Privacy Policy

Last updated: 16 July 2026

1. About this Privacy Policy

flowprofiler® Pty Ltd respects your privacy and is committed to handling personal information responsibly, transparently and securely.

This Privacy Policy explains how we collect, hold, use and disclose personal information. It also explains how you may access or correct your information, exercise applicable privacy rights or make a complaint.

This policy is intended to meet applicable requirements under:

  • the Australian Privacy Act 1988 and Australian Privacy Principles;
  • the United Kingdom General Data Protection Regulation and Data Protection Act 2018; and
  • the European Union General Data Protection Regulation,

in each case where those laws apply to our activities.

2. Who we are

flowprofiler® Pty Ltd is an Australian company that publishes and delivers psychometric assessments, behavioural intelligence products, professional development services, training, coaching and related technology.

Contact details
flowprofiler® Pty Ltd
33 Oxley Crescent, Mollymook Beach, NSW, 2539
Australia

Email: hello@flowprofiler.com | Website: www.flowprofiler.com

Data Protection Lead: Rebecca Chalmers Privacy and data-protection enquiries may be sent to hello@flowprofiler.com.

3. Our role when processing personal information
Our legal role depends on the circumstances in which information is processed.

When we act as a controller
flowprofiler® Pty Ltd acts as a controller where we decide why and how personal information will be processed. This generally includes information relating to:

  • website visitors and people who contact us;
  • direct customers;
  • client representatives;
  • trainers, consultants and delivery partners;
  • suppliers and professional advisers;
  • marketing contacts;
  • job applicants, employees and contractors;
  • complaints and privacy requests; and
  • the administration, security and operation of our business.

When we act as a processor
When an organisation purchases or commissions an assessment, survey, training programme or related service for its employees, candidates, leaders or other participants, that organisation will generally be the controller and flowprofiler® Pty Ltd will act as its processor.

In those circumstances, we process participant information on the client’s documented instructions and under an appropriate data-processing agreement.

The client is responsible for determining:

  • why the assessment or service is being used;
  • the lawful basis for collecting and processing participant information;
  • who will receive or have access to results;
  • how results will be used in employment, recruitment or development decisions; and
  • what information must be provided to participants.

Where a privacy request relates to information that we process solely on behalf of a client, we may refer the request to that client or assist the client in responding.

4. Personal information we collect and hold

  • Depending on your relationship with us, we may collect and hold:
  • Identity and contact information: This may include your name, email address, telephone number, country, organisation, position or professional role.
  • Account and platform information: This may include usernames, account identifiers, access permissions, authentication information, account activity and service history.
  • Assessment and survey information: This may include: assessment or survey responses; psychometric scores and dimension results; behavioural profiles and reports; assessment completion status and dates; self-ratings and ratings provided by other authorised participants; written comments provided through surveys or 360-degree assessments; and information required to administer, interpret or deliver an assessment,
  • Training and professional development information: This may include programme registrations, attendance, completion records, certifications, learning activities, feedback and information you choose to provide during training, coaching or professional development activities.
  • Client and commercial information: This may include contracts, orders, invoices, payment status, correspondence, service requirements and records of products or services provided.
  • Payment-card details may be processed directly by an authorised payment provider rather than being stored by us.
  • Website and technical information: This may include your IP address, browser type, device information, approximate location, referring website, pages viewed, dates and times of access, website logs, cookie identifiers and information submitted through online forms.
  • Communications and marketing information: This may include enquiries, correspondence, meeting records, communication preferences, event registrations and records of marketing communications.
  • Employment and supplier information: This may include qualifications, professional history, references, contractual information, financial or payment information and other information reasonably required to manage employment, contractor, trainer, supplier or professional relationships.
  • Complaints and privacy requests: This may include information required to investigate and respond to a concern, complaint, access request, correction request or other privacy-related communication.

We do not intentionally collect sensitive or special-category information unless it is reasonably necessary, appropriately disclosed and collected with consent or another valid legal authority.

5. How we collect personal information
We may collect personal information:

  • directly from you;
  • from a client, employer or organisation that has invited you to participate;
  • from authorised trainers, consultants, coaches or delivery partners;
  • from people providing ratings or feedback through an authorised assessment;
  • through our websites, platforms, forms, cookies and related technologies;
  • from service providers supporting our business systems;
  • through professional referrals or business introductions; and
  • from publicly available professional or business sources where permitted by law.

Where practicable, you may contact us without identifying yourself or by using a pseudonym. We will normally need accurate identifying information to provide platform accounts, assessments, reports, certifications, contractual services or responses to privacy requests.

6. Why we process personal information
We may collect, hold, use or disclose personal information to:

  • create and administer user accounts;
  • administer assessments, surveys and development programmes;
  • calculate scores and generate authorised reports;
  • provide training, coaching, facilitation and professional services;
  • communicate with participants, clients, trainers and partners;
  • provide technical and customer support;
  • fulfil contracts and manage client relationships;
  • process orders, invoices and payments;
  • maintain business, accounting and compliance records;
  • protect our platforms, users, intellectual property and systems;
  • prevent or investigate misuse, security incidents or fraud;
  • manage trainers, employees, contractors and suppliers;
  • respond to enquiries, complaints and privacy requests;
  • meet legal, regulatory, insurance and contractual obligations;
  • establish, exercise or defend legal claims;
  • improve the accessibility, functionality and quality of our products and services;
  • conduct appropriately authorised, aggregated or de-identified product, benchmarking or psychometric research; and
  • communicate relevant information about our products, services and events where permitted by law.

We will not use identifiable assessment information for a materially different purpose without an appropriate legal basis, client authority where required, and any necessary notice or consent.

7. Lawful bases under UK and European data-protection law
Where UK or European data-protection law applies and we act as controller, we generally rely on one or more of the following lawful bases:

  • Contract: processing is necessary to enter into or perform a contract.
  • Legitimate interests: processing is reasonably necessary to operate, secure and improve our business, provide services, manage professional relationships or conduct appropriate business-to-business communications, provided those interests are not overridden by an individual’s rights.
  • Legal obligation: processing is necessary to comply with applicable legal or regulatory requirements.
  • Consent: you have given clear consent for a particular use and may withdraw that consent.
  • Where we act as a processor, the client controller is responsible for identifying and communicating the lawful basis for the processing.
  • Where sensitive or special-category information is processed, an additional lawful condition will be identified where required.

8. Psychometric scoring and profiling
Our assessment platforms use established scoring rules and algorithms to convert participant responses into assessment scores, profiles and reports. This may constitute profiling under applicable data-protection law.
The scoring process may consider:

  • responses provided by the participant;
  • responses or ratings provided by authorised raters;
  • scoring keys and validated assessment scales;
  • applicable comparison or norm groups; and
  • rules used to generate report content.

The platform does not itself decide whether a person should be employed, promoted, dismissed, disciplined, selected for development or given another employment-related outcome.

Clients and suitably qualified human decision-makers remain responsible for interpreting reports and making decisions. Assessment information should not ordinarily be used as the sole basis for a decision that has a legal or similarly significant effect on an individual.

Where applicable, you may ask for information about the processing, request human consideration, express your point of view or contest a solely automated decision.

9. Who may receive personal information

  • We may disclose personal information, where reasonably necessary, to:
  • the client or organisation that commissioned an assessment or service;
  • the individual to whom an assessment report relates;
  • authorised client administrators, managers or decision-makers;
  • authorised trainers, coaches, consultants and delivery partners;
  • assessment participants or raters where the service requires their involvement;
  • hosting, software, information-security and technical-support providers;
  • email, customer-relationship, communications and document-management providers; payment, banking, accounting and financial-service providers; professional advisers, auditors, insurers and legal representatives;
  • regulators, courts, law-enforcement bodies or government authorities where legally required;
  • a prospective purchaser or successor in connection with a genuine business transaction; and other parties where you have authorised the disclosure.

Access to assessment results is limited according to the service arrangement, client instructions and applicable platform permissions.

We do not sell personal information!

10. Overseas processing and disclosure
flowprofiler® Pty Ltd is based in Australia and provides services internationally. Personal information may therefore be processed or made accessible in Australia and in other countries where our clients, authorised delivery partners or service providers operate.

Countries in which recipients or service providers may be located currently include:

  • Australia
  • United Kingdom
  • Mexico
  • Japan
  • Malaysia
  • Singapore
  • New Zealand

Before disclosing personal information overseas, we take reasonable steps appropriate to the circumstances to assess the recipient and protect the information.

Where UK or European transfer restrictions apply, we use an appropriate transfer mechanism where required. This may include contractual safeguards, approved standard contractual clauses, the UK International Data Transfer Agreement or UK Addendum, adequacy arrangements or another lawful transfer mechanism.

Further information about relevant international service providers and safeguards may be requested by contacting hello@flowprofiler.com.

11. Security
We use reasonable technical and organisational measures designed to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.
Depending on the information and processing involved, these measures may include:

  • role-based access controls;
  • account and authentication controls;
  • secure hosting and transmission measures;
  • system monitoring and logging;
  • backup and recovery processes;
  • contractual confidentiality and security requirements;
  • supplier and processor review;
  • data-protection and security procedures; and
  • incident identification and response processes.

No internet transmission or information-storage system can be guaranteed to be completely secure. We regularly review our safeguards in light of the nature of the information, available technology and relevant risks.

12. Retention and deletion
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to meet applicable contractual, legal, accounting, insurance, security and dispute-resolution requirements.

When we act as a processor, assessment and participant information is retained and deleted in accordance with our contract with the client, the client’s lawful instructions and applicable legal requirements.

In determining an appropriate retention period, we consider:

  • the nature and sensitivity of the information;
  • the purpose for which it is held;
  • the duration of the client or professional relationship;
  • contractual commitments;
  • applicable limitation periods;
  • legal and regulatory obligations;
  • security and fraud-prevention requirements; and
  • whether the information can be securely deleted or de-identified.

When personal information is no longer required, we take reasonable steps to securely delete, destroy or permanently de-identify it.

13. Direct marketing
Where permitted by law, we may use professional contact information to communicate about relevant flowprofiler® products, services, publications, programmes or events.
You may opt out at any time by:

  • using the unsubscribe option in a marketing email; or
  • contacting hello@flowprofiler.com.

We will action an opt-out request without charge. Opting out of marketing will not prevent us from sending essential service, contractual, security or administrative communications.

14. Cookies and website technologies
Our websites may use cookies and similar technologies for:

  • essential website functionality;
  • security;
  • remembering user choices;
  • understanding website usage and performance; and
  • other purposes described in our Cookies Policy and consent-management tool.

Where consent is legally required, non-essential cookies will not be activated until the appropriate consent has been provided.

You may review or change your cookie choices through the cookie-management controls available on our website.

15. Your privacy rights

Your rights depend on your location, the law that applies and whether flowprofiler® Pty Ltd is acting as controller or processor.

Australian privacy rights
Where Australian privacy law applies, you may:

  • request access to personal information we hold about you;
  • ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading; and
  • make a complaint about how your personal information has been handled.

UK and European privacy rights
Where UK or European data-protection law applies, you may have the right to:

  • be informed about the processing of your personal information;
  • request access to your personal information;
  • request correction of inaccurate or incomplete information;
  • request deletion in certain circumstances;
  • request restriction of processing in certain circumstances;
  • object to processing, including processing for direct marketing;
  • request the portability of certain information;
  • withdraw consent where processing is based on consent;
  • raise concerns about profiling or qualifying automated decisions; and
  • complain to an appropriate supervisory authority.

These rights are not absolute and may be subject to legal exceptions.

We do not normally charge for a privacy request. A fee may be permitted in limited circumstances under applicable law. We may request sufficient information to verify your identity and locate the relevant records.

Where flowprofiler® Pty Ltd processes information solely on behalf of a client, the request may need to be made to, or managed in consultation with, that client.

To exercise a right, contact hello@flowprofiler.com.

16. Privacy complaints

Please contact us first if you believe we have mishandled your personal information.

Send your complaint to:

Data Protection Lead flowprofiler® Pty Ltd
Email: hello@flowprofiler.com

Please include enough information for us to understand and investigate the concern. We will acknowledge the complaint and aim to provide a substantive response within 30 days. If additional time is reasonably required, we will explain why.

Depending on where you are located, you may also have the right to complain to:

  • the Office of the Australian Information Commissioner;
  • the United Kingdom Information Commissioner’s Office; or
  • the data-protection supervisory authority in the European Economic Area country where you live, work or believe an infringement occurred.

17. UK and European representatives

United Kingdom representative: [Insert the name and contact details of the formally appointed UK representative, if required.]

18. Information you choose not to provide

You are not generally required by law to provide personal information to us.

However, if you do not provide information that is required to create an account, administer an assessment, produce a report, verify your identity or deliver a contracted service, we may be unable to provide some or all of the requested service.

Your employer or commissioning organisation should separately explain whether participation in a particular assessment or programme is required and any consequences of not participating.

19. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our business, technology, information-handling practices or legal obligations.

The current version will be published on our website and will show the date it was last updated. Material changes may also be communicated through an appropriate additional notice.

20. Contact us

Questions, requests or complaints concerning privacy may be directed to:

Data Protection Lead flowprofiler® Pty Ltd
33 Oxley Crescent
Mollymook Beach
NSW 2539 Australia
Email: hello@flowprofiler.com