This policy applies to the CASHFLOWNAV financial management services, website, software and all associated applications and services (Services), as provided by BUSINESSNAV (Aust) Pty Ltd ACN 629 874 773 (CASHFLOWNAV) and applies to anyone who accesses or otherwise uses the Services (you). This policy forms part of our Terms and Conditions of use of the Services.
CASHFLOWNAV is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your personal information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your personal information.
A copy of the APPs may be obtained from the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
1. Personal Information and why we collect it?
CASHFLOWNAV collects information that can be used to identify an individual (Personal Information). Examples of Personal Information we collect:
- contact information such as name, email address, street address and phone numbers;
- billing information such as credit card details, bank account details and billing address;
- accounting information (detailed below at clause 2);
- purchase and enquiry history with CASHFLOWNAV;
- business and financial situation details;
- current employee details and history;
- optional branding items; and
- any other information you disclose to CASHFLOWNAV through interacting with the Services, CASHFLOWNAV’s support team, or otherwise.
It is optional for you to provide CAHFLOWNAV with Personal Information. However, CASHFLOWNAV may not be able to provide some or all of the Services to you without certain Personal Information.
By providing CAHSFLOWNAV with Personal Information, to the extent consent is required by CAHSFLOWNAV, you consent to CASHFLOWNAV’s use of that Personal Information in accordance with this policy.
Other information that we collect for all users include notification and marketing preferences, and information about your interaction with the Services, as outlined in this policy.
This Personal Information is obtained from your use of the Services and from authorised third parties. We don’t guarantee website links or policy of authorised third parties. You may enter this information yourself, or alternatively, your name and email address may be entered by an account administrator to create an account on your behalf (usually someone from your organisation, or a trusted third party such as your accountant).
We collect your Personal Information for the primary purpose of providing the Services to you and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information we will, where appropriate and where possible, via the CASHFLOWNAV mobile application, explain to you why we are collecting the information and how we plan to use it.
2. Accounting Information
CASHFLOWNAV’s core activity is to provide the Services, which includes facilitating financial analysis and reporting on business entities such as companies and trusts. To provide the Services, CASHFLOWNAV allows you to import into our software and associated mobile application:
- accounting information related to an entity, such as chart of accounts, profit & loss and balance sheet; and
- other non-financial information related to the entity to supplement this accounting information, such as organisation details.
This information can be entered manually, uploaded from a spreadsheet you provide or imported directly from an authorised third party services, where you have given us permission to do so. In the latter case we securely store access tokens which allow us to update the accounting information in CASHFLOWNAV on your behalf.
3. How does CASHFLOWNAV collect Personal Information?
How CASHFLOWNAV collects and stores Personal Information depends on your use of the Services and how you choose to interact with the Services.
CAHFLOWNAV generally collects Personal Information directly from you in the following ways:
a. through your use of the Services;
b. through communications between you and CASHFLOWNAV support staff;
c. whenever you email us or upload any data to us via any software platform; and
d. whenever you participate in CASHFLOWNAV’s promotional offers or surveys.
Specifics of how CASHFLOWNAV collects Personal Information is further detailed below.
As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our websites and Services.
This information includes browser type, internet protocol address, language preference, App store, device information, and the date and time of each interaction.
Usage data & analytics
We collect usage data automatically as you interact with our Services. This data is useful for us as it helps us get a better understanding of how you are using our Services so that we can continue to provide the best experience possible, for example by personalising the content you see.
This information may include pages you visit, information on the device you are using, features you use or actions you take.
Occasionally we connect usage data to Personal Information in order to provide customer support or improve our Services for individual customers. Where this occurs, it is for internal use and the combined information is used in accordance with this policy.
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information about you or your business or related entities by third parties such as:
- your business partners or advisors;
- CASHFLOWNAV’s business partners and contractors, such as those who provide offers or services related to CASHFLOWNAV;
- through authorised third parties who liaise with us, or who we liaise with on your behalf as part of the Services; and
- third party services where you have connected your account with our Services (e.g. Xero).
In such cases we will take reasonable steps to ensure that you are made aware of the Personal Information provided to us by the third party.
4. How does CASHFLOWNAV hold the Personal Information we collect?
CASHFLOWNAV stores Personal Information physically at its business premises and/or in electronic form on secure cloud based storage or third party servers in Australia. Stored Personal Information may be combined or linked with any other information about you that CASHFLOWNAV holds, including any information CASHFLOWNAV receives from third parties
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
CASHFLOWNAV will only retain and handle your Personal Information for as long as necessary to:
- fulfil the purposes for which the Personal Information was obtained (e.g. to provide the Services);
- fulfil any other purpose you have consented to;
- exercise CASHFLOWNAV’s legitimate business purposes as outlined in section 5;
- comply with a legal obligation;
- protect vital interests of yourself or another person.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information.
5. How does CASHFLOWNAV use the Personal Information we collect?
CASHFLOWNAV collects, holds, uses and discloses Personal Information for its legitimate business purposes. These purposes include:
- provide, operate, maintain, improve and promote our Services;
- assess you identity and eligibility to use the Services;
- enable you to access and use our Services, including uploading information, downloading reports, collaborating on reports and sharing access with other users;
- process payments and send you related communications, including invoices;
- send you notices, product updates, security alerts, support and administrative messages;
- provide customer support and to help train support staff;
- monitor and analyse trends, usage, and activities in connection with CASHFLOWNAV Services and for marketing or advertising purposes;
- send promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, promotions, contests, events and providing other news or information about us and our select partners (you have the ability to opt out of receiving any of these communications);
- to provide information to CASHFLOWNAV’s related body corporate in order to carry out CASHFLOWNAV’s business operations;
- to provide information to CASHFLOWNAV’s external service providers including, but not limited to CASHFLOWSNAV’s data hosting partners and payment processing service providers;
- to provide to third parties where disclosed to you in this policy or otherwise authorised by you;
- to provide information to government or industry bodies;
- to understand user demographics and behaviour for the purpose of product development;
- to investigate and prevent unauthorised access to CASHFLOWNAV Services, and other illegal activities;
- to comply with our legal obligations, resolve disputes and enforce our agreements;
- as part of a transfer of CASHFLOWNAV’s assets should CASHFLOWNAV propose or proceed to sell, merge, seek investment in or otherwise alter ownership of CASHFLOWNAV or the Services;
- to exercise or defend CASHFLOWNAV rights, including disclosing information to credit reporting agencies, courts, tribunals and other regulatory agencies.
We don’t disclose your Personal Information to entities outside the CASHFLOWNAV group except as described in this policy. We will not sell or rent your Personal Information. We do not share your Personal Information with third parties for their marketing purposes (including direct marketing) without your consent.
Disclosure of Personal Information
When Personal Information is disclosed by CASHFLOWNAV to its related entities or third parties, as outlined in this policy, Personal Information will only be disclosed to that party to the extent necessary for the disclosure purpose identified in this policy to be carried out by that party.
CASHFLOWNAV carries on its business operations from Australia. Any Personal Information you provide CASHFLOWNAV with is disclosed to and stored on third-party data hosting servers located in Australia, to store data for the purposes outlined in this policy. Accordingly, CASHFLOWNAV may disclose your Personal Information outside of Australia. Where international disclosure of Personal Information is necessary, CASHFLOWNAV will take reasonable steps to ensure that overseas recipients, including CASHFLOWNAV data processors, handle Personal Information in accordance with this policy.
6. Other information and third parties
Whilst you are using the Services, CASHFLOWNAV, CASHFLOWNAV’s advertisers, business partners and other third parties may use various technologies to collect and hold information other than Personal Information. These technologies are used by CASHFLOWNAV for various reasons including to:
- store your username and password for any account you have with CASHFLOWNAV on a device;
- identify and track your IP address;
- collect and generate statistical, technical and descriptive information and reports about your use of the Services (Metadata);
- understand your demographic and location details;
- combine information about your usage patterns with similar information obtained from other users to help improve the Services;
- personalise advertising to suit your interests and prevent the same advertisements appearing to you repeatedly;
- conduct a statistical analysis of trends in usage of the Services and the internet generally or to provide information to third parties to allow them to do so; and
- provide Metadata, via sale or otherwise, to third parties, provided the Metadata does not contain Personal Information which has not been de-identified.
The information detailed above which is collected by CASHFLOWNAV may be disclosed to CASHFLOWNAV’s related entities, advertisers, third party service providers and business partners, but this information does not include Personal Information.
Any content, software or site that is created or hosted by a third party but is accessed by you via the Services (through embedding, hyperlink or otherwise), may be subject to that third party’s own privacy and data collection policies and practices which may vary from those of CASHFLOWNAV. CASHFLOWNAV cannot control or take responsibility for the use of tracking or data collection technologies implemented by third parties.
If you voluntarily disclose Personal Information via a publicly accessible feature of the Services, you do so at your own risk, as third parties may access and use this Personal Information to send you unsolicited material.
Please do not provide CASHFLOWNAV with Personal Information of a third party unless requested by CASHFLOWNAV. If you provide CASHFLOWNAV with Personal Information about a third party, you warrant that you have the consent of that third party to provide that Personal Information.
CASHFLOWNAV may use automated decision making or profiling technologies from time to time. This is to allow CASHFLOWNAV to show you content or marketing which is more personalised.
We reserve the right to modify this policy at any time. You are encouraged to periodically review this policy to stay informed of updates. Changes and clarifications will take effect immediately upon their posting on the application. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised policy by your continued use of the Services after the date such revised policy is posted.
8. Accessing, updating and deleting your Personal Information
You have a right to request access to and seek correction of any Personal Information CASHFLOWNAV holds about you, such as information which you believe is incorrect, incomplete, outdated, misleading or irrelevant. You may also request additional information from CASHFLOWNAV regarding the purposes for which CASHFLOWNAV processes your Personal Information and the types of third parties to whom CASHFLOWNAV discloses your Personal Information.
You can make the above requests via the contact details at the end of this policy or, where applicable, you can update your details via the Services. CASHFLOWNAV may charge a reasonable access fee if multiple requests for access are made by you.
9. Complaints and queries
If you have any complaints, comments or concerns regarding this policy, please contact CASHFLOWNAV directly via the details below. CASHFLOWNAV will endeavour to get back to you in a timely manner, however please allow up to 30 days for CASHFLOWNAV to respond before taking any other action.
CASHFLOWNAV will investigate your complaint in a timely manner and advise you of the outcome of its investigation, including what steps, if any, CASHFLOWNAV proposes to take to handle or remedy your complaint.
10. Contact details
For any queries in relation to this policy, please contact:
BUSINESSNAV (Aust) Pty Ltd
Privacy Compliance Officer
157 Given Terrace
Paddington QLD 4064
Last updated: [22/11/2021]