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).
Your Choices
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
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.
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.
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.
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.