Data Privacy Statement

2.1 Our Core Commitment

Supreme AI exists to help accounting firms, legal practitioners, conveyancers, real estate professionals, trust and company service providers, and precious metals and stones dealers meet their obligations as reporting entities under the AML/CTF Act 2006 (Cth). In doing so, we handle some of the most sensitive information that a business can possess: the identity documents, beneficial ownership data, and financial transaction records of your clients. We take that responsibility seriously.

Our approach to data privacy rests on five principles derived from the Australian Privacy Principles:

  1. Transparency: we tell you what we collect and why, before we collect it.
  2. Purpose limitation: we use data only for the purposes for which it was collected, or compatible purposes you would reasonably expect.
  3. Data minimisation: we collect only what is reasonably necessary, consistent with the proportionality standard in APP 3.
  4. Security: we protect data with controls commensurate with its sensitivity and the risk of harm from unauthorised access.
  5. Accountability: we designate a Privacy Officer, conduct privacy impact assessments for high-risk features, and maintain records of our data handling activities.

2.2 Customer Data and the AML/CTF Act

When you use Supreme AI to comply with your AML/CTF obligations, the personal information of your clients (‘Customer Data’) that you input or upload is held by us as a data processor on your behalf. You remain the data controller (the ‘reporting entity’ under the AML/CTF Act) and the primary APP entity responsible for that data. Our processing is governed by the written agreement between us.

Consistent with the AML/CTF Act and the AML/CTF Rules Instrument (No. 1) 2007 (Cth), Customer Data on the Platform includes:

  1. Know Your Customer (‘KYC’) information collected for initial customer due diligence under the Act
  2. Beneficial ownership records identifying individuals who own or control 25% or more of a company or trust
  3. Source of funds and source of wealth documentation for enhanced customer due diligence
  4. Ongoing transaction monitoring data and risk-rating records
  5. SMR, TTR, and IFTI drafts and lodgement records

2.3 What We Will Never Do with Your Data

  1. Sell personal information or Customer Data to any third party
  2. Use Customer Data to train external AI models
  3. Use personal information for marketing without your express opt-in consent
  4. Share SMR drafts, TTR drafts, or IFTI data with any party other than you, unless compelled by lawful process
  5. Disclose the existence of an SMR to any party other than AUSTRAC and authorised law enforcement, consistent with the tipping-off prohibition in section 123 of the AML/CTF Act

2.4 AI-Powered Features and Privacy

Supreme AI uses artificial intelligence and large language model technology to power compliance assistance features including the AI chatbot, risk-scoring engine, and document analysis tools. All AI processing occurs within Australian-hosted infrastructure. Conversations and document inputs are not shared with external AI providers for training purposes. AI outputs are guidance only and do not constitute legal advice.