1. About this policy
Resonel is operated by Flink Labs Pty. Ltd. (ACN 135 445 911) (Flink Labs, we, us or our) of 425 Smith St, Fitzroy 3065, Victoria, Australia.
This policy explains how we collect, hold, use and disclose personal information when we operate Resonel, including its website, administration and results portals, APIs, support services and public survey technology.
It should be read with:
- the privacy or collection notice provided with a particular survey;
- the privacy policy of the organisation that commissioned that survey; and
- our Cookie Policy.
Resonel is currently offered in Australia and this policy is drafted around Australian privacy law.
2. Our different roles
When we handle information for our own operations
We are responsible for personal information used to manage Resonel accounts, authenticate users, provide support, communicate about the service, secure our systems, keep audit records, administer client relationships and comply with our legal obligations.
When we provide surveys for a client
Resonel is generally provided to an organisation that decides why a survey is conducted, who is invited, what questions are asked and how results will be used (Client).
For survey responses and related respondent information, we generally process information for the Client and under its instructions. The Client's collection notice and privacy policy should explain the purpose of the survey, whether participation is voluntary, how the Client will use the responses, who will receive results and how to contact the Client.
If you are a survey respondent, you should contact the Client first about the survey's purpose or its use of your response. You can also contact us about Resonel's handling of the information.
3. Personal information we handle
Depending on how Resonel is configured and used, we may handle:
Account and organisational information
- name, work email address and organisation;
- account role, permissions and assigned reporting levels;
- sign-in and invitation records;
- selected organisation, language and portal preferences;
- support communications and feedback; and
- billing or commercial contact information supplied by a Client.
Survey and response information
- answers to survey questions, including free-text comments;
- survey, wave, organisational level and cohort information associated with a response;
- dates and times of survey commencement and submission;
- response identifiers supplied by a Client or generated by Resonel; and
- other information a Client includes in a survey or supplies through an integration or import.
A Client may use Resonel for surveys that ask about health, disability, cultural background, employment experiences or other sensitive matters. The Client is responsible for ensuring that its questions, authority, consent process and notice are appropriate. We process that information to provide the service and as otherwise required by law.
Identifying fields and retained responses
The base portal used by current Clients is intended not to retain unnecessary identifying fields in completed survey-response data. Names, email addresses, exact ages and similar source fields should be removed before information is supplied to Resonel or immediately after ingestion. The information retained for analysis should be limited to the survey responses and fields needed for that purpose.
Removing obvious identifying fields does not necessarily make a response anonymous. Free-text comments, health information, demographic combinations, response identifiers or other details may still relate to a reasonably identifiable individual and may remain personal or sensitive information under Australian law.
When a public browser survey is completed, its raw IP address, browser metadata, device fingerprint and session token are not retained with the completed response. Keyed integrity digests derived from the IP address, device information and session token are retained separately for up to seven days for automated fraud prevention, then deleted.
Client API submissions may include metadata and external identifiers supplied by the Client. That information is governed by the Client's configuration, instructions and notices.
[OPERATIONAL REVIEW BEFORE PUBLICATION: Configure SURVEY_INTEGRITY_HMAC_KEY, deploy the public-survey minimisation release, run the production public-survey audit and remediation task, and confirm completion before treating this as the production position. The API interface is unchanged.]
Technical, usage and security information
- IP address and browser user-agent;
- screen dimensions, browser language and timezone;
- a derived device fingerprint used for security and response-integrity purposes;
- survey page and completion timings;
- session, authentication and API activity;
- audit records recording actions performed in the portal; and
- ordinary web request and diagnostic information, which may include request identifiers, URLs, timestamps and error details.
Derived and aggregated information
Resonel may calculate scores, summaries, comparisons, response counts, privacy-threshold status and other analytical outputs from survey responses. We may also create aggregate or de-identified operational information that no longer identifies a Client or individual.
4. How we collect information
We collect personal information:
- directly from administrators, portal users and survey respondents;
- from the Client that creates accounts, configures a survey, imports information or integrates another system with Resonel;
- automatically when a person accesses the website, portal, API or survey; and
- from service providers where needed to operate, secure or support Resonel.
Where practicable, a person may interact with a survey without providing their name or by using a pseudonym. Whether a response is legally anonymous depends on the Client's survey design, identifiers, free-text fields, demographic combinations and purpose. While a public browser survey is incomplete, Resonel receives limited technical information to deliver and secure it. The raw technical session record is removed on successful completion; separate keyed integrity digests are retained for no more than seven days. Client API submissions are handled separately and may include metadata and external identifiers supplied by the Client.
5. Why we handle personal information
We handle personal information to:
- provide, administer and support Resonel;
- authenticate users and apply permissions;
- deliver surveys and record responses;
- calculate and present results authorised by the Client;
- maintain security, detect misuse and protect survey integrity;
- troubleshoot incidents and improve reliability;
- communicate about accounts, support and material service changes;
- meet contractual obligations to Clients;
- comply with law and respond to lawful requests; and
- create aggregate or de-identified operational information to understand and improve the service.
We do not use identifiable survey responses for unrelated marketing or to train a general-purpose artificial intelligence model unless this is expressly authorised by the Client, clearly disclosed to affected individuals and permitted by law.
6. Artificial intelligence features
No external artificial intelligence provider is currently enabled for a production Client, and we do not currently send Client survey information to an external AI provider.
Resonel contains optional capabilities that could use an external provider to generate draft insights or classify free-text comments. Before enabling such a capability for a Client, we will assess the privacy and security implications, agree the use with the Client, update relevant notices and contractual terms, and identify the provider, information involved and processing locations.
7. Who receives information
We may disclose or make personal information available to:
- the Client and its authorised administrators, analysts and portal users;
- service providers that host data, deliver email, provide infrastructure or support the service;
- professional advisers, auditors and insurers where reasonably necessary and subject to appropriate confidentiality obligations;
- a purchaser or successor in connection with a proposed or completed corporate transaction, subject to lawful safeguards; and
- courts, regulators, law-enforcement bodies or other parties where required or authorised by law, or where reasonably necessary to protect legal rights, safety or service security.
We do not sell personal information or disclose it for cross-context behavioural advertising.
8. Service providers and overseas disclosures
Our verified production configuration uses Amazon Web Services for file storage and outbound email, with an Australian region configured. Resonel also loads some browser assets from Google, UNPKG and jsDelivr. No external artificial intelligence provider is currently enabled for production Clients.
Some providers or their support personnel may process information outside Australia. In particular, technical information associated with externally hosted browser assets may be disclosed to providers in the United States or routed through their global delivery networks. Where required, we take reasonable steps to use providers and contractual arrangements that protect the information consistently with applicable law.
The countries in which recipients are likely to be located are Australia and the United States.
10. Retention
We retain personal information only for as long as reasonably needed for the purpose for which it is held, the Client's documented instructions, applicable contractual requirements and legal obligations.
Our current and intended handling rules are:
| Information | Current approach |
|---|---|
| Incomplete survey-session records | Automatically pruned after seven days |
| Audit events | Automatically purged after twelve months |
| Raw public survey technical data | Raw IP addresses, browser metadata, device fingerprints and session tokens are removed when a public survey response is completed and are not retained with the completed response. |
| Keyed public survey integrity digests | Derived from the IP address, device information and session token, retained separately for up to seven days for automated fraud prevention, then automatically deleted. |
| Client API metadata and external identifiers | May be supplied by the Client and are retained and handled according to the Client's configuration, instructions and notices. |
| Survey answers and associated reporting fields | No fixed expiry. They remain while needed for the Client's survey purpose, until the Client removes them or instructs us to remove them, or until earlier deletion or de-identification is required by law. |
| Account and permission records | Retained while the account or Client relationship is active and afterwards only while reasonably needed for security, dispute resolution, legal compliance or another permitted purpose. |
| Support and security records | Retained only while reasonably needed for support, security, dispute resolution or legal compliance. |
| Backups | Retained until overwritten or expired after two weeks through the ordinary backup lifecycle, subject to legal holds and disaster-recovery requirements. |
The Client is responsible for reviewing whether completed survey responses remain necessary for the survey purpose and for removing them or instructing us to remove them when they are no longer needed. Independently of a Client instruction, we take reasonable steps to delete or de-identify personal information when it is no longer required for a permitted purpose or by law. Information in backups may remain until the relevant backup is securely overwritten or expires.
11. Security
We use administrative and technical safeguards designed to protect personal information against unauthorised access, disclosure, alteration, loss and misuse. These include encrypted network connections, access controls, tenant and role permissions, secure session settings, logging and monitoring, and security review and maintenance practices.
No internet service can guarantee absolute security. Clients and users must also protect their accounts, access credentials, exports and downloaded reports.
12. Access, correction and other requests
You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.
For information in a Client's survey, contact the Client where possible. We will assist the Client with a request as required by law and our agreement with it. You may also contact us directly, particularly if you cannot identify or reach the Client.
You may also ask for information to be deleted or de-identified where it is no longer needed, although applicable law may permit or require continued retention in some circumstances.
Requests can be made without using a special form. Contact support@flinklabs.com or use the postal details below. We may need to verify your identity and clarify the information concerned before completing a request. We will respond within the period required by applicable law and will explain any lawful refusal.
13. Privacy complaints
If you believe personal information has been mishandled, contact our Privacy Contact using the details below. Please describe what happened and the outcome you are seeking.
We will:
- acknowledge the complaint promptly;
- investigate it fairly and with appropriate independence;
- seek further information where reasonably necessary; and
- aim to provide a written outcome within 30 days, or explain why more time is needed.
If you are not satisfied, you may contact the Office of the Australian Information Commissioner at oaic.gov.au or another regulator or dispute-resolution body available in your jurisdiction.
14. Children and young people
Resonel administration and results accounts are intended for authorised organisational users who have legal capacity and permission to use them.
A Client may use Resonel to conduct a survey that includes respondents under 18. In that situation, the Client is responsible for having an appropriate lawful basis, authority or consent; providing an age-appropriate collection notice; and configuring the survey consistently with applicable law. We process the information to provide the service to that Client.
If you believe information about a child or young person has been collected without appropriate authority, contact the Client or our Privacy Contact.
15. Changes to this policy
We may update this policy when our services, providers or legal obligations change. We will publish the revised policy with a new effective date and provide additional notice of material changes where appropriate.
16. Contact us
Privacy Contact:
- Flink Labs Pty. Ltd. (ACN 135 445 911)
- Email: support@flinklabs.com
- Address: 425 Smith St, Fitzroy 3065, Victoria, Australia