Privacy Policy

Privacy Policy

Emutare Technologies Pty Ltd (ACN 664 135 479, ABN 11 664 135 479), trading under the business names Emutare and Asayoma (collectively referred to as “Emutare,” “we,” “us,” or “our”), is committed to protecting the privacy of personal information we collect, hold, use, and disclose.

This policy outlines how we manage your personal information, in compliance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).

1. About Emutare

Emutare Technologies Pty Ltd is a technological transformation company, founded on 28 November 2022, focused on applying technology to transform business processes with efficiency and effectiveness, and to improve the standard of living. This includes providing specialised Solution such as Cyber RoleDefense, our continuous threat defense and cyber readiness assessment platform.

  • Registered Office: 37 Barrack Street, Perth, Western Australia, 6000.
  • Contact Email: info@emutare.com

2. Collection of Personal Information

We collect personal information that is reasonably necessary for us to carry out our functions and activities. The types of information we collect depend on your interaction with us:

A. Information Collected from Website Visitors (emutare.com)

When you visit our website, contact us, or join a waiting list (such as for Cyber RoleDefense), we may collect:

  • Contact Information: Name, email address, phone number, and company name.
  • Correspondence: Records of any communications with us.
  • Technical Data: IP address, browser type, operating system, and data collected via cookies and analytics tools (e.g., Google Analytics) regarding your activity on our site.

B. Information Collected from Clients and Prospective Clients

For the purposes of establishing and managing a business relationship, we may collect:

  • Business Contact Details: Names, titles, phone numbers, and email addresses of company representatives.
  • Financial/Billing Information: Necessary details for processing payments for our services.

C. Information Collected via our Technological Platforms (e.g., Cyber RoleDefense)

In our capacity as a service provider (or “data processor”) to our corporate clients, our technological platforms may collect information about the employees or users of our clients. This data is collected and used on behalf of our clients to assess cyber readiness and threat response capability. This may include:

  • User Identification Data: Usernames, employee IDs, and roles/departments within the client’s organisation.
  • Behavioural and Procedural Data: Data related to user interaction with our simulation and assessment platform, and performance metrics relevant to cyber readiness.

Note on Platform Data (Section 2C): When we collect and process information through our platforms, we do so under the instructions and privacy policy of our corporate client. If you are an employee using one of our platforms (like Cyber RoleDefense), you should refer to your employer’s privacy policy for details on how your information is being collected, used, and managed.

3. How We Collect Personal Information

We collect personal information in several ways, including:

  • Directly from you, when you fill out a form on our website, send us an email, or communicate with us by phone.
  • From our clients, when they engage us to provide a service (such as setting up user accounts for the Cyber RoleDefense platform).
  • From third parties, such as our business partners, analytics providers, or publicly available sources.

4. Purpose of Collection and Use

We collect, hold, use, and disclose personal information for the following purposes:

  1. To Provide Services: To deliver, administer, and improve our technological transformation services and platforms, including Cyber RoleDefense.
  2. To Communicate: To respond to your enquiries, provide technical support, and send service-related information.
  3. Marketing and Promotion: To send you news, updates, or promotional materials about our products and services (you may opt-out at any time).
  4. Business Operations: To manage our business, comply with legal obligations (e.g., financial record-keeping), and conduct internal analysis to improve our offerings.

5. Disclosure of Personal Information

We may disclose your personal information to:

  • Our corporate clients, as necessary for providing the services they have contracted us for (this primarily applies to the operational data collected via our platforms, as described in Section 2C).
  • Third-party service providers that assist us with business functions, such as IT support, web hosting, data storage, payment processing, or professional services (e.g., legal or accounting advice).
  • Government bodies or regulatory authorities, where required or authorised by law.

We take reasonable steps to ensure that third-party service providers are obligated to protect personal information and are only authorised to use it for the specific purposes for which we provide it.

6. Storage and Security

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification, or disclosure. This includes:

  • Employing appropriate technical measures (e.g., encryption, firewalls, secure password protection).
  • Implementing internal physical and procedural security measures.
  • Restricting access to personal information only to personnel who require it for their duties.

When personal information is no longer required, we take reasonable steps to destroy or permanently de-identify the information.

7. Access and Correction

You have a right under the Privacy Act 1988 (Cth) to request access to the personal information we hold about you and to request that we correct that information.

To make an access or correction request, please contact our Privacy Officer using the contact details provided below. We will respond to your request within a reasonable time and may charge a reasonable fee for providing access to your information (but not for making the request).

8. Overseas Disclosure

Emutare Technologies Pty Ltd is registered in Australia. While we generally store data in Australia, some of our third-party service providers (e.g., cloud hosting) may be located outside of Australia.

Where we disclose personal information to overseas recipients, we take reasonable steps to ensure that the overseas recipient handles your personal information in a manner consistent with the Australian Privacy Principles.

9. Complaints

If you believe we have breached the Australian Privacy Principles or have a concern about how we have handled your personal information, please address your complaint in writing to our Privacy Officer.

We will acknowledge your complaint and respond to you within a reasonable period. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC).

10. Contacting Emutare

For questions about this Privacy Policy, accessing or correcting your information, or making a complaint, please contact:

The Privacy Officer Emutare Technologies Pty Ltd 37 Barrack Street Perth, Western Australia, 6000 Australia

Email: info@emutare.com

11. Policy Updates

This Privacy Policy may be updated from time to time. We will post any changes on our website so that you are always aware of how we manage your personal information.

This Privacy Policy was last updated: 19th of November 2025