Who are we?
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.
Why do we collect and use personal data?
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 anonymised, 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.
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 firstname.lastname@example.org
- 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 controller 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.
How do we protect your data?
Inflo has in place strong technical and organisational measures to protect against unauthorised, 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 unauthorised or unlawful processing.
Where do we store your data?
All data and files are processed, replicated and backed up in Microsoft Azure’s secure data centres which are located within the following locations:
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.
How long do we keep your personal data?
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.
What rights do you have?
You have the following rights with respect to your personal data:
- the right to request a copy of your personal data that Inflo holds about you
- the right to request that Inflo corrects your personal data if inaccurate or out of date
- the right to request that your personal data is deleted when it is no longer necessary for Inflo to retain such data
- the right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications
- the right to request that Inflo provides you with your personal data 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 data
- the right to object to the processing of personal data, in case data processing has been based on legitimate interest and/or direct marketing.
If you wish to make such a request, this can be submitted to email@example.com and we will respond within 5 days of receipt.
Do we share your data with anyone?
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 organisations as part of member partnership schemes, we will share your membership information with these organisations to confirm eligibility. We may also use this information to provide management information to these organisations 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:
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.
Changes to this Privacy Statement
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.
Who can you complain to?
Inflo is registered with the Information Commissioner’s Office (ICO) in the UK: www.ico.org.uk
As of 1st January 2021, Inflo now complies with the new UK-GDPR regulation which is enacted into the Data Protection Act (2018). The rules of the UK-GDPR are based on and follow the same laws as EU-GDPR.
Following the end of the Brexit Transition period on 31 December 2020, the EU has granted a 6-month grace period whereby transfer of personal data from the EU to the UK is unrestricted.
During this grace period it is expected that the EU will grant the UK’s data protection regime an adequacy decision. This will allow unrestricted transfer of personal data between the UK and the EU as per pre-Brexit arrangements.
If an adequacy decision is not granted by the EU, data processors will be required to implement necessary safeguards, such as the Standard Contractual Clauses currently awaiting approval by the European Commission.
We are monitoring the situation closely and will make the required changes when things become clearer to ensure Inflo remains compliant with data protection legislation.