DATA PRIVACY

At Inflo we are committed to protect and respect your privacy in compliance with data protection regulation. Inflo’s systems and data processing mechanisms are designed to comply in accordance with world-renowned data protection regulations such as; Data Protection Act 2018, EU-GDPR, UK-GDPR, and the California Consumer Privacy Act. Please contact a member of Inflo’s Customer Success Team if you would like to verify Inflo’s compliance to a specific data protection regulation. This privacy statement explains when and why we collect personal data, how we use it, the conditions under which we may disclose it to others, and how we keep it secure.

Inflo provides next generation financial analysis technology as a service to support accounting firms’ professional services. Inflo products deliver the ability to extract data from the accounting system of an organisation, providing accountants with a broad range of financial analysis to interpret.

Inflo processes data extracted from accounting systems on your behalf as instructed by you within our agreement. We use this input data to calculate KPIs and statistics which are provided to you and your users. This data is also anonymized, aggregated and used to generate benchmarking statistics, for example, to compare profit margins with businesses in the same industry (end clients are able to opt out of benchmarking when they join Inflo if they do not wish their data to be used in this way). Inflo Ingest is designed to extract only general ledger transaction records based on parameters specified by the user.

Inflo Collaborate also stores files requested from end clients by accounting firms to support accounting procedures. Information shared in this way is specified by the accounting firm.

Information processed by Inflo Ingest and Inflo Collaborate may include personal data where this has been included by end clients in general ledger transaction records (e.g. transaction descriptions) and files (e.g. payroll records). This data is only used to perform our obligations to you under the contract. For this purpose, Inflo acts as the processor of personal data. You should not transfer personal data to us unless you believe it is absolutely necessary.

In addition, we may also capture personal data to:
-- Authenticate users on the Inflo platform using cookies and user account information
-- Respond to feedback, comments and questions received from you in service-related communication and activities, such as webchat sessions, phone calls, documents, and emails
-- Send you information about our company, services, events and activities
-- Perform direct marketing activities in cases where legitimate and mutual interest is established, and if the privacy interests of the data subjects do not override this interest. By accepting Inflo’s data privacy statement you consent to receiving marketing communications. You can withdraw this consent at any time by contacting us at sayhi@inflosoftware.com
‍ -- Reply to ‘Contact me’ or other web forms you have completed on the Inflo website
-- Perform contractual obligations such as order confirmation, invoicing and similar
-- Notify you about any disruptions to our services
-- Contact you to conduct surveys about your opinion on our services
-- Process a job application

For these purposes, Inflo acts as the processor of personal data.

Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you.

Inflo has in place strong technical and organizational measures to protect against unauthorized, unlawful or accidental processing, destruction, loss, alteration, disclosure of, or access to personal data. Inflo’s approach to information security has been certified to the International Standard on Information Security Management (ISO 27001).

Data is stored and processed on Microsoft’s Azure Cloud Platform and Azure Cloud Services which are also certified to ISO 27001, as well as the Code of Practice for Protection of Personally Identifiable Information in Public Clouds (ISO 27018). Microsoft Azure acts as a sub-processor of data in providing these services.

All client input data is encrypted, whether in transit or at rest, using a combination of Azure’s Storage Service Encryption (SSE) and Hypertext Transport Protocol over certified secure socket layer (SSL). A minimum of 256-bit AES is used for encryption at rest and transmission.

Inflo employees processing data are subject to a duty of confidence and we perform data protection risk assessments as required to ensure that all customer data is appropriately protected.

We will inform you within five business days if any personal data processed is lost, destroyed, damaged, corrupted, becomes unusable or is otherwise subject to unauthorized or unlawful processing.

All data and files are processed, replicated and backed up in Microsoft Azure’s secure data centres which are located within the following locations:
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Americas – Toronto (Primary) / Quebec City (Backup)
Asia-Pacific – New South Wales (Primary) / Victoria (Backup)
Europe, Middle East & Africa – Ireland (Primary) / Netherlands (Backup)
United States – Washington (Primary) / Wyoming (Backup)

All data and files are held and stored in compliance with local data protection directives, laws and regulations within these regions.

To facilitate our global operations, we allow access to information processed in any region by Inflo employees located in the United Kingdom for the purposes described in this policy. We have taken appropriate safeguards to require that your Personal data will remain protected in these circumstances.

If we or our sub-processor should have the need to process personal data outside your region, such processing must be in accordance with relevant regulations e.g. EU-US Privacy Shield Framework. Inflo will make use of the EU’s Standard Contractual Clauses for transfer to third countries, or another specifically stated lawful basis for the transfer of personal data to a third country. We will always ask for your prior written consent if there is a need to transfer data outside your region.

We store personal data for as long as necessary to fulfil the purpose for which the personal data was collected, while considering the need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes. For these reasons we store data for a period of seven years from the point in time at which an instance of an Inflo software module (“Inflo room”) is archived. When the personal data that we have collected is no longer required, we will delete it in a secure manner.

Data subjects have the following rights with respect to personal information:

• The right to request a copy of the personal information that Inflo hold about you,
• The right to request that Inflo correct your personal information if it is inaccurate or out of date,
• The right to request that your personal information is deleted when it is no longer necessary for us to retain such data,
• The right to withdraw any consent to personal information processing at any time. For example, your consent to receive e-marketing communications,
• The right to request that Inflo provide you with your personal information in a portable and commonly used format for transfer to another party,
• The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal information, and
• The right to object to the processing of personal information, in the case that processing has been based on legitimate interest and/or direct marketing.

If you wish to make a request to exercise any of these rights, this can be submitted to sayhi@Inflosoftware.com and Inflo will respond within 5 days of receipt.

We do not share, sell, rent, or trade your information with any third parties without your consent, except in the following cases.

To confirm eligibility to access services and benefits:
Where additional services and benefits are offered to members of professional bodies, affiliations or other organizations as part of member partnership schemes, we will share your membership information with these organizations to confirm eligibility. We may also use this information to provide management information to these organizations on the performance of membership schemes.

‍If required by law: we will disclose your personal data if required by law and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.
‍To protect our rights: we will disclose your personal data if we reasonably believe that disclosure is necessary to protect our rights and/or that of our affiliates, you or others. This includes the health and safety of employees and visitors, physical and online operations, property, intellectual rights, and privacy.
‍In using sub-contractors: Inflo uses Microsoft Azure – a recognized, industry-leading hosting provider – to process accounting data and files within hosted systems and databases on our behalf as a sub-processor. We are responsible for making sure they commit themselves to adhere to our data privacy policy and applicable data protection legislation. Inflo retains full control of this data.

We also use third-party service providers (processors) to store and process the data for which Inflo acts as a controller, and may need to share your information with them to provide information, products or services to you. Examples include performing statistical analysis on your use of the our services or interactions on our website, providing marketing assistance, and processing credit card payments. These service providers are prohibited from using your personal data except for these purposes, and they are required to maintain the confidentiality of your information.

Inflo reserves the right to amend this Privacy Statement at any time. The applicable version will always be found on our website. We encourage you to check this Privacy Statement occasionally to ensure that you are happy with any changes.

Inflo is registered with the Information Commissioner’s Office (ICO) in the UK: www.ico.org.uk