KYC & AML Terms

AML & KYC TERMS & LEGAL BASIS - PROCESSING OF PERSONAL DATA

At ACOM Aviation Ltd ("We"), we uphold a zero-tolerance approach to money laundering and terrorism financing, prioritising the highest standards of openness, integrity, and accountability. We are dedicated to conducting business solely with reputable counterparties whose funds originate from legitimate sources and are not subject to any imposed sanctions.

The processing of Personal Data for Onboarding and Due Diligence Procedures is founded on two legal bases under the General Data Protection Regulation (GDPR):

  1. Legal Obligation (Article 6(1)(c) of the GDPR): We process Personal Data to monitor and implement international and/or national sanctions, ensuring compliance with our legal obligations. This includes monitoring and reporting any suspicious activities that may arise during the onboarding and due diligence process.

  2. Legitimate Interest (Article 6(1)(f) of the GDPR): Personal Data is processed to fulfill requirements for preventing money laundering, financing terrorism, corruption, bribery, and fraud. This allows us to establish ourselves as a legitimate, reliable, and reputable business to both our counterparties and relevant authorities. We conduct necessary due diligence to safeguard our operations and protect against potential risks associated with financial crimes.

For Individual Counterparties:

  • Name, surname, date of birth, nationality, occupation.

  • Valid ID/passport number.

  • Politically Exposed Person (PEP) status.

  • Residential and registered address details.

  • Phone number and email address.

  • Relationship with a third party (if applicable).

  • Source of funds/wealth (if cash payment).

  • Signature.

 We take a risk-based approach to AML, and at our discretion, an individual may be required to fill out an enhanced customer due diligence form to gather additional information.

For Legal Entity Counterparties:

  • Authorised person (name, surname, title, signature).

  • Ultimate beneficial owner (name, surname, address, occupation, date of birth, nationality, PEP status).

  • Shareholder (name, surname, address, date of birth, nationality, PEP status).

  • Controlling person (name, surname, address, country of residence, date of birth, nationality, PEP status, role/position).

  • Member of the board of directors (name, surname, PEP status).

  • Authorised representative (name, surname, address, country of residence, date of birth, email, phone, role/position).

Personal Data Collected from Copies of Documents:

  • Identity Card or Passport.

  • Official documents from authorities verify identity and place of residence.

  • Documentation proving the source of funds/wealth: To ascertain funds' legitimacy.

  • Articles of Association authorising the representative of a legal entity.

  • Certificate of Incorporation or its equivalent.

  • Certificate of Directors or copy of CEO (or other principal management body) appointment document.

HOW LONG WILL WE RETAIN YOUR PERSONAL DATA?

We will retain your personal data collected during the Onboarding and Due Diligence procedure for no more than 6 years, or as required by applicable laws or regulations, or for defence in a judicial process, to avoid storing outdated or unnecessary data.

TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

We may share your personal data with:

  • IT/electronic security service processors.

  • Professional advisors, auditors, lawyers, financial and accounting advisers.

  • Law enforcement authorities.

  • Banks or other financial service providers.

WHAT DATA SUBJECT’S RIGHTS DO WE GUARANTEE TO YOU?

You have the right:

  • To be informed about the processing of your personal data.

  • To access your personal data processed by us.

  • To request corrections to inaccurate or incomplete personal data.

  • To request the destruction of personal data when no longer necessary.

  • To request the deletion of personal data processed unlawfully.

  • To object to the processing of personal data.

  • To request the transfer of your personal data to another data controller, if technically possible.

For more details on how we process personal data and your privacy rights, please refer to our Privacy Policy (https://app.termly.io/document/privacy-policy/05de2178-1959-490d-8962-a225fc7bf127)

If you have any questions regarding the Onboarding and Due Diligence Procedure, please contact support@aero.bid