Revised date: 1 January 2025
This Privacy Policy for FlowXL Software Pty Ltd ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:
§ Download and use our application (FlowXL), or any other application of ours that links to this Privacy Policy
§ Use FlowXL. FlowXL is an add-in for Microsoft Excel providing enhanced productivity tools and shortcuts for regular users.
§ Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at team@flowxl.com.
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
§ names
§ phone numbers
§ email addresses
§ mailing addresses
§ job titles
§ billing addresses
§ contact preferences
§ contact data
Sensitive Information. We do not process sensitive information.
Device Data. If you use our application, we also may collect the following information if you choose to provide us with access or permission:
§ Device Data. We automatically collect device information (such as your device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, and Internet Protocol (IP) address (or proxy server).
This information is primarily needed to maintain the security of licensing of our application, for troubleshooting, and for our internal analytics and product development purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
To secure our intellectual property our application may generate and store a hashed, anonymized device identifier associated with your license key, shared with us through periodic secure API calls. This identifier is used solely to validate your license key, to detect license violations (e.g. redistribution), and to check for available software updates.
Application Data. Our application is a locally installed Microsoft Excel add-in. We do not collect, transmit, or access the contents of any Microsoft Excel workbooks in which our application used. All workbook data remains strictly on your device and is not shared with or accessed by us under any circumstances.
Our application periodically initiates a secure API call to validate your license key and to check for available software updates. No local content from your workbooks is included in this validation.
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
§ To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
§ To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
§ To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
§ To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
§ To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
§ To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
§ Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
§ Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
§ Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
§ Send users information about special offers and discounts on our products and services
§ Understand how our users use our products and services so we can improve user experience
§ Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
§ If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
§ For investigations and fraud detection and prevention
§ For business transactions provided certain conditions are met
§ If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
§ For identifying injured, ill, or deceased persons and communicating with next of kin
§ If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
§ If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
§ If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
§ If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
§ If the collection is solely for journalistic, artistic, or literary purposes
§ If the information is publicly available and is specified by the regulations
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
§ Execution of Services. We may share your personal information when we believe it is necessary to provide our Services as directed by you, including to provide (or cease to provide) our Services through subscription management, product onboarding and offboarding. We may share your personal information with our third-party service providers to enable access and management of our Services.
§ Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user's account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at team@flowxl.com.
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information. If you would at any time like to review or change the information in your account or terminate your account, you can:
§ Log in to your account settings and update your user account.
§ Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at team@flowxl.com.
California law requires us to let you know how we respond to web browser DNT signals. Our Services are primarily not web browser-based and do not typically interact with DNT signals. Where our Services do otherwise interact with a browser, because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect. The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section 'WHAT INFORMATION DO WE COLLECT?'
A. Identifiers: Yes. Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
B. Yes. Personal information as defined in the California Customer Records statute: Name, contact information.
C. Protected classification characteristics under state or federal law: No.
D. Commercial information: No.
E. Biometric information: No.
F. Internet or other similar network activity: No.
G. Geolocation data: No.
H. Audio, electronic, sensory, or similar information: No.
I. Professional or employment-related information: Yes. Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
J. Education Information: No.
K. Inferences drawn from collected personal information: No.
L. Sensitive personal Information: No.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
§ Receiving help through our customer support channels;
§ Participation in customer surveys or contests; and
§ Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
§ Category A - As long as the user has an account with us
§ Category B - As long as the user has an account with us
§ Category C - As long as the user has an account with us
§ Category H - As long as the user has an account with us
§ Category I - As long as the user has an account with us
Sources of Personal Information. Learn more about the sources of personal information we collect in 'WHAT INFORMATION DO WE COLLECT?'
How We Use and Share Personal Information. Learn more about how we use your personal information in the section, 'HOW DO WE PROCESS YOUR INFORMATION?'
Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your Rights. You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
§ Right to know whether or not we are processing your personal data
§ Right to access your personal data
§ Right to correct inaccuracies in your personal data
§ Right to request the deletion of your personal data
§ Right to obtain a copy of the personal data you previously shared with us
§ Right to non-discrimination for exercising your rights
§ Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')
Depending upon the state where you live, you may also have the following rights:
§ Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
§ Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
§ Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
§ Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)
§ Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
§ Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)
How to Exercise Your Rights. To exercise these rights, you can contact us by emailing us at team@flowxl.com, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.
Request Verification. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at team@flowxl.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
California 'Shine The Light' Law. California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This Privacy Policy satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services, in particular:
§ offer you the products or services that you want
§ respond to or help with your requests
§ manage your account with us
§ confirm your identity and protect your account
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may email us at team@flowxl.com or contact us by post at:
FlowXL Software Pty Ltd
PO Box 175
Strawberry Hills, New South Wales 2012
Australia
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: www.flowxl.com.
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