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PRIVACY POLICY 

 

Agentic AML Pty Limited  ACN 691 636 343  Level 57, 25 Martin Place, Sydney NSW 2000 

Last updated: 1 May 2026 

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  1. About This Policy 

This Privacy Policy explains how Agentic AML Pty Limited (“we”, “us” or “our”) collects, holds, uses, discloses and otherwise handles personal information in connection with: 

  • products and services that we provide; 

  • our website at www.agenticaml.com.au and any other product and/or service-related websites that we own and operate (our “Websites”); 

  • our marketing and business development activities; and 

  • our general business operations, including recruitment. 

We are committed to protecting the privacy of our contacts, customers, suppliers and employees consistent with the Australian Privacy Principles (“APPs”). We are committed to handling personal information in a manner that is transparent and fair. 

By using our services or interacting with our business, you acknowledge that we will handle your information as described in this Privacy Policy.   

  1. Kinds of Personal Information We Collect 

2.1 Website Visitors 

When you visit or interact with our Websites we may collect your name, email address, phone number and organisation name (where you submit a contact or demo request form), as well as device and browser information, IP address and pages visited through cookies and analytics tools. 

2.2 Marketing Contacts 

If you subscribe to our newsletter, attend an event, download content, or otherwise engage with our marketing communications, we collect your name, email address, organisation, job title, and your interaction data such as email opens, link clicks, content downloads and event attendance, including through cookies and analytics tools. 

2.3 Subscription Services — Account Holders and End Users 

When you or your organisation subscribes to our Subscription Services, we collect account holder and end user information including names, email addresses, roles and permissions, login credentials (hashed), multi-factor authentication enrolment data, session and usage logs, and billing and payment information including through cookies and analytics tools. 

2.4 Subscription Services — Customer Data 

In connection with our various service offerings (including our software-as-a-service subscription services), our customers submit certain data. Such data provided by our customers may include personal information of third parties such as a customer’s own clients, including names, dates of birth, nationalities, addresses, government-issued identification details, source of funds and source of wealth information, and other information necessary for the customer’s AML/CTF and KYC compliance processes. 

We process such data submitted by our customers strictly on the relevant customer’s behalf and in accordance with the customer’s instructions, including as set out in any relevant services agreement between us and the relevant customer. The Customer is responsible for ensuring that appropriate consents, authorisations and legal bases exist for the collection and submission of that data. 

2.5 Recruitment Applicants 

If you apply for a role with us, we collect your name, contact details, resume, cover letter and any other information you provide in support of your application. 

  1. How We Collect Personal Information 

We collect personal information directly from you when you interact with our Websites, register for our subscription services or otherwise procure services from us, communicate with us or submit a form. We may also receive personal information from third parties, including our technology partners (such as analytics providers), publicly available sources, and from customers who submit data in connection with our various service offerings. Where we receive personal information about you from a third party, we will take reasonable steps to ensure you are made aware of this Policy. 

  1. Purposes of Collection, Use and Disclosure 

We collect, hold, use and disclose personal information for the following purposes: 

  • to provide, maintain and improve our services; 

  • to process customer data on our customer’s behalf in order to provide services to our customers; 

  • to authenticate end users of our services and enforce access controls; 

  • to communicate with you about your account, support requests and service updates; 

  • to send marketing communications where you have consented or where we are otherwise permitted to do so (you may opt out at any time); 

  • to process payments and manage billing; 

  • to generate usage data for analytics, product improvement and reporting; 

  • to comply with applicable laws, regulations and enforceable government requests; 

  • to detect, prevent and address fraud, security issues and technical problems; and 

  • to assess applications for employment. 

  1. Automated Decision-Assistance Tools 

Some of our software-as-a-service subscription tools use automated processes to assist our customers in managing their own AML/CTF-related compliance obligations. These processes use personal information to generate screening results, risk assessments and draft documentation. 

Such services are designed as decision-support tools. They are not intended to replace human judgement or to make final determinations.  All outputs of our software-as-a-service subscription tools must be reviewed and verified by the customer. No final decision that significantly affects an individual’s rights or interests is intended to be made by such services alone and all decisions require independent evaluation and final determination by the relevant customer’s personnel.  

This disclosure is provided for transparency regarding our use of automated decision-assistance tools. 

  1. Sensitive Information 

We do not generally collect sensitive information (as defined in the Privacy Act) directly from individuals. However, some of our AML/CTF services require us to collect (or result in us collecting) sensitive information from you or from our other sources. The kinds of sensitive information we collect are as described in this policy. 

Where a customer submits sensitive information in connection with services that we provide, we process such information strictly in accordance with the customer’s instructions and the relevant services agreement between the customer and us. We take steps to obtain warranties from customers that they have obtained any required consents for the collection and use of sensitive information by the customer (and by us and our subprocessors) for the purposes of providing relevant AML/CTF-related services to the customer. 

  1. Disclosure to Third Parties 

In order to provide our services and operate our business, we engage a limited number of third-party service providers who may receive personal information strictly for the purposes described in this Privacy Policy. This includes sharing information: 

  • with third parties who provide underlying infrastructure, hardware and software in relation to our services or the operation of our business; 

  • with third party authentication and identity service providers that support secure access to our subscription services; 

  • with third party screening and risk intelligence providers that assist in the delivery of AML/CTF compliance functionality within our subscriptions services; 

  • with third party AI and machine learning providers whose models are integrated into our subscription services to generate outputs; 

  • with third party payment processors that handle billing and subscription transactions on our behalf; 

  • with third party professional advisers, including legal, accounting and insurance advisers, where necessary for our business operations; and 

  • with related entities within our corporate group as is reasonably necessary in order to operate our business. 

We may also disclose personal information to law enforcement or regulatory authorities where required by law, and to a successor entity in the event of a merger, acquisition or sale of all or substantially all of our assets. 

We do not sell personal information. 

  1. Cross-Border Disclosure 

Some of our service providers, including data storage and technology service providers, may be located or operate outside of Australia. At times, our service providers may hold your personal information in a number of countries outside of Australia, including the United States, Singapore. 

Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure that the overseas recipient is obliged to protect personal information consistent with the APPs and that they are only permitted to use personal information for the purpose for which it is transferred.  

  1. Data Security and Retention 

We take data security seriously and implement commercially reasonable technical and organisational measures to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. We adopt data minimisation principles, particularly regarding identity documentation, by focusing on verification rather than unnecessary retention. 

We retain personal information only for as long as it is needed for the purposes described in this Privacy Policy or as required by law.  When personal information is no longer needed for any purpose for which it may be used or disclosed, and we are not required by law to retain it, we take reasonable steps to destroy it or ensure that it is de-identified.  

  1. Cookies and Analytics 

We use cookies and similar technologies to ensure our Websites and service function correctly and to understand how visitors interact with our content. We use third party tools to collect de-identified metadata about your visit. You can manage or disable cookies through your browser settings, though this may affect your ability to use certain features of our Websites. 

  1. Direct Marketing 

We may use your personal information to send you marketing communications about our products and services where you have consented or where we are otherwise legally permitted to do so. Every marketing communication we send will include a clear and simple mechanism to opt out.  

We do not use personal information submitted by customers in connection with our AML/CTF subscription services for direct marketing purposes. 

  1. Your Rights 

12.1 Access  

You may request access to the personal information we hold about you. We will respond to your request within a reasonable period. We may charge a reasonable fee for providing access where the request requires substantial effort to fulfil. We will not charge you for simply making the request. 

12.2 Correction  

If you believe that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may request that we correct it. We will take reasonable steps to correct the information as soon as practicable. 

  1. How to Contact Us 

If you have any questions about this Policy, wish to exercise your rights, or wish to make a complaint about how we have handled your personal information, please contact us: 

Privacy Officer 

Agentic AML Pty Limited 

Level 57, 25 Martin Place, Sydney NSW 2000 

Email: info@agenticaml.com.au 

We will acknowledge your complaint within a reasonable period and aim to resolve it as soon as practicable. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC): 

Website: www.oaic.gov.au 

Phone: 1300 363 992 

  1. Changes to This Policy 

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. Where we make material changes, we will notify you by posting the updated Privacy Policy at www.agenticaml.com.au with a revised “Last updated” date. 

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