This privacy policy sets out how we, AML IQ Pty Ltd (ACN 695 971 594), treat the privacy of customers, users of our services and website, our suppliers, and others we interact with or about whom we obtain personal information.
We respect the privacy rights of individuals and are committed to protecting your privacy in accordance with the Australian privacy laws. This policy details how we collect, store, use and disclose personal information.
In this privacy policy, the term “personal information” has the meaning it has in the Privacy Act (1988)(Cth) and includes information (including opinions) about an identifiable individual, including names, addresses, telephone numbers, email addresses, dates of birth, signatures, credit card information, information about nationality, citizenship or residency, passport and other identity document information, drivers’ licence details, photographs, video footage, biometric/liveness information, information about occupation, professional qualifications, company roles, and if and where applicable, includes information that constitutes “sensitive information” as defined under the Privacy Act. We do not generally collect health information, information about religious or philosophical beliefs, union membership or other sensitive information unless incidentally provided by an individual or required for a specific lawful purpose.
We collect some personal information about individuals.
Except in the limited circumstances set out in this policy, we will not collect, store, download or otherwise use identity verification artefacts (including images from identity documents, selfie/liveness images or video, facial matching outputs, biometric or biometric-derived data, device/session data and similar verification evidence) that are collected by the operators of and held in the platform of our third party provider whose platform services we resell to customers. That information remains within that third party platform (and any underlying verification/screening providers used within the platform’s workflow) and is stored and processed only within that platform in accordance with the privacy policy of the platform.
We collect personal information in circumstances including the following:
We do not purchase or use third-party consumer marketing lists.
We may use ‘cookies’ to collect data (not personal information) relating to your general internet usage. This data may include IP-addresses, browser versions, number of visits and similar such data relating to your navigation of the internet and our site. A cookie is a small text file that is placed on your computer or device’s hard drive. Cookies help us to improve our site and to deliver a better and more tailored service, for instance by storing information about your preferences and allowing us to recognise you when you return to our site.
You may refuse to accept cookies by activating settings on your internet browser.
We use and disclose the personal information collected from you for the purpose it was provided or collected, including in the following ways:
1.For the purposes of collection described in (1) above;
(b) To respond to enquiries received from you;
(c) To prevent identity fraud, detect financial crime risk and support AML/CTF compliance for our own business;
(d) To process, confirm, fulfil and update you about and to carry out our obligations arising from any contracts entered into between you and us;
(e) To manage our relationship with you and perform our obligations under the agreement you conclude with us when using our services;
(f) To perform authorised financial transactions with you;
(g) To answer enquiries or support tickets;
(h) To provide services to you and to tailor possible service solutions to you, as a customer;
(i) To verify your identity and to assist you if you have forgotten any user name or password;
(j) To communicate with you and provide you with information (whether by email, post or other means) about our services, where you have requested or consented to receiving this from us or where this provision is otherwise permitted at law;
(k) To notify you about changes to our provision of services, or policies and agreements relating thereto;
(l) To send marketing communications, subject always to inclusion of an unsubscribe feature;
(m) To receive and address feedback from you;
(n) To protect our legal interests and fulfil our regulatory obligations (if and to the extent necessary); and
(o) in other circumstances, with your prior consent or where permitted by law.
We may also provide personal information to third parties outside our company for limited purposes, such as to help us in providing services to customers. Those persons and business may include:
1.Our online payment gateway service providers, for the purpose of facilitating payments;
(b) Third party software providers who store details of customer accounts for us or who provide other IT services e.g we engage sub-processors that support our platform, CRM, email and analytics; and Our professional advisors, subject to confidentiality.
We may also disclose your personal information to third parties outside our company:
(a) To our related entities, shareholders or service partners only where necessary for service delivery, support, governance, technology administration, business operations or compliance and subject to confidentiality and appropriate access controls;
1.Where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties;
2.If all or substantially all of our assets are acquired by a third party, in which case personal information which we hold about our customers may be one of the transferred assets (subject to the same constraints on use and disclosure as under this policy);
(d) If we are under a duty to or are otherwise permitted to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect the rights, property, or safety of our personnel or customers. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and sharing information with AUSTRAC, regulators, law enforcement agencies, courts, tribunals or government agencies where authroised by law, including in connection with AML/CTF obligations or lawful information requests; and
1.Otherwise where we have your express permission to do so.
We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services to us or our customers. We deal with third parties that are required, under contract or under the Privacy Act, to meet the privacy standards required by law in handling your personal information, and use your personal information only for the purposes that we gave it to them.
We do not sell any personal information. Any information that may be commercialised will be de-identified and aggregated. We do not use biometric/liveness information for purposes such as profiling or marketing.
We may use de-identified, aggregated or statical information to improve services, develop risk insights, monitor process effectiveness, train staff and improve controls, provided individuals are not reasonably identifiable.
We take all reasonable steps to protect your personal information from misuse, unauthorised access, interference, loss, modification and disclosure, including by implementing internal and external security, restricting access to personal information to those who have a need to know, maintaining technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security.
We primarily operate on a digital records basis, avoiding paper records where possible. We use secure methods of storage for physical materials containing personal information.
We do not disclose or transfer personal information outside Australia.
We retain personal information only for as long as needed or as required by law.
You have a right to access and correct the personal information we hold about you. To obtain a copy of the personal information we hold about you, please write to us at:
The Privacy Officer
AML IQ Pty Ltd
Email: privacy@amliq.com.au.
Please provide sufficient detail about the information in question to help us locate it. We will then use commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action within a reasonable time.
If our response does not resolve your concern, you may complain to the OAIC (www.oaic.gov.au, 1300 363 992).
We may modify, alter or otherwise update this privacy policy at any time. We will post revisions on our website. We encourage you to review this policy from time to time.