Sendrato Anti-Money Laundering and Counter-Terrorism Financing Policy
Introduction and Scope
Sendrato recognises the inherent risk of our products and services being exploited for money laundering and terrorism financing. We are committed to complying with Australian law and other applicable regulations to identify, manage, and mitigate these risks. Failure to adhere to these laws and regulations could result in significant penalties and damage to our reputation.
Our AML/CTF Policy
Before engaging in any designated services, customers are required to provide proof of identity. The types of customers we deal with include:
Employees are trained to identify and report any suspicious activities that may indicate money laundering or terrorism financing.
Key AML/CTF Principles
Policy Roles and Responsibilities
Sendrato Company Directors and Senior Management oversee the AML/CTF policy. All employees must comply with this policy and undergo role-specific training.
Monitoring and Reporting
We report to our payment acquiring partner for:
1. PURPOSE OF OUR POLICY
(a) Providing the systems and services that we offer; and
(b) The normal day-to-day operations of our business, including compliance with AML and KYC regulations.
2. WHO AND WHAT THIS POLICY APPLIES TO
2.2 We handle Personal Information in our own right and also for and on behalf of our customers and users.
2.5 If an individual provides Personal Information or other information about someone other than themselves, they warrant that they have that person's consent to provide such information for the specified purpose.
2.6 Our website and services are unavailable to children (persons under the age of 18 years) without their parent or guardian’s consent.
3. THE INFORMATION WE COLLECT
3.1 In the course of business, we collect Personal Information necessary for our operations. This information allows us to identify individuals, share Personal Information when asked, contact individuals, and transact with them. The type of information we may collect includes but is not limited to:
(a) Personal Information, such as name, location, date of birth, nationality, family details, and other information defined as “Personal Information” in the Privacy Act;
(b) Contact Information, including email address, telephone & fax number, third-party usernames, residential, business, and postal address;
(c) Financial Information, such as bank or credit card details used for transactions;
(d) Statistical Information, for statistical purposes; and
(e) AML/KYC Information, required for compliance with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations.
4. HOW INFORMATION IS COLLECTED
4.1 Most information will be collected when individuals use a smart wristband, make an inquiry, or interact with us in various ways.
(a) Registrations, Bookings, and Transactions. When individuals register or make a booking, they provide Personal Information details;
(b) Supply. When individuals supply goods or services to us;
(c) Contact. When individuals contact us in any way;
(d) Access. When individuals access us physically or through the internet; and/or
(e) Pixel Tags. Pixel tags enable us to send email messages in a readable format and track email opens.
4.2 We will ensure that individuals are aware of when their Personal Information is being collected, both electronically and physically.
4.3 Where we obtain Personal Information without an individual’s knowledge, we will either delete/destroy the information or inform the individual that we hold such information, following the Australian Privacy Principles.
5. WHEN PERSONAL INFORMATION IS USED & DISCLOSED
5.1 In general, we will not use Personal Information other than for the purpose for which it was collected, except with the individual’s permission.
5.2 We will retain Personal Information for the necessary period, unless a longer retention period is required or permitted by law.
5.3 If it is necessary to disclose an individual’s Personal Information to third parties compliant with the Australian Privacy Principles, we will inform the individual.
5.4 We will not disclose or sell Personal Information to unrelated third parties under any circumstances.
5.5 Information is used for purposes including:
(a) Providing goods and services;
(b) Verifying identity;
(c) Communicating with individuals;
(d) Investigating complaints or unlawful activity; and/or
(e) As required or permitted by law.
5.6 Some circumstances require us to disclose an individual’s information, such as legal obligations.
5.7 We will not disclose Personal Information to entities outside of Australia without similar privacy safeguards.
5.8 We may use third-party service providers (e.g., Gmail, MailChimp) for communication and contact storage, which may be located in the United States.
6. OPTING “IN” OR “OUT”
6.1 An individual may choose to have us collect their Personal Information or exclude themselves from some or all collection.
6.2 If an individual believes they received information from us without their consent, they should contact us.
7. THE SAFETY & SECURITY OF PERSONAL INFORMATION
7.2 We will take reasonable precautions to protect Personal Information from unauthorized access.
7.3 We use SSL encryption to store and transfer Personal Information, but online security cannot be guaranteed.
7.4 We are not responsible for the privacy or security practices of third parties.
7.5 Suspected misuse or unauthorized access to Personal Information should be reported.
7.6 We are not liable for losses resulting from authorized use of Personal Information.
8. Verification of Identity for AML/KYC Compliance
Disclosure for Verification
In accordance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and associated rules and regulations, Sendrato may be required to disclose your full name, residential address, and date of birth to a third-party service provider. This service provider may, in turn, provide this information to a credit reporting agency (CRA) to assess the accuracy of the identification information provided.
Document Verification Services
Additional verification processes may be conducted, which may involve your personal details being cross-verified with the document issuer or official record holder for further validation.
The CRA may compare the details you have provided with the personal information they hold (including names, residential addresses, and dates of birth of other individuals) for the purpose of verifying your identity.
Notification and Record-Keeping
The assessment will be provided to Sendrato, or its designated agent, solely for the purpose of identity verification. If we are unable to verify your identity using the information held by the CRA, we will notify you, providing the name of the CRA involved, and offer you the opportunity to update your information with the CRA. Records of the verification request will be maintained by both Sendrato and the CRA for a period of 7 years from the date of the request. You have the right to request access to these records.
9. HOW TO ACCESS AND/OR UPDATE INFORMATION
9.1 Users of Sendrato can update their Personal Information from within their Sendrato account or profile.
9.2 Subject to the Australian Privacy Principles, an individual has the right to request from us the Personal Information that we have about them, and we have an obligation to provide them with such information within 28 days of receiving their written request.
9.3 If an individual cannot update its own information, we will correct any errors in the Personal Information we hold about an individual within 7 days of receiving written notice from them about those errors.
9.4 It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.
9.5 We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the Personal Information we hold about them.
10. COMPLAINTS AND DISPUTES
10.1 If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to the details below.
10.2 If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
10.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
11. CONTACTING INDIVIDUALS
11.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions, and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.
12. CONTACTING US
12.1 All correspondence with regards to privacy should be addressed to:
The Privacy Officer
Sendrato Australia Pty Ltd
You may contact the Privacy Officer by email in the first instance.
13. ADDITIONS TO THIS POLICY