Who are we?

Datanova Cloud Pty Ltd ACN 627 359 157 trading as FlowLogic (FlowLogic) is committed to managing personal information in accordance with the Privacy Act in Australia and New Zealand and all other applicable rules and regulations.

This privacy policy sets out the manner in which FlowLogic collects, holds, uses and discloses your personal information.

What types of personal information does FlowLogic collect and hold?

The types of personal information FlowLogic collects and holds about you may include:

• your name and contact details (including email address, phone number, billing and postal address), professional title and company name;
• your age and date of birth;
• health fund identification information (such as, patient names, health fund name and number);
• NDIS number;
• FlowLogic account details and password;
• your financial information (such as, your nominated account for direct debt);
• your device, hardware and software information (such as, which browser and operating system you use, your IP address, location, pages you have navigated through FlowLogic);
• information about your access to FlowLogic’s website;
• any other personal information you may have provided to us; and
• other information FlowLogic considers necessary for the provision and/or promotion of FlowLogic’s services, and the operation of FlowLogic’s business.

What type of sensitive information does FlowLogic collect?

FlowLogic may collect certain sensitive information about you (as that term is defined in the Privacy Act), including, for example, your health information.

The collection of any sensitive information about you is reasonably necessary for, or directly related to, FlowLogic’s functions or activities and its ability to provide its services to you. Sensitive information will only be collected with your consent, unless otherwise permitted by law.

FlowLogic’s mobile application (FlowLogic App) permits you to login using your device’s built-in biometric authentication feature (such as fingerprint or facial recognition). The FlowLogic App does not collect, access or store any biometric data, but only a mathematical representation generated and handled by your device’s operating system. The FlowLogic App relies on the operating system to confirm whether an authentication attempt is successful or not, without receiving or storing your raw biometric data.

How does FlowLogic collect and hold your personal information?

FlowLogic collects your personal information, primarily through your interaction with FlowLogic’s software platform or the FlowLogic App. Often this information is initially provided by you to the support providers (our customers) and then made available to FlowLogic via FlowLogic’s software platform or the FlowLogic App.

Your information may also be collected in other ways, for example:

• when you fill out a form on the website;
• when you create an account;
• when you communicate with FlowLogic through correspondence;
• when you otherwise interact with FlowLogic’s website;
• by interacting with the customer portal;
• through our mobile application;
• by you disclosing personal information to FlowLogic representatives on the telephone if you call FlowLogic; or
• from publicly available sources (such as social media, public websites and online business listings).

Storage and security of your personal information

Once FlowLogic has collected your personal information, FlowLogic takes reasonable steps to ensure your information is protected from loss, unauthorised access, use, modification or disclosure, or other misuse.

How and why does FlowLogic use your personal information?

FlowLogic may use your personal information to provide the service requested by you, or to respond to your requests, questions or inquiries, and/or for other purposes, including:

• improving FlowLogic’s website, the FlowLogic App and FlowLogic’s service to you;
• telling you about other products or services offered by FlowLogic that may be of interest to you by way of email, SMS, telephone, mail or other forms of communication in accordance with applicable laws. If you no longer wish to receive marketing communications, you may opt-out by contacting FlowLogic at info@flowlogic.com.au or by managing the subscription using the unsubscribe link in the electronic communication received;
• for operational reasons, including allowing FlowLogic to run its business and perform administrative tasks (for example, training, development, research and testing);
• create anonymised and deidentified data sets to help FlowLogic understand its market and customers better, and to identify new customers who may be interested in FlowLogic’s website, the FlowLogic App and FlowLogic’s services;
• to provide a convenient and secure login experience to the FlowLogic App via biometric authentication – that is, to verify your identify without requiring m annual password entry, relying on your device’s operating system verification mechanism;
• to record (for security, audit and troubleshooting purposes) whether biometric login attempts succeed or fail, but without storing any biometric data, only a log of login attempts;
• preventing or investigating any fraud or crime, or suspected fraud or crime;
• as required by law or regulation binding FlowLogic; and
• any purpose for which you have given your consent.

What happens if you don’t provide your information to FlowLogic?

If you don’t provide your information to FlowLogic, we may not be able to:

• provide you with the services you want;
• grant you access to FlowLogic’s software platform and the FlowLogic App;
• manage and administer FlowLogic’s software platform, the FlowLogic App and FlowLogic’s website;
• engage with you as intended or be able to respond and assist in the manner required;
• personalise your experience with FlowLogic; or
• let you know about products or services offered by FlowLogic that may be of interest to you.

Disclosure of your personal information

FlowLogic may disclose your personal information to:

• financial institutions and payment processors that facilitate payment transactions;
• payment systems organisations, including payment merchants;
• third party suppliers and service providers (including providers who perform services at FlowLogic’s direction or on FlowLogic’s behalf in connection with providing the services to you);
• third party service providers that maintain and develop FlowLogic’s business systems, procedures and technology infrastructure, including testing and upgrading of computer systems;
• related FlowLogic entities;
• anyone to whom FlowLogic’s assets or business (or any part of them) is transferred;
• third parties where you have expressly provided your consent for that disclosure, or that disclosure can be inferred;
• government or regulatory bodies as required or authorised by law; and
• anyone we are otherwise permitted to disclose the information to pursuant to the Privacy Act.

Sharing your personal information overseas

If you call us and provide us with personal information, the transcript of your call may be processed via subprocessors located outside of Australia to assist us in providing ongoing support and/or the data of your telephone call may also be processed and analysed to assist us in improving our services to you.

We take reasonable steps to ensure that the subprocessors are subject to binding contractual obligations to comply with the Privacy Act, or are otherwise subject to a law or binding scheme that protects personal information in a way that is substantially similar to the Privacy Act.

These subprocessors may be located in countries, including but not limited to: the United States of America, United Kingdom, Germany and France.

Accessing your personal information

You may request access to your personal information by contacting FlowLogic at info@flowlogic.com.au, which will generally be granted unless an exception applies under law that prevents FlowLogic from doing so.

If you become aware that some of the personal information FlowLogic holds about you is inaccurate, not up to date, or is incomplete, you should contact FlowLogic on the email address listed above as soon as possible so that FlowLogic can update that information. If FlowLogic does not agree that the information needs to be updated, FlowLogic will attach your request for a correction to the information so that it will always be read with the information.

Use of cookies

FlowLogic’s website may use “cookies” to enhance your user experience. If a cookie collects any personal information about you, that personal information will be handled, collected and used in line with this privacy policy.

Making a complaint

If you have any complaints in relation to this privacy policy, or how FlowLogic has held, collected or used your personal information, please contact FlowLogic at info@flowlogic.com.au. FlowLogic respects your personal information and this privacy policy, and is committed to resolving any complaint as quickly as possible. To this end, FlowLogic will endeavour to get back to you in relation to your complaint within five business days.