AML Smart Guard Privacy Policy

Effective Date: 31 October 2025

Background

At AML Smart Guard it is important to us that we manage your personal information securely and consistently with relevant legislation, including the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (APPs).

This Policy outlines how AML Smart Guard (“we”, “us”, or “our”) and its related companies collect, disclose use and protect personal information, including:

AML Smart Guard Pty Ltd ABN 44 686 495 769

This Policy is effective as at 31st October 2025. Sometimes we will update it – you can always find a current version at https://amlsmartguard.com.au/important-information.

This policy applies to all individuals whose personal information we collect in the course of providing anti-money laundering (AML) compliance services, consulting, and related business activities.

What is personal information?

Personal information is information about an individual who is identified or reasonably identifiable (for example, your name and date of birth).

Sensitive information is another type of personal information. This is information which is sensitive in nature (for example, your political opinions, philosophical beliefs, membership of a professional or trade association or union, and health information). We only collect sensitive information from you if it is necessary in the circumstances and you have consented to that collection.

1. Collection of Personal Information

AML Smart Guard may collect personal information including, but not limited to:

how and why we collect, store, use and disclose your personal information;
how you can access and update your personal information held by us; and
how you can make a complaint if you have any concerns about how we have handled your personal information.

The types of personal information we collect and hold (and why)

To provide our services and effectively run our business, we may collect the following information from you:

Full name, contact details, job title, and business affiliation
Identification documents and onboarding materials
Transactional data and compliance-related records
Information provided during webinar registration or event participation
Website usage data, including cookies and analytics
behavioural biometric data which includes behavioural analytics on how you use and access our websites and mobile apps;
data required for high-quality and safe provision of services, which can include:
- information entered into text fields or live chat, call recordings and system notes;
- session data that is automatically collected and transmitted by our apps, such as your device IP address, version of the operating system, brand and model of your device, unique identifiers of your device, browser used, information about the time our app was accessed, name and parameters of the network connection;
- information about applications installed on your device (metadata from applications), such as application name, application identifier and version, device identifier and checksum;
- information about the geolocation of your device, such as geolocation data using GPS data, nearest Wi-Fi access points and mobile networks;
- call history on your device; and
other relevant information – depending on the circumstances this may also include membership of professional bodies, tax file number information (other government identifiers (e.g. if relevant to identifying you.
publicly available information about you:

We collect this information directly from individuals, through our website, via email or phone, and from third-party sources where lawful.

If you do not provide us with your personal information (including credit-related information), we may not be able to provide products or services.

2. How we collect information

In many circumstances, we will collect the above information primarily from you (or from someone who is representing or assisting you). However, there are certain instances in which we will collect information about you from third parties where it is unreasonable or impracticable to collect it directly from you. For example, we may collect information about you from a business which provides information about lands and titles checks for the purpose of assessing ownership.

Other third parties that we may collect your information from include:

our agents;
other entity involved in providing any products we offer with a partner and associated benefits;
your co-applicant (if any);
your employers, accountant, referees, banks, landlords, guarantors, lawyers, financial advisers or others with whom you have previously had dealings or persons assisting you who you direct to provide information to us;
by accessing information about you that is publicly available (e.g. internet sources or a search of white pages);
your executor, administrator or attorney;
professional organisations;
public and subscriber only databases;
any person considered necessary in our view to execute your instructions; and
government authorities.

3. Use of Personal Information

Personal information we collect about you will only be held, used and disclosed as is reasonably necessary for our business purposes and as permitted by law.

Purposes for which we will usually hold, use and disclose your personal information, depending on the circumstances and the nature and products and services you are obtaining from us, include:

To provide AML compliance services, consulting, and training
To verify identity and conduct due diligence
To manage client relationships and communications
To comply with legal and regulatory obligations
To improve our services and internal operations
To distribute marketing communications related to our business activities (subject to opt-out)
to identify the user of our apps and the user’s device;
to ensure the safety of using our apps and other services;
to detect and prevent instances of fraud and identity theft, unlawful conduct, and other risks to you or our products and services;
to ensure fast and accurate approval and processing services;
dispute and complaint resolution, and assisting other providers to do the same;
enforcing our rights, including the collection of outstanding payments and where necessary, initiating legal proceedings;
undertaking review and maintenance of our systems and infrastructure;
undertaking research and development regarding new and potential products and services;
compiling statistical data;
improving the quality of the apps and services provided by us;
customer data analytics, which may be provided to or shared with any entity with which we have an alliance or partnership arrangement;
complying with various Australian laws which may specifically require us to collect your personal information, and other laws where collecting your information is necessary for us to comply with our obligations. Some of the key laws which may apply include the:
- Anti-Money Laundering and Counter-Terrorism Financing Act;
- Personal Property Securities Act and State and Territory real property and security interests laws;
- Financial Sector (Collection of Data) Act;
- Corporations Act and other regulatory legislation; and
- Taxation Administration Act, the Income Tax Assessment Act and other taxation laws.

4. Disclosure of Personal Information

Where the Privacy Act permits it, we may disclose your personal information for the purposes above to third parties. Other third parties that we may disclose your personal information to include:

Identity verification platforms
Legal, compliance, and professional advisors
Cloud service providers and IT infrastructure partners
Training and consultancy providers
your co-applicant (if any)
related entities based in Australia or overseas;
entities that provide services to us such as mailing houses or call centre operators;
entities providing other services to us, including legal services, financial services, market research and data providers;
our assignees or potential assignees, or where we act as an agent for, or otherwise on behalf of, another person, to the principal or that other person;
identification service providers and providers of digital identity protection and fraud prevention;
insurers, assessors, underwriters, brokers and other distributors;
government regulatory bodies in Australia and overseas;
entities who wish to be involved in our business, or acquire an interest in our business;
third parties you authorise to act on your behalf or that are otherwise connected with you (such as your accountant, legal representative, referee or an access seeker acting on your behalf to obtain your credit report); and
law enforcement agencies.

Some of these entities may not be located in Australia and may not have an Australian link. For example, we employ service providers in countries such as the Philippines, New Zealand and United Kingdom.

We do not disclose personal information to regulators unless required by law or upon request. We do not sell personal information under any circumstances.

5. Cross-Border Disclosure

Personal information may be stored or processed in jurisdictions outside Australia via cloud-based services. Our primary information storage is in Australia; however, some backup locations are outside. AML Smart Guard takes reasonable steps to ensure that overseas recipients do not breach the APPs in relation to the disclosed information, in accordance with APP 8.

6. Data Security

We will hold your personal information in paper or other physical form, but it is usually held in electronic form on our systems. Service providers or partners may hold the information for us. Your personal information is protected by various physical, electronic and procedural safeguards.

Where a service provider holds your information, we require those service providers to adhere to our approved standards of security and confidentiality to ensure the continuing protection of your personal information.

We train staff who handle your personal information to ensure that your personal information is handled appropriately. Our procedures ensure that your personal information is only made available to staff where necessary.

7. Your rights in relation to opting out / unsubscribing from marketing or promotional communications

If you do not want us to send you any marketing or promotional materials, you can opt out of these services by following the unsubscribe instructions in the promotional message itself, by changing your marketing preferences in your online product portal (if this service is available) or by contacting our Customer Service team via phone.

If you do not want one of our third parties or retailer partners to send you marketing or promotional materials, you will need to opt out of these services with them directly.

Important note on service and operational communications: Even if you opt out of our marketing and promotional communications, there is certain service, operational and other correspondence that we will need to send you about the products and services we provide. (As an example, we have a legal obligation to make you aware of any changes to terms and conditions.)

8. Your ability to access and delete your personal information that we hold

You have specific rights under Australian law in relation to requesting access to and correction of personal information we hold about you and making a privacy complaint.

You can request access to the personal information we hold about you subject to certain exceptions under the Privacy Act. You are entitled to specify how you wish to access your personal information, so long as this is reasonable and practicable. In order to access your personal information, please contact the Privacy Officer

We verify the identity of anyone requesting access to personal information, so as to ensure that we do not provide that information to a person or people who do not have the right to access that information.

We ask that your request for information be as specific as possible so that we can accommodate your request. We will usually provide you with access within thirty (30) days of a request but in some circumstances it may take longer.

Please note, that under Australian law, we are entitled to refuse you access to your information in the following circumstances:

access would be unlawful;
denying access is required or authorised by or under an Australian law or a court/tribunal order; or
access would prejudice enforcement activities or the taking of appropriate action in relation to unlawful activity or serious misconduct.

There may be other reasons we may refuse to provide you access to your information.

Subject to our compliance with our obligations under law, you can request for the deletion of certain personal information we hold about you by contacting the Privacy Officer at privacyofficer@amlsmartguard.com.au or on +61406490115.

9. Cookies and Website Analytics

Our website uses cookies and analytics tools to collect usage data. This information is used to improve site functionality and user experience. Users may manage cookie preferences via browser settings.

10. Third-Party Links

Our website may contain links to external sites. AML Smart Guard is not responsible for the privacy practices of third-party websites and encourages users to review their respective privacy policies.

Privacy Officer Email: privacyofficer@amlsmartguard.com.au

If a complaint is not resolved satisfactorily, individuals may escalate the matter to the Office of the Australian Information Commissioner (OAIC) via www.oaic.gov.au.

Policy Updates

AML Smart Guard may update this Privacy Policy from time to time. The most current version will be published on our website and will include the effective date.