Privacy Policy

Introduction

Trust, Integrity and Compliance Limited (tic company) provide customer due diligence and know your customer services, consultancy and training services to businesses captured by relevant anti-money laundering and countering terrorism financing legislation in the client’s respective jurisdiction.

Tic company operates services that enable clients to undertake identification and verification of their customers in an end-to-end service. Tic company acts on behalf of their clients to verify the identity of customers for the purpose of aiding client compliance with relevant anti-money laundering legislation.

This Privacy Policy describes how we collect, use, disclose, and protect the personal information of clients and their customers.

Definitions

AMLOnline Portal: the portal on which customer information is stored, and is accessible by tic company clients.

Client: the business or entity that has engaged tic company to provide applicable services.

Customer: the person or entity that has engaged tic company’s client.

Personal information: any information that identifies an individual, and includes “personal data” as per the relevant privacy laws in jurisdictions.

Service providers: third party service providers that tic company uses for the purposes of customer due diligence.

Applicable laws

Tic company’s privacy policies are governed by the Privacy Act 2020, the European General Data Protection Regulation 2016/679 (“GDPR”), if applicable, and other applicable laws and regulations in the respective jurisdictions.

Customers: What We Collect

For the purposes of conducting anti-money laundering customer due diligence, tic company are agents with authorisation to act on behalf of clients, under the applicable laws.

To carry out the customer due diligence checks required by law, tic company collects personal information from customers, including:

  • Name
  • Contact information
  • Date of birth
  • Place of birth
  • Interactions with the client
  • Financial information, including assets and income
  • Tax residency
  • Tax file numbers (i.e., an IRD number)
  • Open source (public) information that you have published
  • How you may be related to another party for business and personal reasons (i.e., trustee of a trust, or director of a company).

Some of the above information may be collected from tic company clients, or directly from you.

Tic company does not hold or collect information that is suspected to have been gathered using unlawful means. Where this is encountered, the proper authorities are notified.

What Is Done With That Information

Tic company staff can see all information about you unless they know you personally, or there is another conflict of interest. Tic company staff are not allowed to browse information, and must only access records that they are assigned to work on.

Tic company staff will collect and store information about you in the relevant systems, and review as required by law. There are processes in place to ensure that duplicates are identified.

Information collected on you is verified against global data sources, including some Australian and New Zealand databases, that require tic company to revalidate information each time it is provided to us. This is not available to tic company’s clients, and is carried out by tic company on behalf of their clients.

Information is not shared amongst tic company clients unless you have provided express permission for that to occur. You will be asked if you are comfortable for that to occur, and you are able to refuse.

Clients may undergo audits, statutory and law enforcement processes, in line with jurisdictional anti-money laundering legislation. Your information is only released in those circumstances.

How long information is retained for

The information collected on customers is kept for five years in New Zealand, via the tic company AMLOnline Portal, which tic company clients have access to.

Occasionally, tic company clients may retain records for a longer period.

At the end of the required retention period, data on you is digitally shredded and removed from the Portal.

Correction of personal information

You have the right to access your personal information and request a correction, subject to certain grounds for refusal. Before this right can be exercised, you must provide evidence that you are the individual to whom the personal information relates to.

If tic company believes that the correction is reasonable and is able to be carried out in a reasonable manner, the correction will be made. In all other cases, tic company will take reasonable steps to note the personal information that you have requested to be corrected.

To undertake a correction, please email privacy@ticcompany.com. This email should contain evidence of who you are, and set out the details of the correction that needs to be made.

International data transfers
Tic company may be required to transfer, share or process data in countries other than the country that you reside in. There may be different privacy rules in place. Tic company have safeguards and measures in place to ensure that your information is protected in accordance with this Privacy Policy and applicable data privacy legislation.

Clients, website visitors, and enquiring parties

Tic company will collect information from you when:
You use an online enquiry form on the ticcompany.com website, call tic company, meet tic company in person, or otherwise contact tic company
When you sign up for our newsletters, ATTIC magazine subscription, or other electronic alerts or informational updates; or
When you register for, or log into, the tic company AMLOnline Portal.

In these circumstances, tic company will gather the following information:
Your name
Your contact information
Your phone number
Any other information that you choose to provide to us.

We may also gather other information about you, such as:

  • IP Addresses
  • Operating systems
  • Your device information
    Information about the use of tic company products, services or their website.

Some of this information may be gathered through third party tools, website cookies or other third party tools.

Some information collected is mandatory, and some will be optional. This will be signalled when you contact us via the above means. While you may choose not to provide that information to us, this may mean that the website, newsletters, or alerts, or platforms that you access, will not work as intended, or have limited functionality.

What we do with your information

We may use your information to:

  • Contact you
  • Respond to your queries
  • Provide newsletters, electronic alerts or other communications to you
  • Market our products and services to you, including electronic contact;
    Improve tic company websites, products and services;
    Bill you and collect outstanding payments owing to tic company
  • Conduct anonymous surveys, research or statistical analysis
    Protect and/or enforce tic company’s legal rights and interests, including defending any claims
    Respond to lawful requests by public authorities, or to comply with law enforcement.

You can opt out of marketing emails, newsletters and other communications by emailing us: privacy@ticcompany.com.

Disclosing your information

We may disclose your personal information to:

  • Related companies to tic company;
  • Businesses that support tic company, their products or services, including businesses or persons that maintain IT systems or servers that are used to provide the tic company website, AMLOnline Portal, or other systems;
  • Public authorities or law enforcement that require tic company to provide that information;
  • Any person authorised by law; or
    Any person with your express consent.

Contacting us

If you have any queries on this privacy policy, our practices, or if you would like to request access to, or correction of, personal information about you, you can contact us: privacy@ticcompany.com