AML/CTF Privacy Notice

Follio is required to collect and handle certain personal information to comply with its obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and associated rules.

This notice explains how we collect, use and disclose personal information for customer identification, verification and due diligence purposes. It should be read together with Follio’s Privacy Policy.

Why we collect your information

We may collect and use your personal information to:

• establish and verify your identity before providing certain services;
• conduct customer due diligence and know-your-customer (KYC) checks;
• identify and verify beneficial owners, trustees, directors, representatives and other relevant individuals associated with a client or entity;
• understand the ownership and control structure of companies, trusts, self-managed superannuation funds and other entities;
• assess and manage money laundering, terrorism financing and other financial crime risks;
• comply with our record-keeping and other obligations under the AML/CTF Act and associated rules; and
• otherwise comply with applicable legal and regulatory requirements.

What information we may collect

Depending on the circumstances and the type of customer or entity involved, we may collect:

• your full legal name, date of birth and residential address;
• your contact details, including your email address and telephone number;
• information contained in identity documents such as your driver’s licence or passport;
• information about your source of funds or source of wealth, where required;
• information relating to companies, trusts, self-managed superannuation funds or other entities;
• information about beneficial owners, trustees, directors, representatives and other individuals associated with a client or entity; and
• other information reasonably necessary for us to meet our customer due diligence and AML/CTF obligations.

Where required to verify your identity, biometric information, including facial images or biometric data used to compare you with your identity document, may also be collected and processed.

Biometric information used for automated identity verification is sensitive information under the Privacy Act 1988 (Cth). Where required, consent will be obtained before biometric information is collected or used.

How we collect and verify your information

We may collect personal information directly from you, from another individual or representative associated with the customer or purchasing entity, from publicly available or official records, and through third-party identity verification and compliance providers.

Follio currently uses StackGo Pty Ltd’s IdentityCheck platform to facilitate identity verification and AML/KYC checks.

Where an identity verification check is required, you may be sent a secure link to complete the verification process. Information processed through IdentityCheck may include your identity details, identity document information and images, and biometric information required to verify your identity.

StackGo may engage approved third-party service providers to perform parts of the identity verification process.

Who we may share your information with

We may disclose personal information collected for AML/CTF purposes to:

• third-party identity verification, screening, technology and compliance service providers, including StackGo;
• professional advisers and other service providers where reasonably necessary;
• AUSTRAC and other government, law enforcement or regulatory bodies where required or authorised by law; and
• other parties where required or authorised by law.

Some third-party providers may process or store personal information outside Australia.

StackGo advises that information processed through its services may be stored or processed in Australia and the European Union and may also be processed by its approved service providers in other jurisdictions.

For further information about how StackGo handles personal information, please refer to StackGo’s Privacy Policy.

What happens if you do not provide your information

We are required to complete certain customer identification, verification and due diligence procedures before providing designated services.

If you do not provide information reasonably required for these purposes, we may be unable to verify your identity, onboard you as a client, provide certain services or continue our business relationship with you.

How we protect and retain your information

Follio takes reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.

Personal information collected for AML/CTF purposes will only be retained for as long as reasonably necessary or as required or authorised by applicable legal and regulatory requirements.

Information processed by third-party identity verification providers may also be subject to their security and retention practices. Please refer to StackGo’s Privacy Policy for further information about its current data handling, security and retention practices.

Your privacy rights

Follio’s Privacy Policy contains further information about how we handle personal information, including how you may request access to or correction of personal information we hold about you.

If you have any questions or concerns regarding how your personal information is handled for AML/CTF purposes, please contact us using the details provided in our Privacy Policy.