Privacy Policy

Effective Date: 1st January 2025

1. Introduction

Smart Flows (ABN 81 534 936 652) ("we," "us," "our") is committed to protecting the privacy of individuals who visit our website at https://smartflows.com.au (the "Website"), interact with us, or use our services. This Privacy Policy outlines how we collect, use, disclose, and manage your personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).

By using our Website, providing your personal information to us (e.g., through contact forms, newsletter sign-ups, or for downloadable resources), you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

2. What Personal Information We Collect

We may collect the following types of personal information:

• Identity and Contact Details: Such as your name, email address, phone number (if provided), and any other information you provide when you fill out a contact form, newsletter sign-up form, or a form to access downloadable resources.
• Communications: Records of your communications with us, including emails and information provided through website forms.
• Website Usage Data (Non-Identifiable & Aggregated): We may collect information about how you use our Website, such as your IP address (which may be anonymized), browser type, operating system, referring URLs, pages viewed, and dates/times of visits. This is typically collected through analytics tools and helps us improve our Website.
• Cookies and Tracking Technologies: Information collected through cookies and similar technologies as described in Section 7 below.

3. How We Use Your Personal Information

We use your personal information for the following purposes:

• To respond to your inquiries submitted via contact forms or email.
• To provide you with downloadable resources you have requested.
• To send you newsletters, marketing communications, and information about our services, where you have consented to receive such communications. You can opt-out at any time.
• To process any requests or applications you make (e.g., for service engagement).
• To operate, maintain, and improve our Website and services.
• For internal record keeping, administrative, and analytics purposes.
• To comply with our legal obligations.

Regarding Mailing Lists: When you provide your email address to download a resource, sign up for our newsletter, or make an inquiry through a contact form, we may interpret this as your consent to be added to our mailing list for relevant communications from Smart Flows. We will always provide a clear and easy way for you to unsubscribe from these communications in every email sent. **(Note: Your lawyer MUST review this consent mechanism to ensure it complies with the Spam Act 2003 and APPs. Explicit opt-in checkboxes are often recommended).**

4. Disclosure of Your Personal Information

We do not sell, trade, or rent your personal information to others. We may disclose your personal information to:

• Third-Party Service Providers: Who assist us in operating our Website, conducting our business, or servicing you (e.g., email marketing platforms, website hosting providers, analytics providers). These providers are contractually bound to protect your information and use it only for the purposes for which it was disclosed. (You will need to identify these providers for a complete policy).
• Legal Requirements: If required by law, regulation, court order, or other legal process, or to protect our rights, property, or safety, or the rights, property, or safety of others.

We will take reasonable steps to ensure that any third-party recipients of your personal information are bound by privacy obligations similar to those that bind us.

5. Data Security

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and from unauthorized access, modification, or disclosure. This includes using secure servers and access controls. However, no internet transmission is ever completely secure or error-free, so we cannot guarantee absolute security.

6. Data Retention

We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or as otherwise required or permitted by law.

7. Cookies and Tracking Technologies

7.1. Our Website may use "cookies" and similar tracking technologies (e.g., web beacons, pixels) to enhance your experience, understand user activity, and improve our services.

7.2. What are Cookies: Cookies are small files placed on your device that store information. We may use:

• Essential Cookies: Necessary for the Website to function properly.
• Performance/Analytics Cookies: To collect information about how visitors use our Website (e.g., Google Analytics), allowing us to improve its performance. This data is typically aggregated and anonymized.
• Functionality Cookies: To remember choices you make and provide enhanced features.

7.3. Your Choices: You can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the Website. Information on managing cookies is available in your browser's help section or at websites like www.allaboutcookies.org.

7.4. **(Optional: If you use targeted advertising cookies from platforms like Facebook Pixel, Google Ads remarketing, etc., you MUST declare this clearly and get appropriate consent. This template does not assume such use. Your lawyer will advise.)**

8. Your Rights and Choices (Under Australian Privacy Law)

Under the Australian Privacy Principles, you have rights regarding your personal information, including:

• Access: You can request access to the personal information we hold about you.
• Correction: You can request that we correct any inaccurate, out-of-date, incomplete, irrelevant, or misleading personal information we hold about you.
• Complaints: If you believe we have breached the APPs or mishandled your personal information, you can make a complaint to us using the contact details below. We will investigate your complaint and respond to you in writing within a reasonable period. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC).

To exercise these rights, please contact us using the details provided in Section 11.

9. Links to Other Websites (If Applicable)

Our Website does not currently link to third-party websites. If this changes in the future and we provide links to other websites, this Privacy Policy will not apply to those external sites. We would not be responsible for the privacy practices of other sites and encourage you to read their privacy policies.

10. Children's Privacy

Our Website and Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will post any changes on this page and update the "Effective Date" at the top. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

12. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our handling of your personal information, please contact us at: