Privacy Policy

1. Introduction

This privacy policy explains how FlexRule respects the privacy of information about you and upholds your rights to privacy under the key privacy laws in the European Union and United Kingdom (under the GDPR), California (under the CCPA) and Australia (under the Privacy Act), in each case to the extent applicable.

This policy does not apply to our personnel and job applicants. Please contact human resources for privacy details applicable in that case.

2. When does FlexRule collect personal information about me?

Most of the personal information we hold about you is provided to us directly by you (e.g. when you register on our website or as a user of our products, when you respond to a survey or promotion from us, at a presentation or conference, or if you contact us by email or otherwise).

In some limited instances we might obtain it indirectly, e.g. if somebody in your organization provides it to us.

3. What personal information about me does FlexRule collect?

The personal information we collect is as follows (although we might not collect all of the following items in relation to you):

We do not collect any sensitive information (i.e. racial or ethnic origin, political opinions, political or occupational memberships, religious or philosophical beliefs or affiliations, sexual beliefs or practices, criminal record, health or genetic or biometric information, identity card or passport or licence or other official identifier details, credit card or other financial account password or security code, GPS geolocation, or the contents of any mail or email or text message where we are not an intended recipient ).

We do not collect information from those under age 16.

Like many other websites, our website uses cookies. A cookie is information sent by our website to your browser that is then stored on your computer. It is used to identify your computer to us, and to remember previous requests you have made when you return to the website. This allows us to improve the functionality of the website during your visit and for return visits.

4. What does FlexRule do with my personal information?

We use your personal information:

• to assist with any enquiries you make with us or our help desk and support channels (e.g. portal, email);
• to verify your identity and assist you if you have forgotten or lost a user ID or password;
• to improve our products;
• for our internal administrative, marketing, planning, product development and research requirements;
• to assist in providing our products to you and others;
• to send you emails promoting our products, special offers or other information which we think you may find useful or interesting;
• to seek feedback from you about our products;
• for any other purpose made known to you at the time of collection of your personal information; and
• potentially, to protect our legal interests or in connection with a sale of our business or company

At any time you may opt out of receiving any communications from us (other than as necessary or desirable for the operation of our business, e.g. regarding the status of your account).

We do not undertake any automated decision making or profiling using your personal information.

5. Disclosure and sale of personal information

We do not disclose personal information about you to any person except:

• where we have your express permission to do so;
• to third parties who help us to provide our products or run our business (Service Provider). All disclosures to Service Providers are subject to us being satisfied about their reputation, and the Service Provider agreeing (amongst other things) to keep personal information confidential (including not using it for anything other than providing services to us) and comply with any applicable privacy laws. You can view our list of our main Service Providers here, including what types of information we provide to them;
• if required by law;
• if in our opinion it is necessary or desirable in order to protect the health or safety of any person (including you) or to prevent, report, or investigate the damage or destruction of any property or breach of any law;
• in order to enforce or apply our terms and conditions or to protect the rights, property, or safety of FlexRule, our personnel, customers or users (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction); or
• in connection with a sale or proposed sale of FlexRule, or substantially all of its assets, to a third party, in which case we will ensure that any personal information about you that we disclose is protected by suitable constraints on use and disclosure

We do not sell your personal information to any third party.

6. Withdrawing my consent

Our use and disclosure of your personal information is based upon either or both of the following lawful bases:

• You have consented; and
• Our legitimate interests (as described in section 4 above)

Where you have consented, you have the right to withdraw your consent at any time by contacting us at the address below.

Please note that if you do not provide some personal information, or withdraw your consent for us to use it, then we may be unable or unwilling to provide one or more of our products to you. For example, without name, contact and organisation details it may be impractical for us to provide our products to you.

7. Storage and security

We hold most personal information electronically (and to a lesser extent in hard copy form), primarily on secure servers in Australia and the United States, operated by one or more of our Service Providers (referred to in this table ).

We treat the security of the personal information that we hold seriously. Where it is held in electronic form we take reasonable steps to protect it, including by internal and external security and restricting access within our organisation to personal information to those who have a need to know. We implement and maintain technology to protect against unauthorised computer access and regularly review our technology to maintain security.

8. Overseas transfer

FlexRule is based in Australia, so when you provide information to us it is collected by us in Australia. We do not disclose personal information to any recipient outside Australia, to our Service Providers (subject to the protections indicated in section 5 above) in order for them to provide their services to us. They are located in the countries indicated in this table.

9. Access and correction

You have the right to request access to personal information we hold about you at no cost (unless we notify you otherwise), and may do so by writing to us at the address below. Please provide sufficient detail about the information in question to help us locate it. We will provide an acknowledgment of receipt within 10 business days of receiving your request.

Except where we have reasonable grounds for refusing (e.g. disclosure would breach the law or would involve disclosing personal information about someone else), within one month of receipt of your request we will provide you with access. If we refuse your request then we will give you a written statement setting out the reasons for the refusal (unless unreasonable to give them), and the process we provide if you wish to complain about the refusal.

We will provide access in the form you request if it is reasonable and practicable to do so or if that form is required by law. Otherwise we will endeavour to provide you with a reasonable form of access.

You have the right to request correction of personal information that we hold about you if you think it is inaccurate. If you believe that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, then you may request amendment of it by writing to us at the address below. We will consider your request and respond to you within one month of receipt of your request. If we do not agree with the amendment, then we will add a note to the personal information stating that you disagree with it and will also give you a written statement setting out the reasons for the refusal (unless unreasonable to give them), and the process we provide if you wish to complain about the refusal.

In some circumstances you have the right to require that we transfer your personal information to you or another organisation in a standard format (i.e. data portability).

10. Deletion

We will delete or de-identify personal information that we hold about you when any of the following occurs:

• When requested by you, unless by law we may retain it for a further period – and in either case we will provide an acknowledgment of receipt within 10 business days of receiving your request and will notify you within one month of receipt of any action taken;
• When it is no longer needed for any purpose for which we may use it; or
• Automatically up to 7 years after your last interaction with us or our products

In some circumstances you can object to us using your personal information.

11. Our contact details

Our contact details are:

Email: privacy@FlexRule.com
Website: https://www.FlexRule.com

We may require reasonable authentication of your identity in connection with any request to us, but will not require that you create an account with us to do so if you do not already have one. To assist us with authentication, please include all your known identifier details (as listed in section 3 above) when you contact us.

We will not discriminate against you for exercising any of your rights described in this policy.

12. Complaints

Any questions about this policy, or any complaint regarding treatment of your privacy, should also be made by mail or email to the address above.

If you lodge a complaint, we will let you know the name of the individual responsible for taking care of it, and will tell you when we will provide a full response.

If we do not resolve a complaint to your satisfaction then we encourage you to contact us to explain why, or you may raise your complaint with the relevant regulator (including the following, if applicable):

(Australia)
Office of the Australian Information Commissioner (OAIC)
Use any of the following contact details or the privacy complaint form on the OAIC website (www.oaic.gov.au/privacy):
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Mail: GPO Box 5218, Sydney NSW 2001

(United Kingdom)
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk

13. Miscellaneous

In this policy:

including means “including but not limited to”.

FlexRule means FlexRule Pty Ltd (ABN 97 614 968 919), being an Australian company, and its subsidiaries and other related bodies corporate.

personal information means information or an opinion about an identified individual or household, or an individual or household that is directly or indirectly identifiable.

products means the goods, services and other products (including software) that we provide.