Sun Card Pty Ltd (ABN 33 079 249 595) trading as Flagship AML (we, us or our) is committed to protecting personal information and handling it responsibly and transparently.
This Privacy Policy explains how we collect, use, disclose, store and protect personal information in connection with our Anti Money Laundering and Counter Terrorism Financing (AML/CTF) compliance platform and related services.
This Policy is prepared in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and the Spam Act 2003 (Cth).
This Privacy Policy applies to personal information collected:
This Policy does not replace or limit obligations imposed by AML/CTF laws on reporting entities.
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether recorded in a material form or not.RPersonal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether recorded in a material form or not.
Sensitive information has the meaning given in the Privacy Act 1988 (Cth) and includes information such as identity documents and verification details.
We may collect the following categories of personal information:
(a) Account and contact information
(b) Platform usage and compliance information
Important:
Flagship AML does not require customers to upload or store customer identification documents unless a specific platform function requires it. Responsibility for retaining original identity documents remains with the reporting entity.
(c) Technical information
We collect personal information:
We do not collect personal information unlawfully or unfairly.
We collect, use and disclose personal information to:
We do not use personal information for purposes unrelated to our services without consent, unless required or authorised by law.
We may disclose personal information to:
We do not sell personal information.
Where service providers are engaged, we require them to handle personal information consistently with this Policy and applicable law.
Some service providers may store or process information outside Australia (for example cloud infrastructure providers).
Where overseas disclosure occurs, we take reasonable steps to ensure that the recipient handles personal information in a manner consistent with the Australian Privacy Principles.
We may send service-related communications and limited marketing communications consistent with the Spam Act 2003 (Cth).
You may opt out of marketing communications at any time by using the unsubscribe function or contacting us. We do not send unsolicited commercial electronic messages.
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
Security measures include:
We retain personal information only to the extent necessary to operate the Flagship AML platform, comply with applicable laws and meet legitimate regulatory and business requirements.
Customer identification documents and other sensitive source documents are not required to be stored by Flagship AML and remain the responsibility of the reporting entity, unless their upload is required for specific platform functionality.
You may request access to personal information we hold about you and request correction if the information is inaccurate, out of date or incomplete.
Requests can be made using the contact details below. We may need to verify your identity before processing a request.
If you believe we have breached the Australian Privacy Principles or this Policy, you may lodge a complaint by contacting us.
We will investigate complaints promptly and take reasonable steps to resolve them.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.
We may update this Privacy Policy from time to time.
The current version will always be published on our website.
For privacy enquiries, access requests or complaints, please contact:
Privacy Officer
Sun Card Pty Ltd trading as Flagship AML
Email: info@flagshipaml.com.au
Telephone: 1300 823 027