1. About this Policy
EnsureFlow Pty Ltd ACN 634 750 280 (“EnsureFlow”, “we” or “our”) is committed to protecting individuals’ privacy and complies with the PrivacyAct 1988 (Cth)(“Act”). EnsureFlow collects, uses, holds and discloses personal information in accordance with theAustralian Privacy Principles (“APPs”)contained in the Act.
EnsureFlow aims to provide users (“Users, “you” or “your”)of our website, as operated under the domain name ensureflow.com.au, and of our associated mobile phone or tablet applications (together the “Portal”) with information that meets their needs. To do so, EnsureFlow may collect personal information about you each time you visit or use thePortal.
Your use of the Portal acknowledges your agreement to and acceptance of both this Policy and of the terms and conditions of use of this Portal (“Terms”), which are available to download on our website (www.ensureflow.com.au).
EnsureFlow may modify, alter or otherwise change this Policy from time to time without notice to you. We encourage you to periodically review this Policy for changes. Your continued access to, or use of, the Portal means that you agree to and accept the changes we make to the Policy.
2. Collection of personal information
2.1 Personal information
Personal information is information or an opinion about an individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, or is recorded in a material form or not.
The types of personal information that EnsureFlow may hold include, but are not limited to, the following:
- mailing or street address;
- email address;
- telephone number and other contact details;
- date of birth or age;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of any services that you have booked through the Portal or of any enquiries you have made to EnsureFlow in relation to the Portal, including any responsive or additional information EnsureFlow has provided to you;
- any additional information relating to you that you provide to us directly through the Portal or indirectly through your use of the Portal, your online presence or through other Portals or accounts from which you permit us to collect information
- any information you provide to us through customer surveys; and
- any other personal information that may be required in order to facilitate your dealings with us.
2.2 When we will collect personal information
EnsureFlow maycollect your personal information when you:
- register to use the Portal;
- complete forms, supply information or otherwise interact with the Portal;
- communicate with us through the Portal or by email at email@example.com; or
- share information with us from other applications, services or Portals.
EnsureFlow will only collect personal information about you by lawful and fair means.
In some limited circumstances, we may ask you if we can collect sensitive information about you. We will not collect sensitive information about you unless you consent to the collection, and the information is directly related to our activities.
2.3 Automatic collection of anonymous data
EnsureFlow may use pixel tags and other methods to gather information about the emails EnsureFlows ends to Users through the Portal. Pixel tags are tiny graphic files that are included in HTML-encoded email messages. When such a message is opened in an HTML-capable email program, the recipient’s computer will access EnsureFlow servers to retrieve the pixel tag file, allowing EnsureFlow to record and store information such as an email address, date and time the recipient viewed the email message if the recipient’s email program can receive HTML and other logging information.
EnsureFlow uses this information to optimise e-delivery of future messages to specific recipients and to provide information to Users with respect to emails they send through the Portal.
We may also use 'cookies' or other similar tracking technologies on our website that help us track your usage of the Portal and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but the Portal may not work as intended for you if you do so.
2.5 What happens if you don’t provide us with your personal information?
You are not obliged to provide us with your personal information when we specifically request it. However, this may mean we are not able to facilitate the provision of services through the Portal.
You have the right not to identify yourself when dealing with us where it is lawful and practicable for us to allow it. However, the nature of our business is such that there may be practical limitations which impact our ability to facilitate this.
2.6 Consent to the collection, use and disclosure of personal information
Where you provide us with personal information about third parties, you must obtain that person’s consent to provide the information, inform them about the purpose of the information given and confirm the person has read and understood this Policy and separately consents to their personal information being used by us in accordance with this Policy.
As a User, you are required to confirm to us that you and any other individuals whose information is provided consents to us collecting, using and disclosing your and their personal and sensitive information, however collected by us, in accordance with our Policy.
2.7 Withdrawing consent to the use of personal information
You may withdraw your consent:
- to the use of personal information for secondary purposes;
- to being contacted in relation to any of our services; and
- to receiving marketing information from EnsureFlow by contacting EnsureFlow at firstname.lastname@example.org or by completing the section(s) indicated on EnsureFlow’s forms when you submit those forms on the Portal.
3. Holding and storing personal information
We hold and store personal information in our secure electronic databases, and in accordance with clause 7 of this Policy.
All information collected by EnsureFlow is stored in Australian Data Centres (which consists of a Private and Public Cloud).
4. Usage of personal information
We may collect, hold, use and disclose your personal information for the following purposes:
- to enable you to access and use the Portal;
- to operate, protect, improve and optimise the Portal, our business and our Users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners or affiliates that we think you may find interesting;
- to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners or affiliates; and
- to comply with our legal obligations, resolve any disputes that we may have with any of our Users, and enforce our agreements with third parties.
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
We may partner with third party vendors to advertise online and third-party affiliations to run advertising of our services. Third party vendors, including Google, show our advertisements on websites across the Internet by using cookies to serve advertisements based on a person’s past visits to the Portal. These third-party affiliations may contact you by phone to discuss our products and services.
4.3 Social media
EnsureFlow may engage with Users or prospective Users through social media channels such asFacebook, Twitter, YouTube, LinkedIN and Instagram. However, no personal information is collected through these channels, unless explicit consent is provided by you.
4.4 Existing customer database
Under no circumstances will EnsureFlow sell, share or rent the information on EnsureFlow’s database in any manner to any third parties unless required by law.
EnsureFlow will only utilise the information on its database to send promotional information about EnsureFlow’s services.
5. Correction and removal of personal information
If EnsureFlow becomes aware that any personal information we hold is not correct, we will use our best endeavours to obtain the correct information by contacting the individual whose information is incorrect.
EnsureFlow allows its records containing personal information to be accessed and/or corrected by the individual concerned in accordance with the Act.
Individuals wishing to lodge a request to access and/or correct their personal information should contact EnsureFlow. You should provide sufficient detail about the information to help us locate it. We will then use commercially reasonable efforts to take corrective action within a reasonable time.
When personal information is no longer needed for any purpose for which the information may be used or disclosed, it will be destroyed or permanently de-identified.
In certain circumstances, EnsureFlow may refuse your request to correct your personal information. EnsureFlow will provide you with written notice about the refusal in accordance with APP 13.3.
6. Disclosure of information
We will not disclose information collected about you without your consent, other than to attend to your specific enquiries, improve customer experience, send you information about EnsureFlow’s products and services or as required under law.
However, by using EnsureFlow’sPortal, you authorise us to disclose personal information to third party agents or contractors who provide services to us in connection with the provision of products or services you have sought from us.
To carry out the purposes relevant to your relationship with EnsureFlow, we may disclose your publicly available personal information or personal information held by EnsureFlow to persons or organisations such as;
- service providers registered with EnsureFlow for the purpose of delivering services you have booked through the Portal;
- third parties with whom EnsureFlow works with to improve its products and services;
- third parties who assist us in the detection and investigation of fraud;
- regulatory bodies and government agencies;
- other parties to whom we are authorised for mandatory professional standards or required by law to disclose information;
- the party to whom the disclosure is made controls, is controlled by, or is under common control of EnsureFlow;
- third parties who assist us with the establishment or maintenance of legal claims;
- agents that we use in the ordinary course of operating our business such as for data processing, printing or mailing;
- persons or entities for which we are providing services, provided the disclosure is consistent with the purpose for which the personal information was obtained;
- third party software providers who store details of customer accounts for us or who provide other IT services.
We deal with third parties who are required to meet the obligations in the Act and as such, your personal information will only be used for the purposes for which we gave it to them.
EnsureFlow takes all reasonable steps to make sure that the personal information we collect, hold, use and disclose is accurate, complete and up to date. We will protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure. Where permitted by law, we will destroy or permanently de-identify personal information that is no longer required.
We maintain strict procedures and standards and take all reasonable care to protect the security of your personal information received online and/or through the Portal. We use industry-standard security safeguards such as a 128-bit SecureSocket Layer (SSL) to transfer personal and financial information between you and our web servers coupled with carefully developed security procedures. These measures are designed to protect Users’ information from loss, misuse or unauthorised alteration.
No data transmission over the Internet can be guaranteed as fully secure. EnsureFlow cannot guarantee or warrant the security of any information you send to us using the Portal. You submit information at your own risk.
EnsureFlow employees are trained and required to safeguard customer and prospective customer Portal visitor information. Using physical, electronic and procedural safeguards, we restrict access to such personal information to only those employees who are required to know information for operational purposes.
8. Access to your personal information
EnsureFlow will provide you with access to your personal information if practicable and will take reasonable steps to amend any personal information about you which is inaccurate or out of date. In some circumstances and in accordance with the Act, EnsureFlow may not be able to give you access to your personal information.
If we cannot give you access to your information we will provide you reasons for this decision.
To request to access your personal information, please contact EnsureFlow (details below).
9. Opting out of marketing and promotions
If a User no longer wishes to receive EnsureFlow marketing communications, they can opt out of receiving these communications by making the request at the time of receiving the communication or by emailing EnsureFlow at email@example.com
at any time.
10. Links to other websites
The Portal may contain hyperlinks to other websites. When you use a hyperlink from the Portal to the websites of third parties, those websites are not subject to EnsureFlow’s privacy and security standards. Please be aware that third parties may independently collect information about Users when they view advertisements or other communications from third parties through EnsureFlow’s products or services. If Users do not want those companies to collect information about them, they should contact these companies directly.
11. Complaint and dispute resolution
If you have any concerns or complaints about the way your personal information has been collected or handled, please contact EnsureFlow.
Please contact EnsureFlow if you wish to view this Policy in an alternative format. We will endeavour to respond and provide an alternative format as soon as possible.
The aim of the dispute resolution process, such as conciliation, negotiation or mediation, is to reach a settlement that will resolve a complaint.
Remedies for privacy related complaints may include one or more of the following;
- an apology to the individual;
- being provided with access to information;
- correction or amendment of a record;
- systems or procedures improvements, including changed or upgraded security arrangements for personal information;
- privacy notices being amended or updated; or
- staff training.
12. Data breach notification
If an eligible data breach is reported EnsureFlow will take all reasonable steps to ensure an assessment is completed within 30 days. If an eligible data breach is confirmed, as soon as practicable EnsureFlow will provide a statement to each of the individuals whose data was breached or who are at risk, including details of the breach and recommendations of the steps individuals should take.
13. Questions and concerns
If you haveany questions regarding this Policy, the operation of this Portal, or your dealings with EnsureFlow, please email us at firstname.lastname@example.org
Further information about the application of the Act can be found at the Portal of theOffice of the Australian Information Commissioner at www.oaic.gov.au