Privacy Policy - Ternary

 

1. Who we are

Ternary is a strategy game for iPhone, built and operated by Eagles Flight Solutions (ABN 61 200 390 691) (“Eagles Flight Solutions”, “we”, “us”, “our”). This policy explains how personal information is handled in connection with the Pluvia application, this website and our support channels.

2. The law we follow

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) in Schedule 1 to that Act. Where you connect financial accounts to Pluvia, data received through Australia's Consumer Data Right (CDR) is handled under Part IVD of the Competition and Consumer Act 2010 (Cth) and the Competition and Consumer (Consumer Data Right) Rules 2020, which impose additional protections on top of the Privacy Act.

3. The short version

Pluvia is designed so that your financial information never reaches us. It is stored on your device or, if you turn on sync, in a private database in your own cloud account — a database we cannot read. The only personal information Eagles Flight Solutions itself holds is what you send to our support channel and, if you opt in, aggregated diagnostics. The Data collection policy sets out exactly what lives where.

4. Information stored on your device and in your private cloud

The following information is created or received by the application and stored under your control — on your device by default and, at your election in settings, in a private database in your personal cloud account (for example, iCloud):

• Financial account data — account names, balances and transaction records shared with your consent through the CDR (read-only);
• Content you create — budgets, categories, goals and notes; and
• Derived insights — forecasts and patterns, computed on your device.

Eagles Flight Solutions has no technical ability to access, read or recover this information. Because we do not collect or hold it, it is not “held” by us for the purposes of the Privacy Act 1988 (Cth); it remains in your custody, protected by your device passcode and your cloud account credentials.

5. Information we hold

The personal information Eagles Flight Solutions itself collects and holds is limited to:

• Support communications — your name, contact details and message content when you contact our support channel;
• Opt-in diagnostics — aggregated crash and performance reports, shared only if you enable sharing in your device settings, and containing no financial records; and
• Website analytics — with your consent, aggregate visit counts on this website (see the Data collection policy, section 9).

We do not collect sensitive information (such as health or biometric information) and ask that you do not include it in support messages.

6. Why we use it

Consistent with APP 6, we use the limited information we hold to respond to your support requests, to keep the application reliable and secure, to improve it, and to meet our legal obligations. We do not sell personal information, and we never use financial data for advertising — we could not, because we do not have it.

7. Who we share it with

We disclose the information we hold only to:

• service providers who support our operations under contract (for example, an email helpdesk provider), bound to use it solely to provide services to us;
• professional advisers and regulators where required or authorised by law; and
• a purchaser of our business, if the business is sold, on terms preserving this policy's protections.

If any provider processes personal information overseas, we take reasonable steps under APP 8 to ensure it is handled consistently with the APPs, and we will name the relevant countries in this policy. Your financial data cannot be disclosed by us in any circumstances, because we do not hold it.

8. Consumer Data Right data

Financial data shared through the CDR is collected only with your express, informed consent; is delivered to and processed on your device; and is used only for the purposes you have consented to. Your consent dashboard in the application shows every active consent and lets you withdraw any of them at any time. On expiry or withdrawal, the associated data is deleted from your device and private cloud in accordance with the CDR Rules, unless retention is required by law.

9. How it is protected

Under APP 11 we take reasonable steps to protect the information we hold, and the application is engineered to protect the information you hold:

• on-device data is stored in an encrypted database protected by your device's hardware security and passcode;
• private-cloud data is encrypted in transit and at rest within your personal cloud account, which we cannot access;
• all network connections use TLS 1.2 or higher; and
• our own limited systems use multi-factor authentication, least-privilege access and logging, and information no longer needed is destroyed or de-identified.

10. Data breaches

We maintain a data breach response plan for the limited information we hold. If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act 1988 (Cth).

11. Access and correction

Your financial data is already in your hands: view it in the application and export it from settings at any time. For the information we hold — support records and opt-in diagnostics — you may request access under APP 12 and correction under APP 13 by contacting our privacy officer. We will respond within 30 days, at no charge; if we refuse a request we will tell you why in writing and how to complain about the refusal.

12. Marketing

We send marketing messages only with your consent, in accordance with the Spam Act 2003 (Cth). Every message includes a working unsubscribe facility, and opting out never affects your use of Pluvia.

13. Children

Pluvia is not directed to children and is available only to users aged 13 or over. We do not knowingly collect personal information from anyone under 13; if we learn we have done so, we will delete it.

14. Complaints

If you believe we have mishandled your personal information, please contact our privacy officer first. We will acknowledge your complaint within 7 days and aim to resolve it within 30 days. If you are not satisfied with our response, you may complain to the OAIC at oaic.gov.au or on 1300 363 992.

15. Changes and contact

We review this policy at least annually and whenever our practices change. Material changes will be notified in the application before they take effect, and every version is dated and archived.

Privacy Officer, Eagles Flight Solutions
Email: aofree@proton.me