This privacy statement is made on behalf of Fluenccy Pty Ltd ABN 82 641 857 169 and its related body corporates (“Fluenccy”). All references to “Fluenccy”, “we”, “us” or “our” in this policy are references to Fluenccy Pty Ltd.
Fluenccy is committed to protecting your privacy in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).
This document sets out our policy with respect to the collection and management of personal information. We are committed to ensuring the privacy of your information and recognise that you, as a customer, are concerned about your privacy and about the confidentiality and security of information that we may hold about you.
By using our website and/or our services, you consent to the collection, use and disclosure of your personal information in accordance with this policy.
Personal information is information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from that information or opinion.
Open and transparent management of personal information
We seek to ensure that personal information we hold about an individual is managed in an open and transparent manner. We have implemented procedures to ensure compliance with the Australian Privacy Principles and any applicable codes, and to deal with any complaints relating to our compliance with those principles and codes.
Collection of personal information
We will, from time to time, receive and store personal information you enter onto our website, provided to us directly, or give to us in other forms.
Information which you may provide, and which is collected by us includes your name, phone number, address and email address.
We may collect additional information at other times when you provide feedback, when you provide information about your personal or business affairs, change your content or email preferences, respond to surveys and/or promotions, provide financial or credit card information or communicate with our customer support.
We only collect personal information directly from individuals, when it is reasonably necessary for us to do so, and only by lawful and fair means. We will always ensure you are aware of the purpose in collecting information, and your right to gain access to such information. If you do not provide the information requested, we may be unable to provide you with our services.
Wherever lawful and practicable, you may request to deal with us anonymously however, given the nature of our services, it is unlikely that this will be a viable option.
Fluenccy will also collect any personal information necessary for the purposes of complying with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
How we collect your personal information
We collect personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we provide our services to you.
We may also receive personal information from third parties. If we do, we will protect it in accordance with this policy. You consent to such indirect collection of information in these circumstances, unless you advise us otherwise.
Unsolicited personal information
Where we receive personal information about an individual which is unsolicited by us and not required for the provision of our services, we will destroy the information (provided it is lawful and reasonable for us to do so).
Use of personal information
We will use personal information collected from you for the primary purpose of providing our services.
We may also use personal information for secondary purposes. This may include providing you with information, updates and other services. We may also make you aware of new and additional products, services and opportunities available to you
We may use personal information for direct marketing purposes where:
we have collected the personal information from you
you would reasonably expect us to use your personal information for the purpose of direct marketing
we provide you with a mechanism to request us not to send you marketing communications
you have not requested such communications cease.
We allow you to opt out of the receipt of direct marketing in each direct marketing communication. You can change your mind about receiving information at any time by emailing us. On occasion, the law requires us to advise you of certain changes to products/services or regulations. You will continue to receive this information from us even if you choose not to receive direct marketing information from us. We will not disclose your information to any outside parties for the purpose of allowing them to directly market to you.
Disclosure of personal information
We may disclose your personal information to our employees, insurers, professional advisers, agents, suppliers or subcontractors where it is reasonably necessary and for purposes set out in this policy.
We may also provide your personal information to third parties in order to provide you with our services.
We may exchange your personal information with our professional advisers or agents, external service providers, your nominated professional advisers or representatives, government departments/agencies/bodies, other financial institutions, our insurers, or debt collectors.
We will only share personal information with overseas entities or persons to facilitate our services or comply with our legal obligations.
We may also disclose your personal information without consent where it is required or authorised by law.
Security of personal information
We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, loss and unauthorised access, modification and disclosure.
Personal information imaged and stored on electronic databases requires password access and access is restricted to authorised personnel.
Where information is no longer required to be held or retained by us for any purpose or legal obligation, we will take all reasonable steps to destroy or de-identify the information.
Access to personal information
You may request access to details of personal information we hold about you in accordance with the law.
We take all reasonable steps to ensure the personal information held about individuals is accurate, up-to-date and complete.
Where we believe information we hold about an individual is inaccurate, out-of-date, incomplete, irrelevant or misleading, or you request us to correct information held about you, we will take all reasonable steps to correct such information within a reasonable time frame.
If we refuse to comply with your correction request, we will notify you in writing of our reasons for such refusal, and our complaints process if you wish to challenge that decision. You may also request that we associate the personal information we hold with a statement regarding your view of its inaccuracy.
If you would like a copy of the information which we hold about your or believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us. We will not charge for reasonable access and correction requests.
If you have a complaint relating to our compliance with privacy laws or our treatment of your personal information, please contact us. We will investigate your complaint and endeavour to resolve the issue to your satisfaction.
Website & cookies
When you visit our website, www.fluenccy.com, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site. This information is used in an aggregated manner to analyse how people use our site so that we can improve our services.
Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute our endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practices of other websites. We encourage our users to be aware, when they leave our website, to read the privacy statement of each and every website that collects personal identifiable information.
Additions provisions for the European Union under GDPR and for the United Kingdom under UK GDPR
Where applicable, we adhere to the EU General Data Protection Regulations (GDPR) for the European Union (EU) and the UK General Data Protection Regulations (UK GDPR) for the United Kingdom.
We will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.
We process your personal information as a processor and/or to the extent that we are a controller as defined in the GDPR and UK GDPR. We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR and UK GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR and UK GDPR.
You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.
Your rights under the GDPR and UK GDPR
If you are an individual residing in the EU or the UK, you have certain rights as to how your personal information is obtained and used. We comply with your rights under the GDPR and UK GDPR as to how your personal information is used and controlled if you are an individual residing in the EU and UK GDPR.
Except as otherwise provided in the GDPR and UK GDPR, you have the following rights:
(a) to be informed how your personal information is being used;
(b) access your personal information (we will provide you with a free copy of it);
(c) to correct your personal information if it is inaccurate or incomplete;
(d) to delete your personal information (also known as "the right to be forgotten");
(e) to restrict processing of your personal information;
(f) to retain and reuse your personal information for your own purposes;
(g) to object to your personal information being used; and
(h) to object against automated decision making and profiling.
Please contact us at any time to exercise your rights under the GDPR and UK GDPR. We may ask you to verify your identity before acting on any of your requests.
Hosting and International Data Transfers
Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of the EU or the UK. These may include but is not limited to Australia, United Kingdom and Ireland.
We and our other group companies have offices and/or facilities in certain countries. Transfers to those countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission and the United Kingdom which you can obtain from the European Commission Website and United Kingdom Commission Website; the use of binding corporate rules, a copy of which you can obtain from our data protection officer.
The hosting facilities for our website are situated in the countries outside the EU or UK. Transfers to these countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission and the United Kingdom Commission which you can obtain from the European Commission Website and United Kingdom Commission Website; the use of binding corporate rules, a copy of which you can obtain from our data protection officer.
Our suppliers and contractors are situated in Europe and Australia. Transfers to other European countries and Australia will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website and United Kingdom Commission Website; the use of binding corporate rules, a copy of which you can obtain from our data protection officer.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and UK GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
You may request details of personal information that we hold about you in accordance with the provisions of the GDPR and the UK GDPR. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us.