Privacy Policy
Effective Date: January 20, 2026
1. Our Commitment to Privacy
Fluent ("we," "us," or "our") is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy outlines how we collect, use, disclose, and safeguard your personal information.
If we handle information on behalf of our clients as a service provider (e.g., managing a client’s IT environment), we act as a "data processor." In these cases, the client’s privacy policy applies, and inquiries should be directed to them.
2. Personal Information We Collect
We only collect personal information that is reasonably necessary for our business functions as an MSP and cybersecurity provider.
Information Collected Directly
Contact Details: Name, email address, Australian business address, and phone number.
Professional Info: Job title, organization, and technical requirements.
Account Credentials: Usernames and authentication data for accessing our support portals or managed services.
Billing Information: ABN, credit card details, and transaction history.
Information Collected Automatically
Technical Data: IP addresses, device identifiers, and system logs collected when you interact with our website or use our software tools.
Security Telemetry: As part of our cybersecurity services, we may process metadata related to network traffic and system activity to identify threats.
Sensitive Information
We do not typically collect "sensitive information" (e.g., health data, political affiliations). If we are required to do so, we will obtain your explicit consent unless an exception applies under the Privacy Act.
3. How We Use Your Information
We use your information for the primary purpose for which it was collected, including:
Service Delivery: Providing IT support, cybersecurity monitoring, and cloud management.
Communication: Sending service updates, security alerts, and responding to inquiries.
Compliance: Meeting our legal obligations, including the Cyber Security Act 2024 regarding ransomware reporting.
Marketing: Providing information about new services, provided you have opted in (see Section 7).
4. Disclosure and International Transfers
We may disclose your personal information to third-party service providers (such as cloud hosting partners or software vendors) to facilitate our services.
Overseas Disclosure: We may disclose information to recipients outside of Australia (typically in the USA, EU, or UK).
Safeguards: Before disclosing information overseas, we take reasonable steps to ensure the recipient complies with the APPs or is subject to a law that provides substantially similar protection.
5. Security and Data Breach Notification
Security is at the core of our business. We maintain robust technical and organizational measures, including multi-factor authentication (MFA) and encryption at rest and in transit.
NDB Scheme: Under the Notifiable Data Breaches (NDB) scheme, we are required to notify you and the Office of the Australian Information Commissioner (OAIC) if we experience a data breach likely to result in serious harm.
Your Role: You are responsible for the security of your own credentials and ensuring your systems meet the minimum standards outlined in our service agreements.
6. Automated Decision-Making (ADM)
Notice: From December 2026, new transparency rules apply to decisions made by computer programs.
Fluent may use automated systems for threat detection and fraud prevention. While these systems primarily secure your environment, if an automated decision significantly affects your rights or interests, you have the right to request a human review.
7. Your Rights and Choices
Under the APPs, you have specific rights regarding your personal information:
Access and Correction: You may request access to the personal information we hold about you or ask us to correct inaccuracies. We will respond within 30 days.
Anonymity: Where practical, you may interact with us anonymously or using a pseudonym (e.g., making a general inquiry).
Direct Marketing: You can opt-out of marketing communications at any time via the "unsubscribe" link in our emails or by contacting us directly.
Complaints: If you believe we have breached the APPs, please contact our Privacy Officer (details below). If you are not satisfied with our response, you may complain to the OAIC.
8. Contact Us
For any privacy-related inquiries, please contact our Privacy Officer:
Email: info@fluent.com.au