Draft, pending legal review

Data processing agreement

This draft is between the business that opens an EmuFlow account (the business) and EMUFLOW PTY LTD (ACN 703 803 883), which operates EmuFlow (the processor). Registered office: c/- Findex Tenterfield, 253 Rouse St, Tenterfield NSW 2372. It is not legal advice. A lawyer still needs to review it before a business relies on it. EmuFlow is the product name.

What the processor does

EmuFlow stores and shows the records the business puts in the app so the shop can run: people, rosters, clock times, orders, recipes, chat, wholesale contacts, and safety records. It also keeps draft invoice and payroll files, leftover photos, promo signs, cleaning photos, Help reports, and uniform orders. The business decides what is collected and who on the team can see it. EmuFlow does not sell those records. A uniform card number stays with Stripe. EmuFlow does not store it.

Where it is kept

The app runs on Fly in Sydney (syd). The database is Fly Postgres, managr-db, in Sydney on Fly.io. Some helpers sit outside Australia. They are listed on the sub-processors page, including Resend in Tokyo, Stripe in the United States, Printful, OpenAI, Google Places, and, when Google Places does not answer, Nominatim in the Netherlands and Ireland and Photon in Germany, plus push services, Xero, Square, and Lightspeed. The business turns those helpers on when it uses them. A uniform payment goes to Stripe, and the delivery details go to Printful after that payment succeeds.

Security and access

Tax file numbers, bank details, and super details are encrypted in the app. A tax file number is shown only to the owner, the person it belongs to, or someone the owner has allowed, and each view is logged. Sign-in for owners and people who can see pay or tax file numbers uses a second step in production.

How long records stay

Clock times, timesheets, and pay exports are kept for at least 7 years. They are not deleted when a person or the business is removed from the app. Location stamps and punch photos are cleared after 12 months unless the owner sets a shorter period. Error logs are cleared after 90 days.

If something goes wrong

If EmuFlow becomes aware of a breach of the business's records, it will tell the business without undue delay, say what is known, and help the business contain it. The business assesses the breach and, where the Privacy Act requires it, notifies the Office of the Australian Information Commissioner and the people affected within the time the law sets, including the 30-day assessment.

Access, correction, and the end

A person can download their own records and ask the owner for a correction. When the business stops usingEmuFlow, pay and clock records stay for the retention period. Other records can be returned or deleted on the owner's request, except where the law says they must be kept. Questions go to emuflow.team@gmail.com.