Privacy

This page applies to the current public site, merch store, support contact, temporary compliance pages and related technical operations operated by Jeremy Aaron Lugg under ABN 35 780 648 234.

OAIC guidance says many small businesses with annual turnover of $3 million or less are not covered by the Privacy Act 1988 unless an exception applies. This page is published for transparency regardless, and because privacy expectations can change if business activities change.

If the site later becomes a reporting entity under AML/CTF law, trades in personal information, starts storing read-only account credentials, or otherwise falls within a Privacy Act exception, privacy obligations may expand.

• Names, email addresses, shipping details and other contact information you provide.
• Order records, payment status, invoice references and fulfilment notes.
• Support details, contact records and any optional information you submit through current public forms.
• Authentication, session, browser, device, IP and security-log data created through normal site operation.
• Support messages, feedback and other correspondence you send to the operator.

OAIC guidance says personal information collection should be limited to what is reasonably necessary for the activity being carried out.

The current JALSOL Flowboard is a static watch-only preview. It does not currently collect public wallet addresses from visitors, connect to exchanges, store API credentials, import live account data, or calculate visitor-specific portfolio values.

If Flowboard later adds read-only watchlists, account imports, encrypted read-only API credentials, AUD valuation, transaction history or CSV export features, this privacy page should be updated before those features go live.

• Do not submit seed phrases, private keys or withdrawal-enabled API keys through JALSOL.
• Do not submit unnecessary sensitive information through support channels.
• Future read-only features should collect only the data reasonably needed for the selected view or export.

• To create and manage sign-in, access and support records.
• To process payments, match orders, arrange shipping and manage fulfilment.
• To respond to support requests, maintain compliance records and manage temporary public site settings.
• To maintain records, reduce fraud risk, investigate misuse and keep the site operating securely.
• To respond to customer questions, complaints and service requests.

This page does not say that personal information is sold. If that activity ever changed, this policy would need to change too.

Order updates, support replies, fulfilment notices and transactional contact may be sent where reasonably necessary to complete an order or respond to a request.

If marketing emails or similar promotional messages are later sent, ACMA guidance says consent, sender identification and a working unsubscribe pathway should be maintained.

• Transactional messages about orders, support, refunds or fulfilment are treated differently from optional marketing content.
• If you opt out of marketing, operational messages needed to complete an order or handle a complaint may still be sent.

Personal information may be handled by providers used to run the site, such as Stripe for checkout, Supabase for authentication or data storage, hosting or analytics providers, shipping providers and email providers.

Some providers may process or store data outside Australia, depending on their own infrastructure and configuration. External providers have their own privacy terms and operational practices.

Where a third-party platform processes your payment, delivery details or login, some information will also be handled under that provider's own policy.

Reasonable steps are taken to limit access to information and to retain records only as reasonably necessary for orders, support, security and legal record-keeping.

Some technical logs and records may be retained by third-party providers under their own operational settings and legal requirements.

• Security measures reduce risk but cannot guarantee absolute security.
• You should avoid submitting unnecessary sensitive information through general contact forms or support channels.

You can request access to, or correction of, personal information held by Jeremy Aaron Lugg through this site by contacting 358jal@gmail.com. Identity verification may be required before information is released or amended.

If the Privacy Act applies to the relevant activity and an issue cannot be resolved directly, OAIC complaint pathways may be available.

• Include your name, contact details and enough detail to identify the information you want to access or correct.
• Requests should describe the record or activity concerned, such as an order, support interaction or account email.
• Access requests are generally free, though OAIC guidance says a reasonable charge can apply in some cases for providing access.

This policy is intended to be practical and transparent, but it should not be read as a claim that every site activity is automatically covered by the Privacy Act in every circumstance.