Privacy Collection Notice

Certain services that we provide are regulated under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and Anti-Money Laundering and Counter Terrorism Financing Rules 2025 (Cth) (AML/CTF Rules) (together, AML/CTF laws).

The AML/CTF laws are designed to prevent money laundering and terrorism financing by imposing obligations on ‘designated entities’ to detect, report and mitigate financial crime risks.

The AML/CTF laws may require RedeMont ABN 69 399 090 230 (RedeMont, us, we) to undertake due diligence on new and existing clients. This may necessitate the collection of additional information from you, including personal information regulated under the Privacy Act 1988 (Cth) (Privacy Act), to undertake that due diligence.

This notice sets out our obligations under the AML/CTF laws, and how client information will be collected, handled and disclosed in accordance with our obligations under the AML/CTF laws and the Privacy Act.

The AML/CTF laws require us to conduct initial and continuing customer due diligence checks on clients where we expect to provide certain transactional services or advice (Customer Due Diligence).

We are required to verify the identity of our clients and certain associated persons, and understand the money laundering, terrorism financing and proliferation financing risks associated with providing designated services to the client.

We collect your personal information to comply with the ‘Customer Due Diligence’ requirements in the AML/CTF Act. This includes to:

• establish and verify your identity before providing certain services to you or the person you are acting on behalf of;
• assess and manage potential money laundering, terrorism financing, proliferation financing risks or related compliance risks associated with the provision of our services;
• make reports required by law under the AML/CTF Act; and
• meet record keeping obligations under the AML/CTF Act.

We are required to collect certain information to conduct Customer Due Diligence, known as ‘Know Your Customer’ information (KYC information), which may include:

• your full name, date of birth, residential address; and
• individual identification documents such as your passport or driver’s licence number.

For clients that are not individuals, we may also collect the following information (although it may not be personal information for the purposes of the Privacy Act):

• company structure charts;
• business names;
• address of principal place of business and/or registered office;
• identification numbers such as ACN, ABN, and ARBN; and
• governing documents such as trust deeds, shareholder agreements, company constitutions or company registers.

We may also collect sensitive information from you if required, including whether you are a member of any political associations, professional or trade associations which may be used to verify your occupation or determine whether you are a politically exposed person.

Authorisation to collection information for Customer Due Diligence

We are authorised to collect information for Customer Due Diligence and AML/CTF purposes under section 28(3)(c) of the AML/CTF Act.

Where possible, we will collect information required for Customer Due Diligence from the client directly. We may also collect information about clients from publicly available sources or related parties where we are permitted to do so under the Privacy Act, including where it is impractical or unreasonable to collect from the client or relevant person directly.

We may collect your personal information from other sources such as from registers of companies, trusts, or public records (such as court records, regulatory filings, land registries), financial institutions or professional intermediaries.

We may engage third party service providers to assist us in complying with our obligations under the AML/CTF laws.

Legl

We currently engage the AML/CTF provider trading as Legl (The Justice Platform Ltd registered in England and Wales under number 09534141) to assist us with Customer Due Diligence. We may decide to change our AML provider, which might change the way in which your KYC information is handled, and the location in which it is stored and processed.

Legl may request and collect the types of information set out in this notice from you on our behalf, to assist us with complying with the AML/CTF laws. This may include sending you requests for information and undertaking verification of your identification.

Legl and its contractors and service providers will use the information it collects on our behalf to monitor and assess AML/CTF risk. We may use the information and analysis generated by Legl to form an opinion about whether a client presents an AML/CTF risk and to notify law enforcement bodies such as AUSTRAC.

For further information regarding Legl’s privacy obligations and practices, Legl’s privacy policy can be found on its website at https://legl.com/en-au/privacy-policy. Further information about how Legl engages and manages sub-processors can be found in its Sub-Processor Policy located on its website at https://legl.com/sub-processors.

We may engage identity verification partners to conduct an online ID verification. Legl engages Equifax Limited, a company registered in England under Registered No. 2425920 (Equifax) and credit reporting body, as a sub-processor to undertake online identification verification services.

Legl will disclose your personal information to Equifax so that Equifax can verify your identity and provide the results of any verification of identity to us. We are authorised to disclose personal information to Equifax for the purpose of verifying an individual’s identity under section 35A of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

For further information about how we collect, use and disclose personal information for online ID verification purposes, please see our Online ID Verification Privacy Collection Notice available on our website and on request.

Further information about how Equifax uses personal information for online ID verification can be found in the CRA Information Notice located on Equifax’s website at https://www.equifax.co.uk/privacy-hub/crain.

If you do not provide us with the information we request or otherwise we do not have the information we require to conduct Customer Due Diligence, we may not be able to verify your identity and complete the required AML/CTF checks, and may not be able to provide you (or the person you are acting on behalf of) with the services you have requested.

We may disclose your KYC information and other personal information required for AML/CTF compliance to our third-party service providers who process and manage our AML/CTF program (or part of our AML/CTF program) on our behalf. For example, we routinely disclose personal information to Legl to assist us in complying with our AML/CTF obligations, and to Equifax to assist with identity verification.

Some of our AML/CTF service providers are located overseas and may store and process your personal information overseas. We disclose Know Your Customer information (and other types of personal information) to our service providers located in New Zealand, England and Wales.

We may also disclose your AML/CTF information to government and law enforcement agencies, including to AUSTRAC, to meet our legal and regulatory obligations under the AML/CTF Act or the AML/CTF Rules. For example, we are required to report certain transactions of $10,000 or more or which involve cross-border movement of funds.

We are required to keep records under the AML/CTF laws about certain transactions and our identity verification procedures. We are generally required to keep such records for at least seven years, although we may hold those records for longer in certain circumstances.

Our Privacy Statement contains further information about how we will handle your personal information and how you can access and correct your personal information. It also outlines how to lodge a complaint and how that complaint will be managed if you are concerned about how we handled your information.

Our Privacy Statement can be found on our website at https://redemont.com/privacy-statement/ or you can request a physical copy from us via our contact details below.

If you have queries about how we collect, use or disclose your personal information, or if you would like to make a privacy complaint, please refer to our privacy statement on our website at https://redemont.com/privacy-statement/.

You have rights to seek access to, and correction of, the personal information that we hold about you. Further information can be found in our privacy statement.

If you would like further information about the way we manage your personal information, or if you have a privacy-related complaint or request, please contact us at the following details:

Phone	61 7 5553 9400
Email	info@redemont.com
Post	PO Box 11, Varsity Lakes QLD 4227

We will endeavour to respond to all requests within a reasonable time.

More information about your rights and our obligations in connection with your personal information are available from the Office of the Australian Information Commissioner at www.oaic.gov.au.