Privacy & Data Policy

Effective Date: 02 August 2025 

Last Updated: 02 August 2025 

Applies to: Emotivo Pty Ltd (ABN 55 686 187 128 | ACN 686 187 128) trading as Engaige Smart Solutions (Engaige Smart).

1. What We Collect 

We may collect the following types of data: 

• Name, email, phone number, and other contact details. 
• AI interaction logs (e.g. form responses, chat histories). 
• Customer IDs or anonymised data using unique codes. 
• Appointment and campaign data. 
• Business performance and platform usage insights. 

Data may be collected via: 

• Web forms, landing pages, chat interfaces. 
• CRM integrations. 
• Direct API connections or encrypted file uploads. 
• Calendar tools such as Calendly or Outlook. 
• Marketing automation platforms such as GoHighLevel and Twilio.
• Third parties such as referral partners, introducers, or authorised representatives. 
• Public sources, where applicable.

We do not collect sensitive personal information (e.g. health, ethnicity, biometrics, or political views) unless explicitly required and consented to. 

If you provide us with personal information about someone else (e.g. your customers), you must ensure you are authorised to do so and have informed them of our Privacy Policy and intended use. 

2. How We Use This Data 

We use data to: 

• Deliver AI-powered marketing, sales, and customer engagement services.
• Automate and optimise customer journeys on behalf of clients. 
• Personalise communications and track performance. 
• Integrate with CRMs and scheduling tools. 
• Provide reporting, insights, and improvement opportunities. 

Where we act as a data processor, clients are responsible for ensuring all data has been lawfully collected, with valid consent from end-users. 

3. Data Insights & Anonymised Use 

We may use de-identified or aggregated data: 

• For internal analysis and service improvements.
• To generate anonymised campaign performance or trend insights.

This data is never shared in personally identifiable form. 

4. Data Storage, Retention & Purging 

• Stored securely in encrypted environments.
• Encryption in transit and at rest where supported by the platform, with secure API gateways for data transfer.
• Retained only as long as necessary or required by law.
• Client data purged within 90 days of project completion or request.
• Anonymised logs may be retained for improvement purposes.
• All backup data follows the same retention protocols. 

5. Anti-Spam & Consent Compliance 

We comply with the Australian SPAM Act 2003 and international standards. Communications are only sent to opted-in individuals, with unsubscribe options included. 

6. Security & Risk Controls 

We partner with technology providers that are ISO 27001-certified wherever possible. Where non-certified tools are used, we apply equivalent controls, contractual safeguards, and regular reviews to ensure appropriate security standards.

Our measures include:

• Encryption in transit and at rest where supported.
• End-to-end encryption and secure API gateways. 
• Access restrictions and 2FA. 
• Role-based access and audit trails. 
• Regular security reviews. 

7. International Data Transfers 

We use trusted third-party tools with servers in the US, EU, and other regions. All providers are assessed for compliance with  Australian Privacy Principles (APPs), GDPR, and relevant data protection laws  where applicable. 

8. Breach Management 

Suspected or actual breaches trigger our internal incident response plan. Clients are notified immediately and we comply with the Notifiable Data Breach (NDB) scheme. 

9. Access, Correction & Complaints 

You may request access to, or correction of, your data by contacting us. We aim to resolve all concerns within 30 days. If unresolved, you may escalate complaints to the Office of the Australian Information Commissioner (OAIC). 

10. Job Applicants & Team Members 

Application data is handled with the same care as customer data. We do not collect or use employee records except as required by law. 

11. Partner & Subcontractor Disclosures 

We may share data with subcontractors or service providers who work with us, under strict confidentiality, privacy obligations, and formal Data Processing Agreements (DPAs) where applicable.

12. Multi-system Marketing Preferences 

When integrated platforms (e.g. Twilio, GoHighLevel) send communications on our behalf, you may need to manage preferences within those systems directly as well as with Engaige Smart. 

Contact:

Emotivo Pty Ltd trading as Engaige Smart Solutions 

ABN 55 686 187 128 | ACN 686 187 128 

Email: hello@engaigesmart.com