1. Introduction

Cross Borders.s.e.c.s., operating under the AML4YOU branding ("we," "our," "us," or the "Company") is committed to protecting the privacy and security of personal information collected through our website and AML compliance services. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our website at www.aml4you.eu and our anti-money laundering compliance services and tools.

This policy applies to all users of our services, including real estate agents, developers, financial institutions, and other professionals required to maintain AML compliance.

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2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

Account and Profile Information:

• Name, email address, phone number, and business address

• Professional credentials and license information

• Company or organization details

• Job title and role description

Compliance-Related Information:

• Customer due diligence (CDD) data

• Know Your Customer (KYC) documentation

• Beneficial ownership information

• Transaction monitoring data

• Suspicious activity reports (SARs) and related documentation

• Risk assessment information

Technical Information:

• IP addresses, browser type, and device information

• Website usage data and analytics

• Login credentials and authentication data

• System access logs and audit trails

2.2 Information from Third Parties

We may receive information from:

• Government databases and watchlists

• Identity verification services

• Public records and regulatory databases

2.3 Automatically Collected Information

• Cookies and similar tracking technologies

• Website navigation patterns

• Feature usage statistics

• Performance and error logs

 

3. How We Use Your Information

We use collected information for the following purposes:

3.1 Service Delivery

• Providing AML compliance services and tools

• Conducting customer due diligence and enhanced due diligence

• Performing transaction monitoring and analysis

• Generating compliance reports and documentation

• Facilitating regulatory reporting requirements

3.2 Account Management

• Creating and managing user accounts

• Authenticating user identity

• Providing customer support and technical assistance

• Processing billing and payments

3.3 Legal and Regulatory Compliance

• Meeting AML regulatory requirements

• Complying with court orders, subpoenas, and legal processes

• Reporting suspicious activities to appropriate authorities

• Maintaining records as required by law

3.4 Business Operations

• Improving our services and developing new features

• Conducting internal research and analytics

• Ensuring system security and preventing fraud

• Training staff and quality assurance

 

4. Information Sharing and Disclosure

4.1 We may share your information with:

Regulatory Authorities:

• Financial Intelligence Units (FIUs)

• Banking regulators and supervisory authorities

• Law enforcement agencies when required by law

• Other government agencies as mandated by AML regulations

Service Providers:

• Technology and infrastructure providers

• Identity verification and screening services

• Data storage and security providers

• Payment processors (for billing purposes)

4.2 We do not sell, rent, or lease personal information to third parties for marketing purposes.

 

5. Data Security

We implement comprehensive security measures including:

• Access Controls: Role-based access restrictions and multi-factor authentication

• Network Security: Firewalls, intrusion detection, and secure network architecture

• Regular Audits: Security assessments and penetration testing

• Staff Training: Regular security awareness and compliance training

• Incident Response: Procedures for addressing security breaches

 

6. Data Retention

We retain personal information for as long as necessary to:

• Fulfill the purposes outlined in this policy

• Meet legal and regulatory requirements

• Resolve disputes and enforce agreements

Specific retention periods:

• Account information: Duration of account plus 5 years after closure

• AML compliance records: As required by applicable regulations (typically 5-10 years)

• Transaction monitoring data: As mandated by regulatory authorities

• Audit logs: Minimum 5 years from creation date

 

7. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

7.1 Access and Portability

• Request access to your personal information

• Obtain copies of your data in a portable format

7.2 Correction and Updates

• Correct inaccurate or incomplete information

• Update your account and profile information

7.3 Deletion Rights

• Request deletion of personal information (subject to legal retention requirements)

• Close your account and associated data

7.4 Processing Restrictions

• Object to certain types of data processing

• Restrict processing in specific circumstances

7.5 Communications

• Opt-out of non-essential communications

• Manage email preferences and notifications

Important Note: Some rights may be limited by AML regulatory requirements and legal obligations to maintain records and report suspicious activities.

 

8. International Data Transfers

If you are located outside our primary operating jurisdiction, please note that:

• Your information may be transferred to and processed in other countries

• We ensure appropriate safeguards are in place for international transfers

• We comply with applicable data protection laws regarding cross-border transfers

 

9. Children's Privacy

Our services are not designed for or directed to children under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will delete such information promptly.

 

10. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• Changes in our services or business practices

• Updates to legal or regulatory requirements

• Improvements in data protection measures

We will notify users of material changes through:

• Email notifications to registered users

• Prominent notices on our website

• In-app notifications for service users

 

11. Third-Party Links and Services

Our website may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to such external sites or services. We encourage you to review the privacy policies of any third-party services you access.

 

12. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain user sessions and preferences

• Analyze website usage and performance

• Provide personalized experiences

• Ensure security and prevent fraud

You can manage cookie preferences through your browser settings, though some functionality may be limited if cookies are disabled.

 

13. Regulatory Compliance Framework

This Privacy Policy is designed to comply with:

EU Privacy Laws:

• General Data Protection Regulation (GDPR) 2016/679

• ePrivacy Directive 2002/58/EC and national implementing laws

• Law Enforcement Directive (LED) 2016/680 where applicable

EU AML and Financial Regulations:

• 4th Anti-Money Laundering Directive (2015/849)

• 5th Anti-Money Laundering Directive (2018/843)

• 6th Anti-Money Laundering Directive (2018/1673)

• Payment Services Directive 2 (PSD2)

• Markets in Financial Instruments Directive II (MiFID II) where applicable

National Implementations:

• Local data protection and AML laws in EU Member States

• National Financial Intelligence Unit requirements

• Sector-specific regulations for real estate and financial services

 

14. Contact Information

For questions, concerns, or requests related to this Privacy Policy or our data practices, please contact:

Data Protection Officer @ Cross Borders, 1 rue de Turi, L-3378 Livange, Grand Duchy of Luxembourg, Email info@aml4you.eu

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