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):
Username and password
Internet protocol address used
|Customer records:||Telephone number(s)|
Any additional information provided to our service centre
Any information you provide to us through customer surveys
|Commercial information:||Transaction details associated with your purchases from us|
|Internet activity:||Analytical data about your use of our products, which we use solely for the purposes of improving our products|
|Visual or audio:||Your user image or avatar|
Video recordings of presentations by you
Testimonials by you, whether in written or video form
|Professional or employment:||Role title|
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.
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).
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:
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.
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):
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
Mail: GPO Box 5218, Sydney NSW 2001
Information Commissioner’s Office
Cheshire SK9 5AF
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk
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.
14. Changes to this policy
We may change this policy from time to time, with or without prior notice to you, by posting the updated version on our website.
This policy was last updated: 30 June 2021.
OUR SERVICE PROVIDERS
|Service Provider||Country||Service provided to us by them||Categories of personal information we share with them|
|ActiveCampaign||Illinois, United States|
|Email marketing, marketing automation||Identifiers, Visual or audio, Professional or employment|
|Tracking product development, team and project collaboration||Identifiers, Commercial information, Customer records|
|AWS||Washington, United States|
|Cloud storage provider||Identifier, Professional or employment, Internet activity|
|Google Workspace||California, United States|
Google Workspace | Business Apps & Collaboration Tools
|Productivity and collaboration tools||Identifiers, Customer records, Commercial information, Professional or employment|
|Hubspot||Massachusetts, United States|
|Customer relationship management platform||Identifiers, Customer records, Commercial information, Professional or employment|
|California, United States|
|Social media platform||Identifier, Professional or employment, Internet activity|
|Microsoft Azure||Washington, United States|
|Cloud storage provider||Identifier, Professional or employment, Internet activity|
|Slack||California, United States|
|Business communication platform||Identifiers, Customer records|
|California, United States|
|Social media platform||Identifiers, Visual or audio|
|Zendesk||San Francisco, California, United States|
|Customer Service platform||Identifiers, Customer records, Professional or employment, Internet activity|
|Zoom||California, United States|
|Video teleconferencing software||Identifiers, Visual or audio, Professional or employment|
We are committed to safeguarding your privacy. Contact us at if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
We/us (either capitalized or not) – FlexRule Pty Ltd
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
Information you have provided us with
This might be your e-mail address, first and last name, etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your IP address, your page view history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
Publicly available information
We might gather information about you that is publicly available.
How we use your Personal Data
We use your Personal Data in order to:
- provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your customer experience;
- fulfill an obligation under law or contract;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a service or to send/offer you a product;
- to communicate either for sales or invoicing;
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- to send you personalized offers* (from us);
- to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires concerning client satisfaction;
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and campaign offers (from us);
- for other purposes we have asked your consent for;
We Process your Personal Data in order to fulfill obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law, but not longer than.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience.
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe. We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Last modification was made 23/05/2018.