Transparency Report

Aperim Pty Ltd (ABN 46150699737; ACN 150699737) is incorporated in New South Wales, Australia and operates the aicial brand. In this report, “aicial” refers to that brand; “we”, “us” and “our” refer to Aperim Pty Ltd; and “you” refers to a reader of this report.

We publish this report because transparency about government and law-enforcement access to user data is part of the honesty our Ethics Charter requires of us — the same “Honest numbers only” standard among the Ethics Charter commitments reflected in our Responsible AI Usage Policy. A real figure, including a real zero, stated plainly and on the record, is what that standard means here.

Our Government and Law-Enforcement Data Request Policy explains, in detail, how we evaluate and respond to a government or law-enforcement request for user data, including the legal standard we require before we act on one. This report does not restate that process. It publishes the figures that process produces.

This is aicial’s first transparency report. It covers the period from Aperim Pty Ltd’s incorporation on 3 May 2011 to 19 August 2026, the date we first published this report.

We start counting from incorporation, rather than from some more flattering later date, so that this report’s coverage matches the full length of time during which a government or law-enforcement request could, in principle, have been made to us — even though most of that period predates the aicial brand itself. Each future report will cover the period since the previous report, so that the full series of reports covers the company’s history with no gap.

Each report we publish states, for the period it covers:

• the total number of government or law-enforcement requests we received for user data;
• how many of those requests were legal process — a subpoena, warrant, court order or comparable compulsory process — and how many were informal requests made without legal process;
• how many of those requests we responded to under the emergency basis described in section 4 of our Government and Law-Enforcement Data Request Policy;
• the number of requests we complied with, in whole or in part; and
• the number of requests we did not comply with at all.

We apply this same structure in every edition, so the figures are comparable from one reporting period to the next. These figures cover a request made to us. They do not cover a request that a government or law-enforcement authority makes directly to a service provider that hosts our systems on our behalf — see our Sub-processors list — which we may not be told about.

We received zero government or law-enforcement requests of any kind for user data during this reporting period. Every category in section 3 is therefore zero for this period: zero legal process, zero informal requests, zero emergency requests, zero requests complied with in whole or in part, and zero requests declined. No request in this reporting period is subject to a non-disclosure order or other prohibition on disclosure, so this figure is not qualified by section 5.

That is a straightforward fact about aicial’s first reporting period, not a prediction that it will remain true indefinitely. We publish it because an honest zero is still a real, checkable figure, stated on the same public record we commit to using once that number changes.

A government or law-enforcement request can arrive together with a legal prohibition on disclosing that the request was made at all — for example, a non-disclosure order attached to a warrant or similar compulsory process. Where that happens, a future report covering that period will not describe the request while the prohibition remains in force.

We will still state the fact that a request we are prohibited from describing exists, to the extent the prohibition itself permits us to say even that much, rather than publishing a figure that reads as though nothing happened. If a prohibition is later lifted or narrowed, we will update a future report with what we are then able to say.

This first report states a single figure in every category: zero. Once we receive a government or law-enforcement request, we commit to carrying the same standard into every later report — real figures, not rounded, averaged or omitted to present better, and corrected in a later edition if we discover that an earlier one was wrong.

We intend to publish this report at least annually. We will publish it more often than that if the volume or nature of the requests we receive makes a more frequent report materially informative to you.

A later edition of this report replaces this one on this page and covers the reporting period stated in that edition’s own section 2. The version, effective date and last-reviewed date shown at the top of this page identify the current edition. We retain a copy of each earlier edition and will provide it on request — see section 9 — so the series described in section 2 stays a complete, checkable record even after a later edition replaces the version published here.

For a question about this report, contact:

Aperim Pty Ltd, which operates the aicial brand
ABN 46150699737
ACN 150699737
New South Wales, Australia
Email: compliance@aicial.com

If you are a government or law-enforcement authority submitting a request, or you have a question about our approach to a government or law-enforcement request for user data, see our Government and Law-Enforcement Data Request Policy instead, which names the correct contact for that purpose.