Privacy Policy

1. Introduction

Flow MKTG respects your privacy and is committed to protecting the personal information collected through our websites, promotional campaigns, technology platforms and associated services.

This Privacy Policy explains how we collect, use, store and disclose personal information when individuals interact with Flow MKTG or participate in promotional activities delivered using our technology.

Our operations include Flow Marketing Pty Ltd (Australia) and Flow Marketing LLC (United States), collectively referred to in this policy as Flow MKTG, we, us or our.

Our technology and services include TURNSTYLE, PUK™ and PURE RANDOM™, which support promotional campaign management, purchase-linked participation, mobile verification, prize allocation and winner communications.

2. Information We Collect

Depending on the service or promotion, we may collect:

  • Full name
  • Mobile telephone number
  • Email address
  • Postal code or postcode
  • Promotional entry and participation information
  • Purchase or transaction details relevant to promotional eligibility
  • Verification and authentication information
  • Prize allocation, notification and redemption records
  • Technical information, including IP address, device information and interaction timestamps

We collect information directly from individuals, through participating retailers and promotional partners, or through our technology platforms.

The information collected depends on the requirements of the particular promotion or service.

3. How We Use Personal Information

We may use personal information to:

  • Administer promotional campaigns and competitions.
  • Verify participant identity and eligibility.
  • Send one-time passwords (OTPs) and authentication codes.
  • Confirm promotional entries and participation.
  • Notify participants of promotional outcomes.
  • Communicate prize-winning information and redemption instructions.
  • Provide secure links to prize information and redemption pages.
  • Prevent fraudulent, duplicate or unauthorised participation.
  • Maintain records required for promotional compliance, reporting and auditing.
  • Operate, maintain and improve our technology platforms.

Personal information collected for a promotion is used in accordance with the applicable promotional terms and conditions and relevant privacy laws.

4. SMS Communications and Mobile Numbers

Flow MKTG operates promotional technology that uses SMS messaging to support participant verification and transactional communications.

Individuals may receive SMS messages relating to:

  • One-time verification codes requested during registration or participation.
  • Confirmation of promotional participation.
  • Prize-winning notifications.
  • Prize redemption instructions and secure redemption links.
  • Other service-related communications directly associated with a promotion in which they participate.

SMS messages are sent in connection with an individual’s participation in a promotion or use of a service.

Where required, individuals provide consent to receive SMS communications when submitting their mobile number.

Message frequency varies depending on participation and the relevant promotion. Standard message and data rates may apply.

Individuals may reply STOP to supported SMS numbers to opt out of further messages. For assistance, they may reply HELP where supported or contact us using the details below.

Opting out of SMS communications may affect our ability to deliver verification codes or other information necessary to participate in a promotion.

Mobile Information and Marketing

We do not sell mobile telephone numbers or SMS consent information to third parties.

Mobile information and SMS opt-in consent data are not shared with third parties or affiliates for their own marketing or promotional purposes.

We may disclose mobile information to contracted messaging and technology service providers solely to deliver the services requested by participants.

5. Promotional Partners and Service Providers

Flow MKTG provides promotional technology and administration services to brands, retailers and other commercial organisations.

Depending on the promotion, Flow MKTG may process personal information on behalf of the organisation conducting the promotion.

We may share information with authorised service providers where reasonably necessary for:

  • SMS delivery and authentication
  • Secure hosting and data processing
  • Promotional administration
  • Prize fulfilment and redemption
  • Fraud prevention and compliance
  • Technical support

These providers are permitted to process information only for authorised purposes and subject to applicable contractual and legal obligations.

6. Data Security

We take reasonable technical and organisational measures to protect personal information against unauthorised access, misuse, loss, alteration and disclosure.

These measures may include access controls, authentication processes, secure communications, monitoring and appropriate data-handling procedures.

No internet-based system can guarantee absolute security.

7. Data Retention

We retain personal information for as long as reasonably necessary to administer the relevant promotion, fulfil prizes, resolve enquiries, maintain appropriate audit records and comply with applicable legal obligations.

Retention periods may vary depending on the promotion, contractual requirements and applicable laws.

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

8. International Data Processing

Flow MKTG operates in Australia and the United States and may use technology service providers operating in other jurisdictions.

Personal information may therefore be processed or stored outside the country in which it was collected.

Where applicable, we take reasonable steps to ensure appropriate safeguards are in place when personal information is transferred internationally.

9. Access, Correction and Privacy Requests

Individuals may contact us to request access to personal information we hold about them, seek correction of inaccurate information, or request deletion where permitted by applicable law.

We will respond to privacy requests in accordance with applicable legal requirements.

Individuals participating in a promotion may also contact the promoter identified in that promotion’s terms and conditions.

10. Cookies and Website Information

Our websites and promotional platforms may use cookies or similar technologies necessary for website functionality, security, performance monitoring and fraud prevention.

Additional information about cookies or analytics may be provided where required.

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in our operations, technology, services or legal obligations.

The current version will be published on our website with its effective date.

12. Contact

For privacy enquiries or requests relating to personal information, please contact:

Flow MKTG

Flow Marketing Pty Ltd — Australia
Flow Marketing LLC — United States

Sunshine Coast, Queensland, Australia
Las Vegas, Nevada, United States

Website: flowmarketing.co
Email: accounts@flowmarketing.com.au