Privacy Policy
InLoop Pty Ltd (trading as Flexischools) is committed to protecting your privacy and this Privacy Policy explains how we may collect, use and disclose your Personal Information when you visit our Sites or use our Services.
By providing Personal Information to us and/or using our Services, you consent to our data practices, including the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy and any other arrangements that apply between us.
Depending on the services that we provide you, the information we seek may vary. If you choose not to provide us with this information, we may not be able to provide services to you.
Please contact us if you have questions about this policy, or your Personal Information.
The types of Personal Information that we collect and hold may include:
e-mail address;
name;
identified gender;
age or date of birth;
address;
organisation name;
telephone number;
account usage/transaction details;
your interests in our products and services;
school/class name;
information that you provide through customer surveys, feedback or customer service requests, and
any additional information relating to you that you provide us directly through our Sites, or indirectly through your use of our Sites (such as IP address).
We may collect your Personal Information:
when you:
use our Services or create an account with us;
download our App or visit our Sites;
communicate with us such as via phone calls, chats, email;
share information with us via social applications, services or websites;
interact with our Websites, Apps, Services, content and/or advertising and promotions; or
from public sources.
Giving us someone else’s Personal Information
You must ensure you are authorised to give us any other person’s Personal Information and you must inform that person of who we are and that we may use and disclose their Personal Information in accordance with this Privacy Policy.
If you are a parent or guardian giving us the Personal Information of a child in your care, please also see “Childrens’ Personal Information” below.
We may use your Personal Information to:
operate and provide our Services;
communicate with you about our Services;
conduct our own research, or to contact you for research purposes;
tailor our Services to you;
give you information about products and services we think you might be interested in;
assess, manage and respond to risks in our business;
create anonymised and deidentified data sets to help us understand our market and customers better; and
manage our responsibilities at law, including as a financial services licensee.
Direct Marketing
We may use your Personal Information to inform you of products or services we think may be of interest to you. The products and services may be provided by us, our affiliates or other approved third parties. These communications from us may take the form of emails, SMS, mail or other forms of communication, in accordance with all applicable laws.
Generally, we will provide direct marketing to you where you have consented to receiving it, including by accepting this Privacy Policy. If you do not wish to receive direct marketing, you can opt-out by using the relevant opt-out facilities provided (eg an unsubscribe link).
Disclosure of your data
We do not sell your Personal Information for marketing/advertising purposes.
We disclose your Personal Information to third parties including those who work with us to assist in our day-to-day business operations, and those who deliver any products and services that you order or request via our Service.
We may also disclose Personal Information for the following reasons:
in response to a legal request, such as a subpoena, court order, or demand;
to investigate or report illegal or suspected illegal activity;
to enforce or defend our rights or defend claims;
under exigent circumstances to protect the personal safety of our customers, or the public;
in connection with a corporate restructuring, such as a sale or merger, or asset transfer;
to third parties where you have expressly consented to the disclosure or your consent may be reasonably inferred from the circumstances; and
where we are otherwise permitted to disclose the information under the Privacy Act.
Anonymous information
We may disclose information associated with your use of our Service that is de-identified, or aggregated or otherwise made anonymous for any purpose including to third parties provided that, in so doing, we do not reveal any Personal Information.
Overseas handling
Some of our service providers may be located or use locations outside of Australia.
Where we share Personal Information overseas, we take steps to ensure that our service providers are obliged to protect this Personal Information in accordance with Australian legal requirements and that they are only permitted to use it for the purpose for which it is shared.
Our service providers or their data storage servers may be located, and may store your Personal Information from time to time, in the USA, European Economic Area, and Japan.
Childrens’ Personal Information
Our Services allow parents or carers to obtain services for the benefit of children in their care, in two ways:
by ordering products and/or services, or our Services, via their Account for a child in their care. This requires a parent/carer to give us:
(a). the child’s name, school, class and preferences, such as ordering selections (“Student Information”)., and
when enabled by an Account holder (“Account Holder”) we may permit the creation of a sub-account for a minor (“Student Account”). We do not allow the creation of a Student Account without consent from the Account Holder. At the time an Account Holder creates a Student Account, the Account Holder:
(a). will provide the student’s name and email address; and,
(b). may set a daily spend limit.
The Account Holder can see all activity in the Student Account and may delete the Student Account at any time.
We do not use Student Account email addresses or contact information for the purposes of marketing communication, however Student Account holders will receive service emails and alerts from us, such as purchase confirmations and low balance warnings.
Student Account information is not subject to any overseas data handling.
Our Services are not designed to enable minors to make their Personal Information publicly available online.
Security of your Personal Information
Your Personal Information is important to us. We design our systems with your security and privacy in mind.
The Personal Information we hold is generally stored electronically in cloud systems in Australia. We have a range of information security measures and encryption protocols when we hold your Personal Information to help protect it from unauthorised access, loss, misuse or wrongful alteration. These security measures include access controls and data encryption.
While there is no guarantee that Personal Information transmitted to other websites is fully secure, we will encrypt Personal Information in transit through the use of industry standard encryption methods.
4.4 If you are a user of our FLX Services, we encourage you to review the privacy policy of our FLX Card Issuer, EML Payment Solutions Limited (ABN 93 104 757 904) at www.emlpayments.com/privacy
Payment information
We do not record or store your payment card details.
Payment card details entered into the Service are transmitted using industry-standard encryption to our e-commerce payment gateway provider (PayPal Australia Pty Limited), where they are held by that provider or its financial institution for the purpose of processing payments arising from your use of the Site.
Further details on how PayPal treats your payment card-related information may be found by visiting the PayPal Privacy Policy available at: https://www.paypal.com/au/webapps/mpp/ua/privacy-full?locale.x=en_AU.
Use of cookies
A cookie is a small file used to uniquely identify a website or application visitor’s browser or to store information or settings in the browser.
Cookies used on our Sites and Services:
enable our Site to remember visitors, so that we can personalise our Site content to you,
enable the features of the Sites and Services;
help prevent fraud;
help us to manage and monitor our Site and Service performance;
help us understand how visitors use our Site and Services;
collect information and report Site usage statistics without personally identifying individual visitors to our Site.
Most browsers and software accept cookies by default, but you can clear and deactivate them through your browser’s settings. However, if you turn off cookies or change your settings, some features of our Site and Service may not work as we intend.
Our collection of data as set out in this clause and Privacy Policy generally may occur directly by us, through electronic means (for example when you visit our Sites), or through third party service providers.
Third party links on our site
We may include links to other websites through the Services or on our Site.
We encourage you to review the privacy policies of any such web sites you visit so that you can understand how those web sites collect, use and share your information. We are not responsible for the use, access, storage or treatment of your data (including Personal Information) and the privacy Policies or other content on web sites or applications outside of our Sites or our Apps.
Access to your Personal Information
Upon request, we will provide you with access to your Personal Information held by us, except in circumstances where refusing you access is required or authorised by law.
To request access to the information held by us about you, please contact us using the contact details listed below. We will respond to your request within a reasonable time after the request is made, and will advise any additional steps we may need to take to verify your identity before providing information, and if we will not or cannot provide you access, together with the reasons for denying you access.
We reserve the right to charge you for providing access to your Personal Information. We will notify you of those costs prior to providing you with access to the information. We may require those costs to be paid prior to providing you with access.
Correction of Personal Information
We take reasonable steps to ensure that the Personal Information collected by us is accurate, complete, relevant and up to date. If you believe that any of the Personal Information we hold about you requires correction, please inform us in writing using the contact details set out below.
Contact details
Please direct any correspondence in relation to your Personal Information or this Privacy Policy to:
Flexischools Privacy Officer
by email to: privacy@flexischools.com.au
by post to: PO Box 1157 Manly NSW 2095
How to make a complaint
If you have a complaint about how we have collected, used or disclosed your Personal Information, or if we have not corrected or provided you with access to your Personal Information, then you may contact our Privacy Officer using the contact details above so that we can investigate the complaint and respond to your concerns.
If you are not satisfied with our response, you can submit a complaint to The Office of the Australian Information Commissioner: http://www.oaic.gov.au/privacy/privacy-complaints.
Changes to this Policy
We may occasionally update this Privacy Policy, including to reflect school and community feedback and encourage you to periodically check our Sites and review this Privacy Policy to be informed of any changes to how Flexischools is protecting your information.
An up-to-date version of this Privacy Policy may be found through our Sites.
Definitions
InLoop means InLoop Pty Ltd (ABN 27 114 508 771 and AFSL 471558) including trading under the business names of Flexischools and Flexibuzz;
Personal Information includes any information or opinion, about an identified individual or an individual who can be reasonably identified from their information. The information or opinion will still be Personal Information whether it is true or not and regardless of whether we have kept a record of it;
Privacy Act means the Australian Privacy Act 1988 (Cth);
Sites means the websites, mobile apps, official social media platforms or other online properties through which InLoop offers the Services and which has posted or linked to this Privacy Statement;
Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by InLoop (including under the business names or product names Flexischools and Flexibuzz, ROVR or FLX); and
We, us or our means InLoop.
Last updated
11 December 2023
Version 2.0