Global Privacy Policy

Asayoma is a business division of Emutare Technologies Pty Ltd (ACN 664 135 479, ABN 11 664 135 479), founded on 28 November 2022.

We are committed to protecting the privacy of personal information we collect and process globally. As a provider of expert project management, strategic vendor management, workforce augmentation, and actionable business consultation, we handle sensitive information that requires the highest standard of care and compliance.

1. Scope and Legal Compliance

This Global Privacy Policy applies to the personal information collected, held, used, and disclosed by Asayoma.

Australian Compliance: We are primarily regulated by and comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).
Global Compliance: We have adopted this robust framework to uphold the spirit of international privacy laws, including (but not limited to) the principles of the General Data Protection Regulation (GDPR) for data subjects in the European Economic Area (EEA), and the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) for residents of California.

Registered Office (Data Controller/Business): 37 Barrack Street, Perth, Western Australia, 6000, Australia.

2. Personal Information We Collect

We collect information necessary to provide our specialised consulting, management, and augmentation services. This information falls into three categories:

Category	Type of Information Collected	Source / Context of Collection
A. Contact & Business Data	Name, job title, company name, address, email, and phone number.	Collected directly from clients, partners, or through business development processes.
B. Professional & Employment Data	Curriculum vitae (CVs), Resume, professional qualifications, work history, skills, references, and professional background.	Collected from contractors, candidates, or employees for Workforce Augmentation and placement with clients.
C. Technical & Usage Data	IP address, browser type, operating system, and data collected via cookies/analytics on our website (Asayoma.com).	Collected automatically when you interact with our website or digital communications.

3. Legal Basis and Purpose of Processing

Under the GDPR, we must have a lawful basis for processing personal data. The legal bases and corresponding purposes for which we use the collected information are:

Legal Basis (GDPR)	Primary Purpose for Processing
Performance of a Contract	To deliver Project Management and Consultation services; to fulfill Workforce Augmentation placement and contracting agreements.
Legitimate Interests	To manage, secure, and improve our services; to communicate with business contacts; to conduct internal reporting and data analysis.
Legal Obligation	To comply with Australian, US, and other international legal requirements, including tax, employment, and anti-money laundering laws.
Consent	To send direct marketing communications (where required by law); to place non-essential cookies on our website.

4. Disclosure of Personal Information

To deliver our global services, we may disclose personal information to the following parties:

Clients and Engaged Companies: For Workforce Augmentation, we share candidate/contractor professional data (Category B) with our clients globally to facilitate placement and contract engagement.
Sub-Processors & Service Providers: Third-party providers who assist us with IT, cloud hosting, data analytics, professional advice, and payment processing.
Legal & Regulatory Authorities: Where required by law or a valid legal process (e.g., courts, government bodies, or financial regulators).

5. International Data Transfer

As a global consultancy and augmentation firm working with clients in the USA, Europe, and worldwide, we transfer personal information across international borders.

Transfer Mechanism: When transferring personal data outside of Australia (or outside the EEA, UK, or California), we take reasonable steps to ensure the overseas recipient is bound by adequate privacy and security obligations. For transfers originating from the EEA, we implement appropriate safeguards, which may include the use of Standard Contractual Clauses (SCCs) approved by the European Commission.
Data Location: While our primary records may be stored in Australia, our data processing activities, including use of cloud services, may result in data being stored or accessed in other countries, including the United States.
Accountability: Under the APPs (Principle 8.1), if we disclose personal information to an overseas recipient, we remain accountable for any act or omission by that recipient that breaches the APPs.

6. Your Global Privacy Rights

We are committed to honoring the fundamental rights of individuals worldwide regarding their personal data. Depending on your location and relationship with us, you may have the following rights:

A. Rights under APPs (Australia)

Access and Correction: You have the right to request access to and correction of the personal information we hold about you.

B. Rights under GDPR (EEA/UK Data Subjects)

In addition to the Australian rights, you have:

Right of Erasure (“Right to be Forgotten”): You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, subject to legal exceptions.
Right to Restriction of Processing: You have the right to restrict the processing of your data in certain circumstances.
Right to Object: You have the right to object to the processing of your data based on legitimate interests or for direct marketing purposes.
Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.

C. Rights under CCPA/CPRA (California Residents)

In addition to the Australian rights, you have:

Right to Know: The right to request information about the categories and specific pieces of personal information we have collected.
Right to Opt-Out of Sale or Sharing: The right to direct us not to “sell” or “share” your personal information (as defined by the CCPA/CPRA) for cross-context behavioral advertising. Asayoma does not sell personal information for monetary value.

7. Contact Us and Complaints

If you have questions about this policy, wish to exercise any of your global privacy rights, or have a complaint about how we have handled your personal information, please contact our Privacy Officer:

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

Email: [Insert Dedicated or General Company Contact Email: info@asayoma.com

Making a Complaint

We will acknowledge your complaint within a reasonable time and seek to resolve it through our internal process.

Australian Residents: If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).
International Residents: You may have the right to lodge a complaint with your local Data Protection Authority.

8. Policy Updates

This policy will be reviewed and updated periodically to reflect changes in our services, technology, and legal requirements. The updated version will always be posted on our website and will be effective immediately upon posting.

Last updated: 19th November 2025