Personal Information is the information or opinion that gives an individual its own identification. The attributes included in the personal information are Name, Email Address, Address, Contact Numbers and Date of Birth.
This information is collected in multiple ways that may include phone or facsimile, via email through our web portal, media and publications, from other available sources that are public and various third parties too. However, we don’t guarantee website links or policy of authorized third parties. The primary purpose of collecting the personal information is to make your experience of Street Hawk Coin platform better. The secondary reason of using your personal information is closely associated with the primary reason. Moreover, in any circumstance, where appropriate and possible, we will elaborate you the reason of collecting the information and how we are planning to use it.
Whenever the situation is reasonable and practical, we will collect your personal information only from you. However, in some situations, we may be provided with the information by the third parties. In such situation, we would make you aware in prior about any information provided to us by any third party.
Your personal information may be disclosed in a number of circumstances that may include:
Your personal information is stored in a way that reasonably protects it from misuse and loss and from any unauthorized access, modification or disclosure. When the need of your personal information comes to a halt, a reasonable action will be taken from our end to either destroy it or permanently de-identify your information. However, in some cases the personal information is or will be stored in a client file whose life period is 5 years.
You have the access of the personal information provided by you to update it or correct it, subject to certain exceptions. If you want the access to your information, you may contact us anytime. We are not going to charge you anything but may charge an administration fee for providing a copy of your personal information. In order to make your personal information safe, we may require some kind of identification proof from your end.
It is important for us that your personal information stays up to date. We will take reasonable steps to make sure that your personal information is updated, accurate and complete. If you find that information is not upto date or inaccurate, please suggest us as soon as possible so that we can update our records and ensure we can continue to provide quality services to you.
The company protects itself from any involvement in money laundering or any suspicious activity by the following:
Prior to the launch of Street Hawk Coin, the AMC and KYC policies will be written and approved by the owner of the company. Once approved, the policies will be given to all the employees. Each employee will acknowledge the policy in writing. All procedures and policies will be reviewed and updated as per the requirements.
The organization has developed and implemented internal controls to ensure that all its functionalities complies with all the AML requirements and that all reports are required in a particular time frame. Some of these controls are listed within the document and include but not limited to the Customer Identification Program, the Suspicious Activity Reporting system, and the required reports on the effective of the function to the owner of the company
All the officers and employees of the company are required to get trained in AML at least once in a year. The newly joined employees will receive appropriate AML training within a month’s span of their hire date. The training for the person will not only include the legal aspects of the AML laws and regulations but also cover the job oriented applications of these regulations. Running trainings will be provided regularly to reflect the current developments and upgradations and amendments in laws and regulations.
it is the policy of the company to ensure that it has accurately identified each user who uses Street Hawk Coin platform. The identification of the users can be done in various ways.
When a user opens his account to begin using the Street Hawk Coin Platform, the organization will, as part of its account opening process:
Documents used in opening an account relationship must be verified in prior to the establishment of the account. Verification of identity will need multi factor authentication, multi-layer security and other features to get a meaningful user identity confirmation process based on the activities performed in the account.
The organization will keep a close eye on each of the transaction and will check out any of the suspected activity. Transactions that are unusual will be carefully reviewed to see if it makes any apparent sense or is meant with any kind of fraud. Internal protocols will be implemented so that an in-process monitoring system can be laid to detect any suspicious activity as soon as it takes place. If such activities are traced, the organization will decide if filling of any law enforcement is required or not. Suspicious activity may include fraud money laundering activities. Activity may be suspicious and the organization may take a strict action by complaining a case even if no loss of money has taken place. However, the organization will initially decide if any suspicious activity has occurred or not. Once the review of the transaction process has been done, the team people will raise the issue with the senior management and then the verdict will be delivered if the transaction meets the criteria of the suspected transaction or not and does it require any legal action or not. The organization will keep a copy of the filling as well as all the documents for the backup. Once the filling is made confidential, no other member other than the investigation team will ever be informed about such occurrence. The company may inform the company’s board of filling and the underlying transaction.
Reasonable procedures for maintaining records of the information used to verify the name of the person, address and other identifying information are required for this policy. The following are the steps in the record keeping process
The organization is responsible for directing the annual AML auditing of the company’s operations. The independent audit will be conducted by an independent third party with the working knowledge of BSA requirements. The company will develop corrective action plans for all the 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 the final review. Reports of the corrective action will continue until all issues are resolved.