privacy policy

AML Incubator (“AMLI,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect Personal Data—meaning information that identifies you or can reasonably be linked to you—when you interact with: (i) our websites that post or link to this Privacy Policy (the “Site”); and (ii) our offline activities related to those services. It also describes the choices available to you regarding our use of your Personal Data.

Please read this Privacy Policy carefully. We may update it from time to time. Changes take effect when we post or link the revised version on the Site. For any material changes to how we collect or use Personal Data, we will highlight the update in advance on the Site’s homepage. Refer to the “Last Updated” date above to see when this Policy was most recently revised.

You may visit the public areas of the Site without providing Personal Data. However, if you choose not to provide information we request (for example, to create an account, access client resources, or receive services), certain features of the Site or our services may be unavailable.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies, pixel tags, SDKs, local storage, and similar technologies (collectively, “Cookies”) on our websites and online services (the “Site”) to help the Site function, improve performance, and deliver a better experience. Where required by law, we will obtain your consent before setting non-essential Cookies. You can manage preferences at any time via Cookie Settings (see Your Choices below).

Essential Cookies

What they do

Enable core Site functionality (e.g., page navigation, session management, security, load balancing, and your Cookie preferences).

Personal Data

Typically limited to a pseudonymous session or device ID necessary to distinguish your visit and maintain your session.

Duration

Usually session-only (deleted when you close your browser), though some may persist briefly to record your choices.

Legal basis

Our legitimate interests in providing a secure, functioning Site (and/or contractual necessity).

Functional Cookies

What they do

Remember choices and settings (e.g., language, login state, saved forms), and tailor features or content when you return.

Duration

From session up to 24 months, depending on purpose.

Legal basis

Consent where required / otherwise legitimate interests in enhancing usability.

Performance / Analytics Cookies

What they do

Help us understand Site use (e.g., pages viewed, time on page, referrers, device/browser type, approximate location derived from IP) so we can maintain, secure, and improve the Site and our services; measure the effectiveness of communications (including open and click metrics for certain emails).

Tools

We may use analytics providers (e.g., Google Analytics) that supply aggregated reports. While reports we receive are aggregated, analytics providers may process your Personal Data to deliver those reports. You can opt out of Google Analytics by using the Google Analytics opt-out browser add-on.

IP addresses

When you visit the Site, our servers log your IP address, timestamps, and visited pages to diagnose issues, protect security, and understand usage (and to derive approximate location).

Duration

From session up to 24 months, depending on the Cookie.

Legal basis

Consent where required / otherwise legitimate interests in running and improving our services.

Targeting / Advertising & Social Media Cookies

What they do

On certain pages, third-party partners may set Cookies (including pixels) to show you ads for AMLI content or services that may be relevant to you across the web and to avoid repeating ads. These Cookies store a unique identifier linked to profiles maintained by our partners and may record your browsing actions on our Site (e.g., links or buttons clicked) along with device and network information (including IP-derived location). Social media plug-ins (e.g., “Like”/“Share” buttons) may allow the platform to recognize that you visited our Site, whether or not you are logged in or have an account.

Duration

Typically 30 days to 9 months (campaign-dependent), and up to 24 months for some social media or retargeting Cookies.

Legal basis

Consent where required.

Your Choices

Cookie Settings

Cookie Settings

Use the Site’s Cookie Settings control to accept, reject, or withdraw consent for non-essential Cookies.

Browser controls

Browser controls

You can set your browser to block or delete Cookies. Essential Cookies may be required for core functionality and the Site may not work properly without them.

Analytics opt-out

Analytics opt-out

You can opt out of Google Analytics via the Google Analytics browser add-on.

Do Not Track / Global Privacy Control

Do Not Track / Global Privacy Control

Our Site currently recognizes widely adopted browser-level opt-out signals where legally required; otherwise, use Cookie Settings to manage preferences.

Third-Party Cookies

Some Cookies are set by third parties that provide services to AMLI (e.g., analytics, advertising, social media integrations). AMLI does not control how these third parties use information once collected and their use is governed by their own privacy policies. We maintain contracts and require appropriate safeguards where applicable.

Retention

Cookie data is kept for the period stated above for each category (generally session to 24 months, unless a shorter or campaign-specific period applies). Server logs containing IP addresses are retained for a limited period necessary for security, diagnostics, and compliance.

USERS

When you engage with AMLI, you may provide your company name and address, your name, affiliated reporting entity type (if applicable), phone number, and email address. We use this information to deliver our products and services, provide access to tailored content obtained from the website or client portal, and perform internal analytics to improve our offerings, services, and communications. We do not disclose your information to third parties except as needed to deliver our products and services or as required by Canadian or international law.

COLLECTION OF PERSONAL DATA

“Personal Data” means information that identifies you or could reasonably be linked to you (for example, your name, email address, telephone number, postal address, employer, job title, or date of birth). We collect and process Personal Data to operate the Site, respond to inquiries, provide our services, manage our relationship with you and our clients, and to comply with applicable laws (including anti-money laundering, anti-terrorist financing, sanctions, and privacy laws such as PIPEDA).

How we collect Personal Data

We may collect Personal Data

Directly from you

Directly from you

wWhen you create an account, submit web forms, request information, engage AMLI for services, upload documents, participate in webinars/events, or communicate with us by email, chat, phone, or other channels.

From your employer or another organization

From your employer or another organization

When an employer, client, sponsor, or partner designates you as a representative, user, or contact and provides your information to us in connection with our services.

In the course of providing compliance services to our clients

In the course of providing compliance services to our clients

Where AMLI acts as a service provider/processor and receives Personal Data about our clients’ personnel, contractors, or customers (e.g., for KYC/KYB/EDD, sanctions screening, or transaction monitoring). In such cases we process Personal Data pursuant to our client agreements and instructions.

From service providers and partners

From service providers and partners

For example, identity/verification vendors, sanctions/PEP and adverse-media screening providers, analytics and communications platforms, conference organizers, and referral partners.

From public or commercial sources

From public or commercial sources

Including government or corporate registries, regulatory filings, professional networking sites, published directories, and licensed marketing lists where permitted by law.

AML/KYC-related collection

To meet legal and contractual obligations, AMLI may request or receive Personal Data necessary for KYC/KYB/EDD and sanctions screening, such as legal name, date of birth, residential or business address, nationality, government-issued identifiers, beneficial ownership and control information, and supporting documentation.

Payments

We may use third-party payment processors (each, a “Payment Service”) to collect payments made through the Site. If you choose to make a payment, you may be redirected to a webpage hosted by a Payment Service (or its providers). Any Personal Data you submit on that page is collected by the Payment Service and is governed by its privacy policy, not this Privacy Policy. AMLI does not control a Payment Service’s use of such information. We may receive limited information from the Payment Service (e.g., transaction status, amount, and non-sensitive identifiers) for reconciliation, fraud prevention, and recordkeeping.

Your choice

You may visit the public portions of the Site without providing Personal Data. If you choose not to provide information we request, certain Site features or AMLI services may be unavailable.

USE OF PERSONAL DATA

We use Personal Data transparently and in compliance with applicable law for legitimate business purposes. Depending on the context, our legal bases include performance of a contract, compliance with legal obligations, and our legitimate interests (balanced against your rights). Where required by law, we rely on your consent.

Service delivery & fulfillment of requests

Service delivery & fulfillment of requests

We use Personal Data to deliver and manage our services (e.g., compliance advisory, KYC/KYB/EDD support, transaction-monitoring setup, sanctions screening enablement, policy drafting), operate the Site/portals, respond to inquiries, provide customer support, and administer accounts. (Contractual necessity / legitimate interests.)

Regulatory compliance & reporting

Regulatory compliance & reporting

We use and, where legally required, may disclose Personal Data to comply with applicable laws and respond to lawful requests from regulators or law-enforcement authorities (e.g., FINTRAC, the Bank of Canada under the RPAA, provincial/territorial regulators, courts, police). In many engagements we act on behalf of our clients to help them meet their own obligations (e.g., preparing reports, evidence packages, or responses). (Legal obligation / legitimate interests.)

Security, fraud prevention & integrity of services

Security, fraud prevention & integrity of services

We process Personal Data to protect accounts and systems, prevent, detect, and investigate fraud, financial crime, abuse, or security incidents, and to enforce our terms. (Legal obligation / legitimate interests.)

Administrative communications

Administrative communications

We send non-marketing notices about the Site or services (e.g., account, security, service updates, policy/terms changes, billing). These communications are essential; you may not opt out of them. (Contractual necessity / legal obligation.)

Business operations & improvements

Business operations & improvements

We use Personal Data for service quality, audits, analytics, troubleshooting, training, forecasting, product/service development, and to improve Site content and user experience. We may create aggregated or de-identified data for statistical and benchmarking purposes. (Legitimate interests.)

Marketing communications

Marketing communications

Where permitted by law, we may use contact details to inform you about AMLI services, updates, events, and insights we believe may interest you. If your employer is an AMLI client, we may use contact information they provide to reach you in that capacity. You can opt out of electronic marketing at any time (see Your Choices). (Consent / legitimate interests, as applicable.)

Events & webinars

Events & webinars

If you register for or attend AMLI events/webinars, we use Personal Data to manage registration, attendance, communications, and follow-ups. (Contractual necessity / legitimate interests.)

Promotions (if applicable)

Promotions (if applicable)

If we run a sweepstakes, contest, or similar promotion, we use Personal Data to operate it in accordance with the specific rules provided. If those rules differ from this Policy, the promotion rules control for that activity. (Contractual necessity / consent.)

Vendor management & receiving services

Vendor management & receiving services

We process Personal Data to onboard, communicate with, and receive services from vendors and independent professionals (including you or your employer, where applicable). (Contractual necessity / legitimate interests.)

Acting on behalf of clients

Acting on behalf of clients

When AMLI processes Personal Data as a service provider to a client (for example, during KYC/KYB/EDD, screening, or investigations), we handle Personal Data per our client agreements and their instructions, and we assist them in meeting their legal obligations. (Contractual necessity / legal obligation.)

Legal compliance & enforcement

Legal compliance & enforcement

We use Personal Data to comply with tax, accounting, audit, and recordkeeping requirements; to respond to subpoenas or lawful requests; and to establish, exercise, or defend legal claims. (Legal obligation / legitimate interests.)

Corporate transactions

Corporate transactions

We may use and disclose Personal Data in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate safeguards. (Legitimate interests / legal obligation.)

AMLI uses Personal Data for purposes compatible with those described here and in any other applicable online or offline notice. Where required, we will seek your consent before using Personal Data for additional purposes.

DISCLOSURE OF PERSONAL DATA

We disclose Personal Data for the purposes described below. In some engagements, AMLI acts as a service provider/processor to our clients; in those cases, we disclose Personal Data on our client’s documented instructions and in accordance with our agreement.

Client, Employer, or Sponsoring Organization

If your employer, client, or another third party pays for or sponsors your access to AMLI services (e.g., platform access, training, or advisory deliverables), we may—upon their request—share information related to the specific services they funded (for example, service usage, attendance/completion for trainings, or project status). We will not share such information with other parties unless we have your consent or are legally required to do so.

Regulatory and Supervisory Authorities

Where required or permitted by law, we may disclose Personal Data to regulators and public authorities, including FINTRAC, the Bank of Canada (RPAA), provincial/territorial regulators, law-enforcement agencies, courts, or self-regulatory bodies, to: (i) comply with legal obligations and lawful requests; (ii) assist our clients in meeting their own obligations (e.g., responding to examinations, audits, or information requests); or (iii) report significant incidents where legally required.

Third-Party Service Providers (Processors)

We share Personal Data with carefully selected service providers that perform services on our behalf, such as: hosting and cloud infrastructure, identity verification and sanctions/PEP/adverse-media screening, analytics, customer support tools, document management, payment processing, training/event administration, auditing, and professional advisors. These providers are bound by contract, must use Personal Data only for the contracted purpose, and must apply appropriate security and confidentiality measures.

Affiliates

Where applicable and in compliance with law, we may share Personal Data with AMLI affiliates for operational support and—where permitted—marketing communications about relevant products or services. You can opt out of affiliate marketing at any time (see Your Choices).

Strategic Partners and Co-Branded Pages

We may collaborate with partners to offer joint services, events, or content (including co-branded webpages). Information you provide in connection with these Jointly Offered Items may be shared with the relevant partner. Their use of Personal Data is governed by their own privacy policies. If you do not want your information shared in this context, please refrain from submitting Personal Data on those pages or offerings.

Third-Party Data and Content Providers

If you subscribe to AMLI services that include third-party data or tools (e.g., screening databases or analytics), we may be required to provide limited Personal Data to those providers (for example, to verify authorized users or meet reporting obligations set by the provider).

Promotions (If Applicable)

If we run contests, sweepstakes, or similar promotions, we may disclose Personal Data to sponsors or as otherwise described in the promotion rules. If those rules differ from this Policy, the promotion rules govern for that activity.

Publications and Recognitions (If Applicable)

Where relevant (e.g., for training certificates, workshop completion lists, or professional recognitions issued by AMLI), we may publish participant names and business affiliations, subject to applicable law and any choices we make available.

Corporate Transactions

We may disclose or transfer Personal Data to an acquirer, affiliate, or other third party (and their advisors) in connection with a corporate transaction (e.g., merger, reorganization, financing, sale of assets), subject to appropriate safeguards and applicable law.

Legal, Security, and Emergency Purposes

We may disclose Personal Data as we believe necessary or appropriate to: (i) comply with laws and legal processes (including outside your country of residence); (ii) respond to governmental or public-authority requests; (iii) enforce our terms and agreements; (iv) protect the rights, privacy, safety, or property of AMLI, our clients, you, or others; (v) detect, prevent, and address fraud, financial crime, or security incidents; or (vi) pursue remedies or limit damages. Where permitted, we will resist, narrow, or challenge overbroad requests for Personal Data.

HOW YOU CAN ACCESS, CORRECT, OR DELETE YOUR PERSONAL DATA

Subject to applicable law, you may request to review, correct, update, restrict (suppress), delete, or receive an electronic copy of your Personal Data (data portability, where this right applies). To exercise these rights, please contact us using the details in “Contact Information for AMLI.” We will respond in accordance with applicable legal timeframes.

Verification & scope

Verification & scope

For your protection, we will take reasonable steps to verify your identity before acting on a request. We may only implement requests with respect to Personal Data associated with the specific email address (or account) you use to contact us, unless you authorize otherwise and we can verify that authorization.

When AMLI acts for clients

When AMLI acts for clients

In many engagements AMLI acts as a service provider/processor to our clients. Where we process Personal Data on a client’s instructions, we will refer your request to that client (the data controller) and assist them as required by our contract and the law.

Marketing preferences

Marketing preferences

You can opt out of electronic marketing at any time using unsubscribe links or by contacting us (see Your Choices and Contact Information for AMLI). We will continue to send non-marketing/administrative messages as necessary to provide our services or comply with legal obligations.

Data portability

Data portability

Where applicable law provides a right to data portability, you may request an electronic copy of certain Personal Data you have provided to us, which we will supply in a commonly used, machine-readable format.

Limits & exceptions

We will fulfill your request as soon as reasonably practicable, consistent with the law. Please note:

We may retain certain information for recordkeeping, security, fraud-prevention, audit, tax/accounting, or to complete transactions initiated before your request.

We may retain data where required by statute or regulation (for example, anti-money laundering/anti-terrorist financing recordkeeping requirements) or to establish, exercise, or defend legal claims.

If a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse it, as permitted by law, and will explain our reasons.

LINKS TO THIRD-PARTY SITES AND SERVICES

The Site may contain links to websites and online services operated by third parties (for example, social media platforms and third-party collaboration/file-sharing or conferencing tools). These sites and services are not controlled by AMLI. We provide such links for convenience only and do not endorse or assume responsibility for their content, security, or privacy practices.

If you choose to visit, interact with, or provide Personal Data on a third-party site or service, your activity occurs on that third party’s property and is governed by that party’s privacy policy and terms, not this Privacy Policy. This includes situations where you communicate with AMLI via social media, community forums, or third-party collaboration workspaces—your information may be visible to the provider and, depending on your settings, to other users or the public.

We encourage you to review the applicable privacy policies and settings of any third-party site or service you use. This Privacy Policy does not address the privacy or information practices of third parties, including any AMLI affiliates that do not post or link directly to this Privacy Policy.

SECURITY MEASURES

AMLI employs appropriate organizational, technical, and physical safeguards to protect Personal Data from unauthorized access, use, disclosure, alteration, or destruction.

Governance & training

Governance & training

Formal security/privacy policies, least-privilege access, role-based training.

Access & encryption

Access & encryption

MFA, periodic access reviews, encryption in transit and at rest where appropriate.

Monitoring & hardening

Monitoring & hardening

Logging, vulnerability management and patching, periodic independent assessments/pen tests.

Network & endpoint security

Network & endpoint security

Firewalls, endpoint protection, secure configurations, and continuity/backups.

Vendors

Vendors

Due diligence, privacy/security assessments, and contractual safeguards; ongoing oversight.

Incident response

Incident response

Documented plan; we notify clients, individuals, and/or regulators of privacy breaches as required by law.

Retention & disposal

Retention & disposal

Keep data only as needed for stated purposes or legal obligations (including AML/ATF); secure deletion/anonymization thereafter.

Continuous improvement

Continuous improvement

Controls are updated to reflect evolving threats, standards, and legal requirements.

Data Integrity

AMLI will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Privacy Policy, or authorized by you. We will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you). AMLI depends on you to update or correct your Personal Data whenever necessary.

DATA RETENTION

We store information on servers that may be located outside Canada or the USA, including other jurisdictions. Any data stored outside Canada or the USA is subject to the laws of the jurisdiction where it is located. We retain information only as long as needed for the purposes described above, to operate our business, or as required by law.

USE OF THE SITE BY MINORS

This Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through this Site.

SENSITIVE PERSONAL DATA RESTRICTIONS

Unless specifically requested by AMLI to comply with AML/ATF, sanctions, KYC/KYB/EDD or other legal obligations, please do not provide any sensitive Personal Data to us or via the Site (including in free-text fields or attachments). “Sensitive Personal Data” includes, for example: social insurance/social security numbers, passport or ID numbers, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health information, biometric or genetic data, and criminal background.

If AMLI needs such information, we will ask for it through secure channels, limit collection to what is necessary, and process it in accordance with applicable law and our contractual safeguards. If you submit sensitive data without a request, we may delete or restrict it to protect your privacy.

CHANGES TO POLICY

We may update this Policy from time to time by posting a new version on our website with a revised “Last Modified” date. We encourage you to review this Policy periodically for any changes. Your continued use of our website or Services after changes are posted indicates your acceptance of the updated Policy.