Privacy Policy

Effective 1 December 2025 Last reviewed December 2025 Version 1.0 OramisAI Pty Ltd  ABN 54 693 539 936

This Privacy Policy explains how OramisAI Pty Ltd (ABN 54 693 539 936) collects, uses, and handles personal information in connection with our website and AI governance software. It is issued in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

1. Introduction and Overview

OramisAI Pty Ltd (ABN 54 693 539 936) trading as OramisAI ("OramisAI", "we", "us" or "our") is an Australian artificial intelligence software and governance technology company. We develop and license a customer-configurable AI governance platform and related software products (the "Software") that enables enterprise and government customers to deploy, manage and govern AI capabilities within their own controlled environments.

This Privacy Policy ("Policy") applies to personal information that OramisAI collects and handles in connection with: (a) the operation of our website at www.oramisai.com (the "Site"); (b) the provision of our Software, support services and professional services (collectively, the "Services"); and (c) our general business operations.

This Policy is issued in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs").

Important — Customer-Controlled Deployments: OramisAI primarily functions as a software provider and governance layer. In many deployment configurations, OramisAI does not routinely access, process, or retain the data uploaded, processed, or generated by customers within their own environments, except where operationally necessary to deliver contracted services or as expressly authorised by the customer. Customers and their end users are responsible for their own compliance with applicable privacy and data protection laws in connection with data they upload or process using the Software.

2. Scope and Application

This Policy applies to personal information OramisAI collects, holds, uses and discloses in the course of its own operations as a software vendor. It applies to:

  • visitors to the Site, whether or not they register an account;
  • registered users, administrators and subscribers of the Services;
  • business customers, partners, resellers, vendors and contractors;
  • job applicants and prospective employees; and
  • any other individual whose personal information OramisAI receives in its capacity as a software vendor.

This Policy does not govern or describe how OramisAI's customers process personal information of their own end users within the Software. Where OramisAI processes personal information on behalf of a customer under a data processing agreement ("DPA") or equivalent arrangement, the terms of that DPA prevail over this Policy to the extent of any inconsistency.

3. About the OramisAI Platform and Deployment Model

OramisAI operates as a software provider and AI governance layer. The Software is designed to be deployed in customer-controlled and customer-configurable environments. Depending on the deployment model selected by the customer, the Software may operate:

  • entirely within the customer's own cloud or on-premises infrastructure;
  • in a dedicated single-tenant environment logically and technically isolated from other customers;
  • using the customer's own AI model integrations, including Bring Your Own Key (BYOK) and Bring Your Own Model (BYOM) architectures;
  • under the customer's own data residency and regional hosting requirements; and
  • subject to the customer's own role-based access controls, audit logging settings and governance configurations.

In these deployment configurations, OramisAI acts as a software licensor and service provider. The customer retains ownership of and control over all data uploaded to, processed within, or generated by the Software in their environment. OramisAI does not routinely access customer environments, data repositories, or AI outputs. Any access is limited to what is operationally necessary to provide contracted technical support, where expressly permitted by the customer, or where required by law.

4. What Personal Information OramisAI Collects

"Personal information" has the meaning given to it in the Privacy Act: information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in material form or not.

4.1 Information You Provide Directly

We collect personal information that you provide to us when you:

  • create an account or register for the Services (e.g., name, email address, job title, organisation name);
  • contact us for sales, support or general enquiries;
  • subscribe to our newsletter or marketing communications;
  • participate in surveys, webinars or research activities;
  • apply for employment with OramisAI; or
  • enter into a contract or commercial arrangement with us.

4.2 Information Collected Automatically

When you visit our Site or use our Services we automatically collect certain technical information including IP address and approximate geolocation, browser type and operating system, pages viewed and navigation paths, referring URLs and exit pages, session identifiers and authentication logs, and platform usage metadata.

Platform usage metadata collected for service improvement and support purposes is aggregated and de-identified where possible. We do not use customer-uploaded data or customer AI outputs for the purpose of improving our Software without the express written consent of the relevant customer.

4.3 Information From Third Parties

We may receive personal information from third parties including integration partners, identity verification providers, payment processors, and publicly available sources where lawfully permitted.

4.4 Sensitive Information

OramisAI does not intentionally collect sensitive information through its own Site or business operations. If you voluntarily provide sensitive information in the course of a support request or other direct communication, we will handle it in accordance with this Policy and the APPs.

5. Customer Data — Ownership, Control and OramisAI's Limited Role

5.1 Customer Ownership of Data

All data that a customer uploads to, processes within, or generates using the Software ("Customer Data") remains the exclusive property of that customer. OramisAI does not claim any ownership rights, licence or interest in Customer Data beyond the strictly limited operational access described in Section 5.2.

5.2 OramisAI's Limited Access to Customer Data

OramisAI does not, by default, access, view, use or process Customer Data. Limited access may occur only in the following circumstances:

  • at the explicit written request of the customer for the purpose of technical support or troubleshooting;
  • where required by law, regulation, court order or government authority; or
  • as expressly authorised in a signed DPA or equivalent contractual instrument.

5.3 No Use of Customer Data for AI Training

OramisAI does not use Customer Data — including customer prompts, AI outputs, uploaded documents, memory stores, or enterprise knowledge bases — to train, fine-tune, benchmark or improve OramisAI's own AI models or software products. This prohibition applies by default across all deployment configurations.

5.4 Customer Responsibility for Lawful Data Use

Customers are solely responsible for ensuring that any personal information or other data they upload to, process within, or instruct the Software to handle has been collected lawfully and may be processed in accordance with applicable law, including the Privacy Act 1988 (Cth) and the APPs.

5.5 Configurable Retention and Deletion

The Software provides configurable data retention settings. Customers may set their own retention periods for prompts, outputs, audit logs, memory stores and other data elements. Customers may initiate deletion of their data at any time through the platform's administrative controls or by submitting a written request to OramisAI.

5.6 Bring Your Own Key (BYOK) and Customer-Controlled Encryption

Where supported by the customer's deployment configuration, customers may supply and manage their own encryption keys (BYOK architecture). In such configurations, OramisAI does not by default hold or access the customer's encryption keys.

5.7 Audit Logging and Auditability

The Software includes configurable audit logging features covering user activity, access events, data processing actions and governance decisions within the customer's environment. Audit log retention periods and export options are configurable by the customer.

6. How OramisAI Uses Personal Information

OramisAI uses personal information collected through its own Site and business operations for the following purposes:

  • providing, operating, maintaining and supporting our Site and Services;
  • creating and managing customer accounts and user credentials;
  • processing billing, payments and commercial transactions;
  • communicating with you about your account, support requests and service updates;
  • with your consent, sending marketing and product communications (which you may withdraw at any time);
  • conducting internal business analytics to measure and improve our software products and services;
  • complying with our legal, regulatory and contractual obligations;
  • detecting, investigating and preventing fraud, unauthorised access, and security incidents; and
  • protecting the rights, property and safety of OramisAI, its customers and the public.

OramisAI does not use personal information to build individual behavioural profiles for third-party advertising, nor does it sell personal information to third parties.

7. Disclosure of Personal Information

7.1 Service Providers and Sub-Processors

We engage carefully selected third-party service providers to support our business operations. These may include cloud infrastructure providers, payment processors, customer relationship management platforms, support and helpdesk tools, identity and access management providers, and business analytics services. All such providers are bound by contractual obligations to process personal information only on our documented instructions.

7.2 Professional and Legal Advisers

We may disclose personal information to our lawyers, accountants, auditors, insurers and other professional advisers where necessary for the conduct of our business, subject to confidentiality obligations.

7.3 Corporate Transactions

In the event of a merger, acquisition, restructure, capital raising, asset sale or insolvency event, personal information may be disclosed to counterparties, investors and their advisers on a confidential basis.

7.4 Legal and Regulatory Disclosure

We may disclose personal information where required or authorised by law, including to law enforcement, courts, regulatory bodies and government authorities in response to lawful requests or court orders.

7.5 With Your Consent

We may disclose personal information to any other third party where you have given explicit consent to that disclosure.

8. Overseas Handling of Personal Information

Some of the third-party service providers that support OramisAI's own business operations are located overseas, including in the United States and other jurisdictions. As a result, personal information that OramisAI collects through its Site and business operations may be transferred to and processed in countries outside Australia.

Before disclosing personal information to overseas recipients, OramisAI takes reasonable steps to ensure that personal information is handled consistently with the APPs, including through contractual protections and data transfer mechanisms appropriate to the circumstances.

8.1 Customer Data Residency

For customers with data residency requirements, the Software supports deployment in customer-selected regions and cloud environments. Customers may configure the Software to ensure that Customer Data does not leave a specified geographic region. OramisAI does not, by default, transfer or replicate Customer Data across geographic regions except as instructed by the customer, as operationally necessary under a contracted service, or as required by law.

9. Security of Personal Information

OramisAI implements and maintains reasonable technical, organisational and administrative security measures designed to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. Our measures include:

  • encryption of data in transit and at rest;
  • access controls, least-privilege principles, multi-factor authentication and role-based permissions;
  • regular security assessments, vulnerability scanning and penetration testing;
  • incident response and business continuity procedures; and
  • vendor security assessments for material service providers.

In the event of a data breach affecting personal information held by OramisAI in its own systems that is likely to result in serious harm, we will comply with our obligations under the Notifiable Data Breaches (NDB) scheme in Part IIIC of the Privacy Act, including notifying the Office of the Australian Information Commissioner (OAIC) and affected individuals as required.

10. Cookies and Tracking Technologies

Our Site uses cookies and similar tracking technologies to support Site functionality, measure performance and improve user experience. You may configure your browser to refuse or manage cookies. Please refer to our Cookie Policy for further information and opt-out options.

11. Retention of Personal Information

Personal information collected by OramisAI through its own operations is retained for as long as necessary for the purposes for which it was collected, or as required by applicable law. When personal information is no longer required, we take reasonable steps to destroy or de-identify it securely. For Customer Data, retention and deletion are governed by the customer's own configurable settings and the applicable service agreement.

12. Your Privacy Rights

12.1 Access

You may request access to personal information OramisAI holds about you. We will respond within 30 days. We may decline access where required or authorised by law.

12.2 Correction

If you believe personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us to request a correction. We will respond within 30 days.

12.3 Marketing Opt-Out

You may withdraw consent to receive marketing communications at any time by using the unsubscribe mechanism in any marketing email, adjusting your account preferences, or contacting us.

12.4 Anonymity

Where lawful and practicable, we will offer the option to interact with us anonymously or by pseudonym.

12.5 Deletion

You may request deletion of your personal information where we are not required to retain it by law, contract, or for legitimate operational purposes.

12.6 End User Rights Within Customer Deployments

Where your personal information is held within a customer's deployment of the Software, you should direct access, correction or deletion requests to the relevant OramisAI customer. The customer is the data controller for that environment.

13. Enterprise and Government Deployments

OramisAI's platform is designed to meet the data governance, security and sovereignty requirements of enterprise and government customers. Key features available for enterprise deployments include single-tenant or on-premises deployment, configurable data residency, BYOK encryption, BYOM integration, RBAC, SSO, comprehensive audit logging, and no default use of Customer Data for AI model training. Data processing agreements (DPAs) are available on request.

14. Children's Privacy

Our Site and Services are not directed at individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently received personal information from a person under 18, we will take steps to delete it promptly.

15. Changes to This Privacy Policy

We reserve the right to amend this Policy at any time. The updated Policy will be published on our Site with a revised effective date. Where we make material changes, we will notify registered users by email or via a notice on the Site prior to the change taking effect.

16. Contact and Privacy Officer

Privacy Officer

OramisAI Pty Ltd

Email: privacy@oramisai.com

Website: www.oramisai.com

17. Complaints and Dispute Resolution

If you believe OramisAI has breached the APPs or your rights under this Policy, you may lodge a complaint with our Privacy Officer. Please mark your communication "Privacy Complaint - Confidential". We will acknowledge receipt within 5 business days and aim to provide a substantive response within 30 days.

If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.

18. Limitation of Liability

To the maximum extent permitted by Australian law, OramisAI shall not be liable for any indirect, incidental, special, consequential or punitive loss or damage arising out of or in connection with any collection, use, disclosure, or security incident involving personal information held within a customer-controlled deployment of the Software; any breach or data loss caused or contributed to by a customer, end user, or third party; or a customer's failure to configure the Software in accordance with applicable law. Nothing in this Policy is intended to exclude any rights under the Australian Consumer Law.

19. Governing Law and Jurisdiction

This Policy is governed by the laws of New South Wales, Australia, and applicable federal Australian laws. Any disputes shall be subject to the exclusive jurisdiction of the courts of New South Wales and the Federal Court of Australia.

Schedule 1 — Glossary

APP
Australian Privacy Principle as set out in Schedule 1 to the Privacy Act 1988 (Cth).
BYOK
Bring Your Own Key: a deployment architecture in which the customer generates, manages and controls the encryption keys used to encrypt their data within the Software.
BYOM
Bring Your Own Model: a deployment configuration in which the customer integrates and uses their own nominated AI models within the Software platform.
Customer Data
All data, including personal information, that a customer uploads to, processes within, or generates using the Software in their environment. Customer Data remains the property of the customer.
DPA
Data Processing Agreement: a contractual instrument governing the terms on which OramisAI processes Customer Data on behalf of a customer.
NDB Scheme
The Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth).
OAIC
The Office of the Australian Information Commissioner.
Personal Information
Information or an opinion about an identified individual, or an individual who is reasonably identifiable, as defined in section 6 of the Privacy Act.
Privacy Act
Privacy Act 1988 (Cth), as amended from time to time.
RBAC
Role-Based Access Control: a security model in which access to system features and data is determined by the roles assigned to individual users.
Services
The Software products, support services and professional services provided by OramisAI.
Site
The OramisAI website at www.oramisai.com and associated sub-domains.
Software
The OramisAI AI governance platform and related software products licensed or provided by OramisAI.