WorkflowMax by BlueRock
WFMax Pty Ltd (ACN 666 239 952) (trading as “WorkflowMax by BlueRock” and as “WorkflowMax”) and/or their related entities (together “us”, “our” or “we”) are committed to protecting the privacy of your Personal Information.
2. What Personal Information do we collect?
We collect and use Personal Information from Users of the Portal, Users of any of our Services and visitors of the Portal. The specific type of Personal Information that we collect will depend on the reasons for, or circumstances of its collection and may include, but is not limited to, the following:
- User information: name, telephone and mobile number, email address, residential and postal address;
- Payment and transactional information: banking, credit card or debit card details, billing information, Device information and Technical Usage Data;
- Enquiries, communications and social media: information contained in any enquiry you submit to us regarding our Portal or any of our Services, communication content, metadata associated with communications and information about you shared by social media Portals (if you communicate with us by way of a social media Portal that we use); and
If you do not allow us to collect all the Personal Information we reasonably request, we may not be able to deliver any of our Services to you.
3. How do we collect Personal Information?
We may collect your Personal Information directly from you or in the course of our dealings with you. For example, we collect Personal Information from you or about you from:
- your access and use of the Portal;
- your use of any of our Services;
- correspondence between you and us;
- visits to and submissions you make on our Portal or in connection to any of our Services;
- your interactions with our electronic direct mail and/or emails from our marketing campaigns (such as clicks on links included in these emails); and
- registration and forms you may fill in for our marketing-related activities and events.
In some instances, we may receive Personal Information about you from third parties, including our related entities, government agencies and regulatory authorities. We may also receive Personal Information about you from your authorised third parties and publicly available sources.
4. Why do we collect, hold and use Personal Information?
We collect, hold and use your Personal Information for the purposes of providing you with access and usage of the Portal and the Services, which include (without limitation):
(GDPR lawful basis: consent)
- providing you with use of our Portal and/or any of our Services;
- ongoing client relationship management purposes;
- offering, promoting, advertising, marketing and selling relevant and suitable Services to you;
- sending you relevant notifications, electronic direct mail, email marketing campaigns and/or newsletters;
- any other purposes identified at the time of collecting your Personal Information;
- developing and improving our business, the Portal and/or any of our Services;
- for monitoring, research and analysis in relation to our business, the Portal and any of our Services;
- involving you in market research, gauging customer satisfaction and seeking feedback;
(GDPR lawful basis: contractual obligation)
- performing and supplying any of our Services to you;
- managing our relationship with you (including maintaining a User profile), communicating with you, identifying you when you contact us, responding to your enquiries and keeping records;
- processing payments you have authorised;
(GDPR lawful basis: legal obligation)
- complying with all of our legal obligations to you and to third parties (including, without limitation, any governmental authority.
- ensuring the security of our Portal and our Services and maintaining back-ups of our database(s);
- for our internal accounting and administration;
- where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
- in the preparation for, or conduct of, court proceedings or in an administrative or out-of-court procedure (or the implementation of orders of a court or tribunal or on behalf of an enforcement body);
- for the purpose of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice; and
(GDPR lawful basis: protect a person’s vital interests)
- where we reasonably believe that use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone's health or safety or the public's health or safety.
Where we wish to use or disclose your Personal Information for other purposes, we will obtain your consent.
5. Will my Personal Information be disclosed to third parties?
By using our Portal, any of our Services and/or by providing us with your Personal Information (or allowing another person to do so), you acknowledge and consent to us disclosing some or all of your Personal Information to third parties. This includes disclosure of your Personal Information and details:
- to our related entities as necessary for the provision of any of our Services or to enable them to provide any of the service offerings that you have requested;
- to government agencies to enable relevant registrations, notifications and/or lodgements in connection with the Portal and/or our Services;
- to a person that uses the Portal or any of our Services on your behalf and/or a person you have authorised;
- if you enable third party applications to be used in conjunction with the Portal and/or any of our Services, to those third party applications;
- to our partners, contractors, suppliers, subcontractors and service providers, including without limitation our suppliers of IT based solutions that assist us in providing any of our Services, distributors of direct marketing communications; marketing agencies, insurers and external business advisors;
- in accordance with requirements or authorisations under applicable laws or to comply with our legal obligations; and
We take reasonable steps to ensure that third party recipients are obliged to protect the privacy and security of your Personal Information and use it only for the purpose for which it is disclosed. These measures include use of industry-standard, physical procedural and technical security measures and encryption where appropriate. However, regardless of any security measures used, we cannot guarantee the absolute protection and security of any Personal Information stored with us or with any third parties.
Our current list of sub-processors, their location and the services they perform, includes:
- Amazon Web Services, Cloud infrastructure service provider, United States
- Aspose, cloud infrastructure service provider, Australia
- HubSpot, CRM, marketing and web hosting service provider, United States
- New Relic, infrastructure monitoring, United States
- Stripe, Online payment processing, United States
- Planhat, customer support, Sweden
- Sentry, infrastructure monitoring, United States
- Userback, customer support, AustraliaUserpilot, product analytics and guided onboarding, United States
- Zendesk, customer support, United States
Note: These sub-processors may change over time. Check back regularly for updates.
At all times, the third parties that we disclose your Personal Information to:
- are required to provide GDPR compliant services (if they are subject to the GDPR);
- must take reasonable steps, to our satisfaction, to ensure that Personal Information disclosed by us is protected against misuse, interference, loss and unauthorized access, modification and disclosure;
- must, if they become aware of any misuse, interference, loss, or unauthorized access, modification or disclosure of Personal Information disclosed by us, immediately notify us.
Without your consent, we will not disclose your Personal Information to any third party (except for those described above), unless such disclosure is required by local Data protection laws or the GDPR and/or where we reasonably believe that it is necessary to lessen or prevent a threat to life, health or safety or for action to be undertaken by an enforcement body, or where allowed to do so in accordance with the local Data protection laws.
6. How we hold and store Personal Information?
Your Personal Information is held and stored on paper, by electronic means (including by way of a third party client relationship management product or system) or both. We have physical, electronic and procedural safeguards in place for Personal Information and take reasonable steps to ensure that your Personal Information is protected from misuse, interference, loss and unauthorised access, modification and disclosure. our cloud-based servers are located in Australia in data centres that have represented to us that they are GDPR compliant (including by incorporating the Standard Contractual Clauses that the European Commission adopted in June 2021).
When developing and designing products and services that involve the processing of Personal Information, we take into account Data protection to ensure that we can fulfil our Data protection obligations.
Data held and stored on paper is stored in secure premises.
Data held and stored electronically is protected by internal and external firewalls. We encrypt and/or pseudonymise data wherever possible. All access to electronic Data including databases requires password access that meets industry complexity standards.
Access to Personal Information is restricted to staff and contractors whose job description requires access. Our employees and contractors are contractually obliged to maintain the confidentiality of any Personal Information held by us. We also implement multi-factor authentication (MFA) safeguards wherever possible.
Data stored or archived off-Portal is contained within secure facilities. We also require our storage contractors to implement privacy safeguards.
We undertake regular Data backups, with the Data copied and backed up to multiple locations for redundancy purposes.
Our staff receive regular training on privacy procedures.
7. How long will my Personal Information be retained?
We will retain your Personal Information for the time periods required by law.
We use secure methods to destroy, desensitise or de-identify your Personal Information when it is no longer needed or legally required to be retained. Paper records are sent for secure destruction. In some instances, paper records and original documents will be returned to you and/or relevant third parties.
Electronic records may be archived to alternative storage and are subject to the procedural safeguards described above.
Please refer to the details below for the procedure to have your Personal Information deleted.
8. Will I be able to access and control my Personal Information?
You have a right to request access to or correction of your Personal Information held by us. If you are in the European Union, you also have a right (with a few exceptions) to request that your Personal Information is deleted.
If you wish to access, correct or update any Personal Information that we hold about you, please contact us via the details below.
We will respond to your request within 30 days of you making the request and give you access in the manner you requested unless it is unreasonable or impracticable for us to do so. Before we accept your request, we will need to use reasonable methods to verify your identity. There may be reasons why we cannot give you access to the information that you have requested, or we refuse to correct your personal information. In these instances, we will let you know these reasons in writing. To assist us to keep our records up to date, please notify us of any changes to your Personal Information.
9. Can I withdraw my consent to hold my Personal Information?
You have a right to withdraw your consent to us using your Personal Information at any time.
Please contact us via the details below if you would like to make such a request. We will process a request within one month. Please note that by withdrawing your consent, we may no longer be able to provide you with access to our Portal or Services. Please refer to section 8 above for the procedure to have your Personal Information deleted.
10. Will my Personal Information be transferred internationally?
When we share Personal Information, it may be transferred to, and processed in, countries other than the country you live in, where our Data hosting provider’s servers are located. These countries may have laws different to what you’re used to. Rest assured, where we disclose Personal Information to a third party in another country, we put safeguards in place to ensure your personal Data remains protected.
For individuals in the European Economic Area (“EEA”), this means that your Personal Information may be transferred outside of the EEA. Where your Personal Information is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA Data, or to a third party where we have approved transfer mechanisms in place to protect your Personal Information, for example, by entering into the European Commission’s Standard Contractual Clauses. For further information, please contact us using the details set out in the Contact us section below.
11. What happens if there is a Data breach?
We will take seriously and deal promptly with any accidental or unauthorised loss, use or disclosure of Personal Information (Data Breach).
We are subject to the Notifiable Data Breaches Scheme (“NDB Scheme”) under the Privacy Act. In assessing and responding to suspected notifiable Data breaches, we will act in accordance with:
- our applicable policies which incorporate the requirements of the NDB Scheme; and
- the guidance of the Office of the Australian Information Commissioner (“OAIC”).
Where a breach of your Personal Information occurs that is likely to cause harm (e.g. releasing unencrypted Personal Information), we will notify you and make recommendations about the steps you should take in response to the breach. Where required by law, the OAIC will also be notified.
If a Data Breach releases Personal Information of a European Union-based user, we will notify the European Data Protection Supervisor within 72 hours of becoming aware of the Data Breach.
12. Will I have the opportunity to provide feedback?
From time to time, you may have the option to participate in surveys or provide feedback intended to improve any of our Services which may involve providing additional Personal Information. Your participation in such activities is subject to your consent.
13. What direct marketing will be undertaken?
We may use and disclose your Personal Information for the purpose of direct marketing to you by way of a direct mail, email, SMS, MMS, targeted digital advertising or any other means of marketing communication, where:
- you have consented to us doing so; or
- it is otherwise permitted by law.
You may opt out of direct marketing communications at any time by contacting us or by using opt-out facilities set out in the direct marketing communications.
14. How will cookies be collected?
15. How do we collect and process Data?
Our Users are solely responsible for determining whether and how they wish to use our Portal, and for ensuring that all individuals using the Portal on the User’s behalf or at their request, as well as all individuals whose Personal Information may be included in Business Data processed through the Portal, have been provided with adequate notice and given informed consent to the processing of their Personal Information, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of Data through our Services are fully met by the User. Our Users are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose Data they process through the Portal.
17. Who do I contact if I have a complaint?
You can contact us by post or email to:
WorkflowMax by BlueRock
Level 9, 505 Little Collins Street
Melbourne VIC 3000
EU Privacy Officer
WorkflowMax by BlueRock
18. Schedule - Definitions
“Device” means any type of device including a computer, mobile phone, tablet or console that meets the minimum specifications required to access to the Portal and/or use any of our Services.
“Device Information” means Data that can be automatically collected from any device used to access the Portal and/or any of our Services, including your Device type, your Device’s network connections, your Device’s name, your Device’s IP address, information about your Device’s web browser and the internet connection used to access the Portal or any of our Services, Geolocation Information, information about apps downloaded to your Device and biometric Data (such as Touch ID/Fingerprint).
“Geolocation Information” means information that identifies your location by using longitude and latitude coordinates obtained through GPS, Wi-Fi or cell Portal triangulation.
“Personal Information” means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion;
“Site” means the website operating from the domain at “https://workflowmax2.com” or such other domains used by us from time to time for access to this site or any other sites or provision of any of our Services.
“Technical Usage Data” means information we collect from your Device that you use to access the Portal or any of our Services such as what you have searched for and viewed on the Portal, the length of your visit and the way you use any of our Services, including your IP address, statistics regarding how pages are loaded or viewed, the website you viewed before coming to the Portal and other usage and browsing information collected through cookies.
“User” means a user of the Portal and/or any of our Services, as the context requires.