Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, and phone and facsimile numbers.
This Personal Information is obtained in many ways including correspondence, by telephone and facsimile, by email, via our website, from media and publications, from other publicly available sources, and from third parties. We don’t guarantee website links or policy of authorized third parties. We collect your Personal Information for the primary purposes of enabling you to use the STECH Coin Platform. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Sensitive information includes information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information. Sensitive information will be used by us (if at all) only:
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Your Personal Information may be disclosed in a number of circumstances including the following:
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification, or disclosure. When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 5 years.
You may access the Personal Information we hold about you to update or correct it, subject to certain exceptions. If you wish to access you’re Personal Information, please contact us in writing. We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information. In order to protect your Personal Information, we may require identification from you before releasing the requested information.
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete, and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
The Company protects itself from involvement in money laundering or suspicious activity by the following:
Prior to launch of the STECH Coin Platform, the KYC & AMC Policies will be written and approved by the Company’s owners. Once approved, the policies will be provided to all employees. Each employee will acknowledge the Policy in writing. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.
The Company has developed and implemented internal controls to ensure that all of its operations comply with all AML legal requirements and that all required reports are made on a timely basis. Some of those internal controls are listed within this document and include, but are not limited to, the Customer Identification Program, the Suspicious Activity Reporting system, and the required reports on the Program’s effectiveness to the Company’s Owners.
All officers and employees of the Company are required to receive AML training at least annually. New employees will receive appropriate AML training within 30 days of their hire date. Training for all employees will include not only the legal elements of AML laws and regulations but will also cover job specific applications of these laws. Ongoing training will be provided and updated regularly to reflect current developments and changes to laws and regulations. Customer Identification. It is the Company’s policy to ensure that it has reasonably identified each customer who uses the STECH Coin Platform. Users may be identified using a variety of methods.
When a User opens an account to begin using the STECH Coin Platform, the Company will, as part of its account-opening process: (i) cross-check the names of users against compliance databases such as the OFAC Specially Designated Nationals list and other governmental watch lists; (ii) require users to provide proof of identification; and (iii) not permit any payment above 1,000 USD to be made with incomplete account-opening information.
Documents used in opening an account relationship must be verified prior to establishing the account. Verification of identity will require multi-factor authentication, layered security, and other controls to ensure a meaningful user identity confirmation process based on account size or other factors.
The Company will diligently monitor transactions for suspicious activity. Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. Internal controls will be implemented so that an ongoing monitoring system is in place to detect such activity as it occurs. When such suspicious activity is detected, the Company will determine whether a filing with any law enforcement authority is necessary. Suspicious activity can include more than just suspected money laundering attempts. Activity may be suspicious, and the Company may wish to make a filing with a law enforcement authority, even if no money is lost because of the transaction. The Company will initially make the decision of whether a transaction is potentially suspicious. Once the Company has finished the review of the transaction details, it will consult with the Company’s senior management to make the decision as to whether the transaction meets the definition of suspicious transaction or activity and whether any filings with law enforcement authorities should be filed. The Company will maintain a copy of the filing as well as all backup documentation. The fact that a filing has been made is confidential. No one, other than those involved in the investigation and reporting should be told of its existence. In no event should the parties involved in the suspicious activity be told of the filing. The Company may inform the Company’s Board of the filing and the underlying transaction.
Reasonable procedures for maintaining records of the information used to verify a person’s name, address, and other identifying information are required under this Policy. The following are required steps in the record keeping process:
The Company is responsible for directing the annual AML audit of the Company’s operations. The independent audit will be conducted by an independent third party with working knowledge of BSA requirements, or by Company personnel with working knowledge of BSA requirements. The Company will develop corrective action plans for all issues that are raised in the audit and will provide the audit report and all corrective action plans to the Company’s senior management for review. Reports of the corrective action will continue until all issues are resolved.