Privacy and KYC Policy
Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, place an order, and in connection with other activities, services, features or resources we make available on our Site.
Users may be asked for, as appropriate, name, email address, mailing address, phone number, credit card information. Users may, however, visit our Site anonymously.
We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal identification information, except that it may prevent them from engaging in certain Site related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users’ means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
How we use collected information
Deals may collect and use Users’ personal information for the following purposes: We may use the information Users provide about themselves when placing an order to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service or if there is a legal requirement to do so. This includes being requested to disclose information from Police Departments where the information concerns the commission of a criminal offence or relates to life threatening circumstances. • - To run a promotion, contest, survey or other Site feature To send Users information they agreed to receive about topics we think will be of interest to them. • - To send periodic emails We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. Sharing your personal information We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
Third party websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website's own terms and policies.
Your acceptance of these terms
Anti-Money Laundering and Anti-Terror Financing
Purpose of the policy
All jurisdictions to varying degrees have requirements that persons in business are required to look out for and then report activities which may be criminal, aimed at money laundering or the financing of terror activity.
This policy sets out the organisation’s requirements and processes for the identifying, investigation and reporting of improper activity.
Application of the policy
This policy is applicable to all stakeholders. Regulators and law enforcement expect all persons involved in the operation of a business to be concerned and act accordingly. It is not the case that money laundering only takes place in the financial services. Anywhere where money moves is potentially exploitable by criminals and terror financers.
Money Laundering is the process whereby money from the proceeds of an illegal activity is made to look like it came from a legitimate source. A criminal may have stolen $ 1,000 in cash. In order to conceal where he got the cash from, he might go to a bank and deposit the funds. This is the ‘placement phase’ where the dirty funds are mixed with legitimate deposits. The criminal may transfer the funds between accounts to give the funds the appearance of being legitimate in the ‘layering phase’. Finally the criminal withdraws the funds in the ‘integration phase’.
The Money Laundering Reporting Officer or MLRO, is the designated person charged with investigation potential incidents of money laundering and terror financing.
Terror Financing is the process whereby funds are moved to a point where they can be utilised by an organisation planning or supporting terror attacks.
Tipping-off is a behaviour whereby a money launderer or terror financer is able to suspect or learn that someone believes they may be acting inappropriately. Tipping-off is a criminal offence in many jurisdictions.
Certain kinds of behaviour can alert a stakeholder to an attempt at money laundering or terror financing. The following examples are by no means extensive. Generally, if any aspect of a business transaction inclines a stakeholder to look at that aspect more closely, it potentially highlights suspicious activity.
- Refusing to undergo the Know Your Client (KYC) process;
- Being reluctant to reveal the details behind the source of the funds;
- Outright boasting as the source of the funds or criminal intent;
- Behaving in such a way that makes no commercial sense, such as signing-up for the product and immediately withdrawing;
- Providing KYC details or documents that are incorrect;
- Transacting from a high risk geography. Certain parts of the world are highlighted from time-to-time as being centres for criminal or terrorist funding activity and are sanctioned. The MLRO can provide you with a list; or,
- Asking detailed questions around the controls instituted to counter money laundering or terror financing.
The KYC Process
No business can knowingly deal with a criminal undertaking a crime or terror financer. No business can deal with someone they reasonably suspect of engaging in such activities. Should the Business suspect that it is dealing with a party breaking any applicable law, or planning to do so, the Business reserves the right to carry out the KYC Process.
The KYC process is a tool enabling the business to establish who it is dealing with and whether they constitute a threat.
For individuals, the following original documents (copies are not acceptable) are required to be viewed:
- A photo ID. A valid passport, drivers license, or national ID is required. If there is any doubt as to the suitability of the ID, the MLRO must be consulted;
- Proof of address. A utility bill, rent agreement, mortgage statement is required. This document is to be less than three months old.
For companies, trusts or similar organisations, the following documents are required to be viewed:
- A founding statement (such as that from a registrar or court), a contract (in the case of a partnership), a trust deed, or other proof of formal registration;
- A list of the current directors, trustees, partners, etc.
The MLRO reserves the right to demand that the KYC process be repeated at any time or that proof of source of funds be immediately supplied.
If the parties are never physically present together, the documents supplied are to be certified as original copies by a suitably qualified person (a solicitor, policeman, clergy, etc) along with a statement from that person that the individual is known to them and that they have had sight of the original documentation.
No part of the KYC process is to be undertaken by a third party not connected to the business.
Records are kept centrally for a period of five years after the termination of the relationship.
Records are required to be lodged via [email protected] within three working days of the KYC process having been completed. The MLRO reserves the right to terminate a relationship if documents are not forthcoming or in a format or state that cannot be opened or interpreted.
No person may suffer civil or criminal consequences or any kind of harassment for having raised a suspicion in good faith. Failure to treat a matter with the concern and delicacy it requires may result in disciplinary action.
Tipping-off is a criminal offence in many jurisdictions. Terminating a transaction after a suspicion often amounts to tipping-off.
Making a report
Reports are to be e-mailed to [email protected].
The reports should contain:
- The names of all concerned parties;
- The dates at which they became customers and the date or dates at which suspicion arose; and,
- What caused the suspicion to arise and how this came about and other information that may be relevant.
The MLRO will investigate the incident and may require further documentation or information.
The MLRO will make decision as to whether to file a Suspicious Transaction Report with the relevant authorities in the jurisdiction or jurisdictions concerned.