or classes.

• Translators, interpreters, instructors, contractors, or authorized personnel who require access to provide the requested service and are subject to appropriate confidentiality obligations.

• Professional advisers, including attorneys, accountants, auditors, and insurers.

• Government authorities, regulators, courts, law-enforcement bodies, or other parties where disclosure is required or permitted by law.

• A purchaser, successor, or adviser involved in a legitimate business transaction, subject to appropriate confidentiality and legal protections.

We require service providers handling information on our behalf to provide appropriate security and confidentiality safeguards. We do not authorize them to use personal information for unrelated purposes.

10. International Processing

Some service providers, including website, payment, analytics, email, Zoom, Google Meet, and cloud-service providers, may process information outside Antigua and Barbuda.

Where personal information is transferred or processed internationally, we will take reasonable steps to use reputable providers and appropriate contractual, organizational, and security safeguards consistent with applicable law.

11. Retention and Translation Records

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected or for an applicable contractual, accounting, tax, regulatory, court, immigration, professional, dispute-resolution, or other legal requirement.

Translation and interpretation records including source documents, completed translations, certifications, correspondence, and related records may be retained when necessary to complete the service, verify accuracy, issue replacement copies, respond to questions, comply with a contract or lawful authority, or establish, exercise, or defend legal rights.

We do not represent that every translation must be retained for the same period. The appropriate period depends on the document, service, recipient, contract, and applicable legal requirements. When information is no longer reasonably required, we will take reasonable steps to securely delete, destroy, or anonymize it.

Fluent Empire should maintain an internal retention schedule specifying the applicable period for each category of record.

12. Information Security

We use reasonable and appropriate technical and organizational measures designed to protect personal information from loss, misuse, unauthorized or accidental access, disclosure, alteration, or destruction.

These measures may include access restrictions, password controls, secure transfer methods, staff and contractor confidentiality requirements, software updates, backups, and appropriate safeguards when selecting service providers.

No website, email account, video platform, storage system, or internet transmission can be guaranteed to be completely secure. This statement does not limit any responsibility imposed on Fluent Empire by applicable law.

If we become aware of a security incident involving personal information, we will investigate and take steps required by applicable law and the circumstances.

13. Your Rights

Subject to the Data Protection Act, 2013 and any lawful limitations, you may request:

• Confirmation of whether we process your personal information.

• Access to personal information held about you.

• Information about the purposes, sources, and recipients of that information.

• Correction of information that is inaccurate, incomplete, misleading, excessive, irrelevant, or out of date.

• Deletion of information that is no longer required, subject to lawful retention requirements.

• Withdrawal of consent for future processing where processing depends on consent.

• Cessation of promotional emails by using the unsubscribe option or contacting us.

Requests must be made in writing. We may request reasonable proof of identity or authority before responding. Requests concerning a minor must be made by an authorized parent or guardian. We will respond within the period required by applicable law and may refuse or restrict a request where the law permits or requires us to do so.

14. Third-Party Websites

Our website may link to websites or services operated by other organizations. Their privacy practices are governed by their own policies. Fluent Empire does not control those independent services, but this does not limit any responsibility that applicable law places on us for providers processing information on our behalf.

15. Changes to This Policy

We may update this Privacy Policy to reflect changes in our services, practices, technology, providers, or legal obligations. The revised policy will be posted with an updated effective date.

Where a material change requires additional notice or consent, we will take reasonable steps to provide it.

16. Contact Us

Questions, complaints, consent withdrawals, and written requests to access or correct personal information may be sent to:

Fluent Empire
Email: info@fluent-empire.com
Location: Antigua and Barbuda
Business address: Fluent Empire

Please use the subject line “Privacy Request” and describe your request clearly. We may need to verify your identity or authority before disclosing or changing personal information.

If a privacy concern is not resolved, you may have the right to complain to the Information Commissioner of Antigua and Barbuda or pursue another remedy available under applicable law.

FLUENT EMPIRE