Privacy Policy
1. Introduction
At Seamless AML Limited (Seamless AML), we are committed to protecting the privacy of our clients and ensuring the security of personal information. This privacy policy outlines how we collect, use, store, and disclose personal information in accordance with the New Zealand Privacy Act 2020.
As an independent AML auditor and consultant, Seamless AML assists reporting entities in meeting their Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) obligations. While we are not a reporting entity, we may handle personal information provided by our clients for compliance purposes.
This policy does not limit your rights under the New Zealand Privacy Act 2020 and other applicable privacy laws. For more information about privacy rights in New Zealand, visit www.privacy.org.nz.
2. Collection of Personal Information
We collect personal information that is necessary for us to provide our AML auditing and consulting services. This may include:
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Client details: Name and address
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AML/CFT compliance documentation: AML risk assessments, compliance programme materials, and CDD processes
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Business information: Company structure, policies, and procedures
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Financial and transactional data: If relevant to an AML audit or review
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Other information required to provide AML-related services
We collect this information through:
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Dropbox Secure Platform (our preferred method for document collection)
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Email correspondence (if necessary)
3. Use of Personal Information
We use personal information solely for the purpose of delivering AML/CFT audit, advisory, and consulting services. This includes:
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Conducting independent AML/CFT audits and compliance reviews
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Providing AML/CFT risk assessments and programme development
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Advising on AML/CFT obligations, policies, and procedures
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Assisting clients in meeting regulatory requirements
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Responding to client inquiries and providing ongoing AML support
We do not use personal information for marketing purposes without prior consent.
4. Disclosure of Personal Information
We only disclose personal information where necessary to provide our services or as required by law. This may include sharing information with:
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Regulatory authorities (e.g., Department of Internal Affairs, Financial Markets Authority, Reserve Bank of New Zealand) if required during compliance-related engagements
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Our professional advisors (e.g., legal or accounting consultants assisting with AML matters)
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Service providers that support our operations, such as IT and data security providers
Where possible, we take steps to ensure that third parties handling personal information are bound by confidentiality and privacy obligations equivalent to our own.
We do not file Suspicious Activity Reports (SARs), as we are not a reporting entity. However, we may advise our clients when a SAR may be appropriate under their AML/CFT obligations.
5. Storage and Security of Personal Information
We take reasonable steps to protect personal information from loss, misuse, unauthorised access, modification, or disclosure. This includes:
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Secure electronic storage via Dropbox, which provides encrypted and access-controlled document management
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Confidentiality agreements with employees and contractors handling client data
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Email security measures to protect correspondence containing sensitive information
We retain personal information for as long as necessary to provide our services and meet legal obligations.
6. Access to and Correction of Personal Information
Clients have the right to access and correct their personal information held by us. If you would like to access or update your personal information, please contact us in writing.
7. Changes to Our Privacy Policy
We may amend this privacy policy from time to time to reflect changes to our services or legal obligations. The most up-to-date version of our privacy policy is available on our website.
8. Contact Us
If you have any questions about our privacy policy or the handling of personal information, please contact us in writing at the following address: