Anti-Money Laundering (AML) Consulting

PRIVACY POLICY

Compliense Advisors Pty Ltd [ABN 46 670 831 464]

Definition and References

‘Compliense’ refers to Compliense Advisors Pty Ltd, ABN 46 670 831 464, a proprietary company
formed and registered in Australia, providing governance, risk and compliance services including AML and FinCrime compliance advisory services.

‘Online Services’ refers to subscribing for or registering for our Website content like articles,
emailers, newsletter, generally provided without any specific engagement agreement and whether for free or a charge.

‘Privacy Policy’ or ‘Policy’ refer to this Privacy Policy of Compliense, as amended and updated from time to time applicable in relation to Personal data.

‘Services’ means our professional services including professional advice provided by us to our clients under a specific written engagement, and includes such Services purchased online.

‘We’, ‘us’ or its grammatical variations refer to Compliense or the Website, as the context may
suggest.

‘You’, ‘your’ or its grammatical variations refer to you or the person visiting the Website and
referring, using or accessing its contents.

Personal data

“Personal data” means any information relating to an individual who can be identified, directly
or indirectly, in particular by reference to an identifier such as a name, an identification number,
date of birth, location data or an online identifier.

Personal data also refers to one or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of an individual.

What Personal data we collect and how we use it

When you engage us to provide you Services or Online Services, we may need to collect and use
Personal data where we have a valid business reason to do so.

Personal data collected may include one or more of the following:

Basic information - name, date of birth, work details, relationship to a person
Contact information – postal and email addresses, and contact numbers
Financial information, as relevant
Any other Personal data or information relating to you or other third parties which may
be collected or you provide to us for the purpose of accessing any content on the
Website or receiving our services.

Depending on the nature of your dealings with us, we may collect Personal data from you when you:

Seek our professional Services
Purchase or subscribe to any of our Online Services
Have business dealings or relationship with us
Register your name or subscribe for job openings, or work with us as employee (including

contractors / freelancers)

Attend any event, conference, seminar, workshop organised, conducted, sponsored by us

We may use the Personal data in one or more of following ways:

To provide Services or Online Services to you
To administer our relationship and maintain contractual relations
For accounting and tax purposes
For marketing and business development, develop relationships with clients, potential clients, service providers, contractors
To invite you or communicate about professional events, conferences, workshops and the like
To share with our employees, external contractors, vendors, service providers, technology providers engaged by us whose services or products we use in providing
Services or Online Services to you, or where we outsource some of our functions and activities
To recruit, retain employees and maintain their records during or after their employment. Employee records include related records like details of referees or family details provided to us
To comply with our legal and regulatory obligations, directions of any court, tribunal or other authority or body, and in such case we will inform you as soon as practicable and if permitted
To establish, exercise or defend our and our associate entities legal rights
For our analysis, historical records keeping
Customising or enhancing your online experience with our Website.

Your Personal data may be shared for business-related purposes outside of Compliense with our
related entities, our agents and third-party suppliers, service providers or business
collaborators. These can include contractors and consultants, information technology providers,
business collaborators, event managers, mail houses, credit managers, debt collecting agencies
or any other businesses whose services or support is needed in our day to day activities. We
may also share non-personal or de-identified information with third parties for research,
development, analytics or promotional purposes.

In some cases, the organisations that we may disclose your Personal data to may be located
overseas, or they may hold information in cloud. Such organisations may be our own entities or
operations, associate entities, or to third parties who provide services to us like IT services or
operational support. We will always ensure that we have considered appropriate privacy
considerations and risk, have confidentiality agreements, and restrict and prescribe how they
can or cannot use the Personal data or information.

Cookies and electronic modes of information collection

We use cookies and similar technologies to collect usage data and improve our website. You can
manage your cookie preferences through your browser settings.

When you visit our Website, a small data file called a "cookie"; is stored on your device. They are
widely used in such electronic communication technologies to make websites work more
efficiently and provide information to the website owners.

We use cookies or similar digital markers to maintain user sessions and track the behaviour of
Website visitors (eg: this may help in pages loading faster for you). This enables us to keep our
site relevant and useful. Generally this information obtained through cookies will not identify
you. We do not link this information back to your identity or other information that you have
provided to us.

We and our service providers also use cookies and other digital markers to assist us with our
online marketing services and advertise to our Website visitors on other third-party websites or
platforms (eg. Google Ads Services or LinkedIn).

Cookies placed on third party websites help us to monitor the efficacy of our business
relationships with third parties, improve performance as well as personalise your experience
when you visit our and our service providers’ websites. We may disclose the information
collected via use of cookies on our Website to third parties for our marketing purposes.

Most web browsers are set by default to accept cookies. If your browser is set to not opting-out
of cookies, you consent to our use of cookies in accordance with the terms of this Privacy Policy.
If you use your browser settings to block all cookies, you may not be able to access and/or use
all or parts of our Website, or any feature or functionality.

Your rights in relation to your Personal data

If we have collected or you have provided your Personal data to us, you have the following rights in relation to your Personal data:

To access the Personal data held by us
To have your Personal data corrected. For example, if it is incomplete or incorrect
To opt out of receiving marketing communications
To restrict or object to the processing of Personal data or request erasing Personal data.
Where you have provided Personal data voluntarily, or otherwise consented to its use, the right to withdraw your consent

Some of the actions above can result in interruption to Online Services or Services to you, or
there may be restrictions in providing features or functionalities, or we may have to completely
cease providing Online Services or Services to you.

Please write to us at compliense@compliense.com.au in relation to any of the above in regards to your Personal data, including for any correction or update.

Marketing Communications

If you do not wish to receive our marketing communications, products or service
announcements, kindly write to us on compliense@compliense.com.au; or use the ‘unsubscribe’
facility in any such communication.

Security of Personal data

Compliense takes reasonable steps to ensure the security of your Personal data and information,
appropriate to our business size and context against unauthorised access, disclosure, alteration , or destruction. We will also ensure adequate security of any paper based Personal data. Our IT systems are password protected and subject to regular system check and anti-virus software update. All employees and internal contractors are under contractual obligation to treat all Personal data and other information as confidential.

Third party websites

If you visit the website of any third parties whether or not our service providers, contractors etc,
or any third party that we may have referred to or linked to in any content on the Website, or
who are providing services on our behalf as independent service provider, you will be bound by
their terms and privacy policy, and we do not have control of any such third party’s website
terms and privacy policy.

Agreement

By using this Website and/or providing information to us, you accept and agree to the collection,
use, management and disclosure of your Personal data in the manner described in this Policy.

Website Terms of Use

Our dealings, interactions and your use of Website is also subject to Terms of Use of the Website, as published on the Website.

Complaints

If you are concerned in regards to any Privacy matter, you can contact at
compliense@compliense.com.au, addressed to The Principal, Compliense Advisors Pty Ltd.

You also have the right to complain to the Office of Australian Information Commissioner (OAIC)
(www.oaic.gov.au).

This Privacy Policy is current as of September 2023.