Trust, Integrity and Compliance Limited NZBN: 9429046223609 (tic company,” “us,” “we” or “our”) provides customer due diligence and know-your-customer services, consultancy and training services to businesses captured by the relevant Anti-Money Laundering and Countering Financing of Terrorism Act 2009 in the client’s respective jurisdiction.
Tic company operates services that enable clients to undertake risk assessment, identification and verification of their customers in an end-to-end service. Tic company acts as an authorised agent of its clients when collecting and processing personal information for AML/CFT compliance purposes.
Tic company is committed to protecting your privacy and personal information and this Privacy Policy describes how we use, disclose, and protect the personal information of clients and their customers.
AMLify Portal: the portal on which customer information is stored and is accessible by tic company clients.
Client: the business or reporting 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 about an identifiable 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.
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.
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 conduct the customer due diligence checks required by law, tic company collects personal information from customers according to level of risk involved, including:
We collect personal information at your consent and/or as required by law and via the appropriate channels:
In most instances our client will have agreements or engagements/terms and conditions that outline and facilitate Trust, Integrity and Compliance PTY Limited to conduct the necessary processes to collect personal information on their behalf.
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.
Tic company staff may only access your personal information when they are assigned to work on your case. Access is controlled on a strict need-to-know basis. Staff with a personal relationship with, or conflict of interest in relation to, a customer are prohibited from processing that customer’s record and required to declare any such relationship to the manager.
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, which require tic company to revalidate information each time it is provided to us. This is not available to tic company’s clients and is conducted by us 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.
We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. This includes:
In adherence with AML/CFT Act 2009, we cannot retain information collected on customers for more than five years in New Zealand. Records are stored in the tic company AMLify Portal, which our clients have access to.
Occasionally, our 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.
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.
If tic company believes that the correction is reasonable and is able to be conducted in a reasonable manner, the correction will be made. In all other cases, we 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.
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. We have safeguards and measures in place to ensure that your information is protected in accordance with this Privacy Policy and applicable data privacy legislation.
Tic company will collect information from you when:
In these circumstances, tic company will gather the following information:
We may also gather other information about you, such as:
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.
We may use your information to:
You can opt out of marketing emails, newsletters and other communications by emailing us: privacy@ticcompany.com.
We may disclose your personal information to:
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
