Privacy Policy
Effective Date: January 1, 2025 | Last Updated: January 1, 2025
AML Assure Pty Ltd ("AML Assure", "we", "our", or "us") provides an end-to-end Customer Due Diligence (CDD) and Anti-Money Laundering / Counter-Terrorism Financing (AML/CTF) compliance solution tailored to the Australian real estate sector. We act on behalf of our clients ("Clients") to verify the identity of their customers ("Customers") as required under the AML/CTF Act 2006 (Cth) and other applicable regulatory requirements ("Applicable Laws").
This Privacy Policy ("Policy") explains how we collect, use, disclose and protect personal information in connection with our services and website.
It applies to:
- A. Customers (see Section A); and
- B. Clients, website visitors and others (see Section B).
Together referred to as "you".
Definitions
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not, as defined under the Privacy Act 1988 (Cth).
Service Providers means third-party vendors engaged to support the delivery of our services, such as identity verification, sanctions screening, hosting and analytics providers.
AML Assure is an APP entity under the Privacy Act 1988 and is committed to managing Personal Information in accordance with the Australian Privacy Principles (APPs), the AML/CTF Act 2006 and other Applicable Laws.
We may update this Policy from time to time. Updates will be published on our website and will take effect from the date of publication.
Company-Wide Commitment to Privacy
Safeguarding Personal Information is central to AML Assure's business.
- All employees undertake mandatory training on privacy, data protection and AML obligations.
- Privacy considerations are embedded into our compliance workflows and product design.
- Our Clients are contractually required to comply with the Privacy Act, AML/CTF obligations, and our security standards.
Section A: Customers
1. When We Handle Your Information
We may collect and process Personal Information about you in two circumstances:
On behalf of a Current Provider: A real estate agent, law firm, accountant, conveyancer, or other entity legally required to conduct AML/CTF checks. We act strictly on their instructions. In this case, their privacy policy applies, and you should contact them directly for queries or access requests.
For potential Future Providers: With your authorisation, we may securely retain your verification information for use by other service providers in accordance with Applicable Laws. This Policy applies in those cases.
2. Information We Collect and Disclose
We may collect the following categories of Personal Information directly from you, from your Current Provider, or from documents you provide:
| Category | Examples |
|---|---|
| Contact Information | Full name, email, phone, residential address |
| Identity Documents & Identifiers | Driver licence, passport, Medicare card, identification numbers |
| Biometric & Sensory Information | Facial images, liveness detection, video recordings |
| Demographic Information | Date of birth, nationality, gender (as shown on ID) |
| Geolocation & Device Data | IP address, device ID, location metadata |
We may share this information, where necessary, with:
- Your Current Provider (who requested the CDD check);
- Our Service Providers;
- Future Providers (if authorised by you and permitted by law).
3. Data Retention
We retain Personal Information only for as long as necessary to meet our Clients' legal obligations or as otherwise required by law. Once no longer required, information is either securely destroyed or de-identified.
4. Use and Disclosure
We use your Personal Information to:
- Conduct CDD, KYC, sanctions, PEP and adverse media checks;
- Prevent fraud and financial crime;
- Comply with legal and regulatory obligations;
- Respond to enquiries, complaints or disputes.
We may disclose Personal Information to:
- Regulatory, government or law enforcement agencies, if required by law;
- Verification sources, such as the Document Verification Service (DVS), ACIC, VEVO, and sanctions screening databases;
- Successors in the event of a merger, acquisition or restructure.
We will never sell your Personal Information.
5. Security and Storage
- Customer data is hosted on secure servers located in Australia, operated by providers meeting ISO 27001 and SOC 2 standards.
- Data is encrypted at rest (AES-256) and in transit (TLS 1.2+).
- Access is strictly role-based and audited.
- Staff undertake ongoing security awareness training.
6. Overseas Disclosures
We aim to keep all data in Australia. However, in limited cases, information may be disclosed overseas if:
- Verification of a foreign document or visa is required; or
- A Client's authorised personnel are based overseas.
7. Access, Correction & Complaints
You may request access to, or correction of, your Personal Information by contacting us. Where the information is held on behalf of a Client, we will refer your request to that Client.
Complaints should be directed to AML Assure in the first instance. If you are dissatisfied, you may escalate to the Office of the Australian Information Commissioner (OAIC):www.oaic.gov.au.
Section B: Clients, Website Visitors & Others
1. Information We Collect
We may collect:
Directly provided information: Name, contact details, job title, business information, enquiry forms, emails.
Automatically collected information: IP address, device details, browser type, usage analytics.
Cookies & tracking technologies: To improve website performance and personalise services.
We do not knowingly collect information from children under 13.
2. How We Use & Share Your Information
We process this information to:
- Provide services to our Clients;
- Improve our website and offerings;
- Communicate with you, including marketing (which you may opt-out of);
- Ensure system security and compliance with legal requirements.
We do not sell Personal Information. We may share it with Service Providers or regulators where required.
3. Your Rights
Subject to law, you may request to:
- Access or correct your information;
- Request deletion or de-identification;
- Withdraw consent to marketing communications.
Contact Us
If you have any questions or complaints about this Policy or our data practices, please contact us:
Email: info@amlassured.com
Website: www.amlassured.com
We will aim to respond within 30 days.
If you remain unsatisfied, you may contact the OAIC at 1300 363 992 or viawww.oaic.gov.au.
© 2025 AML Assure Pty Ltd. All rights reserved.