Privacy Policy

WeFlow

1. General

1.1 This Privacy Policy (“Privacy Policy”) applies to all Personal Data collected by Winways Aurora Pty Ltd (ACN 633 611 444) a proprietary limited company registered in Australia (together, “Winways”, “WeFlow”, “we”, “our” and “us”).

1.2 Winways is committed to complying with its obligations under applicable Data Protection Laws. BY ACCESSING AND USING THE SERVICES OR ENGAGING IN COMMUNICATIONS WITH US, YOU AGREE TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY AND TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY.

1.3 In this Privacy Policy, we explain how and why we collect Personal Data about you, how we use, share and protect it, and what controls you have over our use of it. Please read this Privacy Policy carefully. If you do not agree with the terms and conditions of this Privacy Policy, please do not use our Websites and Services.

2. Definitions

2.1 In this Privacy Policy:

3. Types of Personal Data We Collect

3.1 We may collect, use, store and transfer various types of Personal Data, including:

3.2 Where we solicit Personal Data, we only collect:

3.3 We may collect various other types of Personal Data, including Sensitive Information, in the course of conducting our business where it is provided to the users of the Services or other persons without being solicited, in accordance with clause 11.

4. How We Collect Personal Data

4.1 We may collect Personal Data about you through any of the following methods:

4.2 If we solicit Personal Data, we will generally solicit it directly from the person it relates to or their agents, unless it is unreasonable or impracticable for us to do so. Where we collect Personal Data about you from a third party without your prior consent, we will take reasonable steps to inform you that we have collected Personal Data. We may combine Personal Data from multiple online and off-line sources.

4.3 It is voluntary to provide Personal Data to us, but if you choose not to provide certain Personal Data, we may not be able to provide the requested Services. You have the right to deal with us anonymously or under a pseudonym unless it is impracticable for us to do so or unless we are required or authorised by law to only deal with identified individuals.

4.4 Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that information when requested or withdraw your consent to us processing your Personal Data (where applicable) we may not be able to perform the contract we have or are trying to enter with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

5. How We Store and Protect Personal Data

5.1 We prioritise the security of your Personal Data whilst it is in our possession. We may hold Personal Data in various forms, including but not limited to physical documents, electronic records, visual records, and audio recordings. We use commercially reasonable efforts to keep physical files securely inside our access-controlled premises and store electronic files securely on protected information systems. Electronic files are only accessible through our secure network. Our staff members and contractors are bound by confidentiality agreements or professional confidentiality responsibilities.

5.2 We take reasonable steps to:

5.3 We cannot guarantee the security of information transmitted via the internet. As such, transmission of Personal Data via the internet is at your own risk and we cannot be held responsible for the security of such information.

5.4 We will notify you and/or any applicable supervisory authority of a data security breach where the Data Protection Laws in that jurisdiction require us to do so, and within the timeframe required by the relevant Data Protection Laws.

6. How We Use Your Personal Data

6.1 We may collect, hold, use, and disclose your Personal Data for the following purposes:

7. How We May Share or Disclose Personal Data

7.1 We may share your Personal Data within the Group and with the Group’s respective officers, directors, employees, accountants, attorneys and agents in order to provide and improve the Services, to ensure complete Account and customer profiles and transaction records for the Services, and to allow you to sign in, manage and access information in your Account for any of our and the Group’s Websites and Services, and for marketing purposes.

7.2 We may hire third party providers and contractors to provide limited services on our behalf, such as hosting our Websites, conducting marketing activities, reviewing and verifying information via AI Products, installing products for you as part of your requested Services, processing payment transactions, or performing statistical analysis of our Services. We will use commercially reasonable efforts to only provide those third parties with the Personal Data they need to deliver the specific services and take reasonable steps to ensure that these third parties maintain the confidentiality of your information and are prohibited from using that information except for the purposes for which it was supplied.

7.3 Winways does not store Financial Data that is collected and processed for billing or payment purposes on servers and equipment it controls. This Personal Data is stored on servers and other equipment managed by the third party Payment Processors and Payment Facilitators as described under this Privacy Policy.

7.4 Winways may disclose your Personal Data, without your notice or prior consent, only for the purposes set out above or in relation to:

7.5 We may ask, from time to time, if you would like us to share Personal Data about you with affiliated or unaffiliated third parties. We will only disclose your information in this context with your consent. If you do not provide consent, we may not be able to provide you with the requested information and/or Services.

8. Disclosure of Sensitive Information

8.1 Collection of information for verification purposes may involve collection of Sensitive Information (for example, photos of you which indicate racial or ethnic origin or religious affiliation). We will not disclose Sensitive Information about you to third parties unless the disclosure is necessary for the purposes for which the Sensitive Information was collected (such as verifying your identity via AI Products), or otherwise with your consent or as authorised or required by law.

9. Australia

9.1 In Australia, the legal basis for our processing of your Personal Data (other than Sensitive Information) is notification in accordance with Australian Data Protection Laws. With respect to Sensitive Information, we require your consent for its collection, use, and disclosure. Consent may be implied by the circumstances existing at the time of collection (such as by you agreeing to submit Sensitive Information to us). There may also be circumstances under which we may collect Sensitive Information without your consent, as required or authorised by law.

9.2 To the extent that we processed your Personal Data before the commencement date of the relevant Data Protection Laws in Australia, you consent to us continuing to process such Personal Data in accordance with this Privacy Policy.

10. Direct Marketing

10.1 We will only send you direct marketing communications and information via mail, email, and social media platforms about our Services with your consent.

10.2 If you do not provide your consent to receive direct marketing communications, you may opt-out of receiving marketing communications from us by contacting us at the details below in this Privacy Policy or by using opt-out facilities provided in our communications. Please note that certain email communications that are transactional in nature (for example, emails about your order, or a change in terms and features of your Account) may not contain an unsubscribe link or opt-out instructions.

10.3 We do not provide your Personal Data to other organisations for the purposes of their direct marketing. Winways’s practices in regard to its email are designed to be compliant with anti-spam laws, including Australia’s Spam Act 2003 and the American CAN-SPAM Act.

10.4 If you believe you have received mail(s) or email(s) from us in violation of these laws or any other anti-spam law, please contact us using the contact information in this Privacy Policy.

11. Unsolicited information

11.1 If you provide Personal Data that we have not requested, we will only retain it in limited circumstances. We will only Process the unsolicited information if: (i) it is reasonably necessary for us to provide you with the Services, and; (ii) you have either expressly consented to the information being collected and used by Winways, or it was not practical or reasonable for us to obtain your consent under the circumstances and Winways’s use of Personal Data about you is permitted under applicable Data Protection Laws.

11.2 If these conditions are not met, we will destroy the unsolicited information. If the unsolicited information we receive about you is Sensitive Information, we will always obtain your consent.

12. Children’s Privacy

12.1 The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

12.2 As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 18 years of age.

13. Third-party Sites

13.1 For your convenience and to improve the usage of the Website and Services we may insert links to third-party websites, applications, or resources, for which this Privacy Policy does not apply.

13.2 Winways is not responsible for those third-party websites, applications, or resources. If you access such websites, applications, or resources, you do so at your own risk, and we make no representations or warranties regarding third parties’ privacy practices. We encourage you to read the privacy statements/policies of every website, application, or resource you use.

13.3 When we do link to a third-party website, application, or resource, this does not automatically imply that Winways endorses that website, application, resources, and their contents. Our Privacy Policy does not cover the use of cookies by any third parties.

14. Data Retention

14.1 We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

14.2 To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means.

14.3 We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

14.4 In some circumstances you can ask us to delete Personal Data about you in accordance with applicable Data Protection laws, as set out in this Privacy Policy.

14.5 We delete Personal Data within a reasonable period after we no longer need to use it for the purpose for which it was collected (or for any subsequent purpose that is compatible with the original purpose). This does not affect your right to request that we delete your Personal Data before the end of its retention period. We may archive Personal Data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures.

14.6 Where we anonymise your Personal Data consistent with applicable Data Protection Laws and industry standards (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.

15. Changes to this Privacy Policy

15.1 The date at the top of this page indicates when this Privacy Policy was last updated. From time to time, we will have to modify or update this Privacy Policy, so please review it periodically.

15.2 We reserve the right to make amendments to this Privacy Policy at any time. You can find the latest version of this Privacy Policy on our Websites and it will apply to all your Personal Data held by us at that time. We will post a notice on the Website if we make a material change, in our sole discretion. If you have provided us with an email address as part of your interactions with Winways, we may also email you to tell you the Privacy Policy has been updated, and what the material change is. We do not ordinarily provide advance notice of a minor change. Historic versions of this Privacy Policy can be obtained by contacting us. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to our Websites.

15.3 It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

16. Your Privacy Choices

16.1 Depending on the jurisdiction in which you live, you may have certain rights with respect to Winways use and disclosure of your Personal Data. You may request to access, correct, or delete your Personal Data, or object to or ask us to restrict our processing of your Personal Data by submitting a request via the contact information listed in clause 17 (How to Contact Us) below. We will review all such requests in accordance with applicable Data Protection Laws. We may need to verify your identity before actioning your request. In certain circumstances, we may not be able to completely remove your Personal Data from our systems, as further discussed in clause 15 (Data Retention). If we are not able to provide the information or make the change you requested, you will be provided with the reasons for such decisions. You may be entitled, however, to appeal our decisions and can do so by following the instructions provided in the correspondence we send to you communicating our decision. Under local law, you may also be entitled to lodge a complaint with your local data-protection authority.

16.2 This clause 16.2 applies to you if and when AU Privacy Act applies to Personal Data about you:

16.3 You may learn more about internet advertising practices and related consumer resources, and opt out from targeted advertising at https://youradchoices.com/control/, https://optout.networkadvertising.org/?c=1, and https://youronlinechoices.eu/. PLEASE NOTE: We do not operate or control these third party services, and there may be additional ways for you to opt out of online advertising. By opting out, you will continue to see ads, but ads may not be as relevant to your interests.

16.4 For more information on Google Analytics’ processing of your Personal Data, please see “How Google uses information from sites or apps that use our services.” You can opt out of Google Analytics by installing Google’s opt-out browser add-on. You can find more information on data processing by Google at https://policies.google.com/privacy?hl=en.

16.5 For more information on how your Personal Data is processed, used, stored and disclosed using AI Products provided by Google (i.e. Gemini for Google Workspace (Enterprise)), please see Google’s terms and conditions at https://workspace.google.com/terms/premier_terms/, as updated by Google from time to time.

16.6 Various browsers (i.e., Internet Explorer, Chrome, Firefox, Edge, etc.) allow a “do not track” (“DNT”) setting, which sends a signal to websites visited by an individual about their browser DNT setting. At this time, there is no general agreement on how companies, like us, should interpret DNT signals. Therefore, at this time our Services do not respond to “Do Not Track” signals transmitted by browsers.

17. How to Contact Us

17.1 If you have any questions or concerns about this Privacy Policy or would like to exercise your rights in relation to Personal Data we hold about you under applicable Data Protection Laws, please contact us at:

WINWAYS Aurora Pty Ltd
Address: 31/40 Pavesi St, Smithfield NSW 2164 Australia
info@winways.com.au
+61 02 8348 4125