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Privacy Notice

Last updated: September 2026

This Privacy Notice explains how Flex AML collects, uses and protects personal information when you register for and use Flex AML Hub, including the Compliance Calculator and AML Courses.

Flex AML Hub is provided for business and professional use only.

1. Who we are

Flex AML provides AML consultancy, tools and training for virtual office, flexible workspace and trust or company service provider (TCSP) businesses.

For the purposes of UK data protection law, Flex AML is responsible for the personal information described in this notice where we determine how and why that information is used.

For privacy enquiries or requests, contact: [email protected]

2. Information we collect

When you create an account or use Flex AML Hub, we may collect:

  • your name;
  • email address;
  • organisation or company name, where provided;
  • account and login information;
  • course progress, answers and completion information;
  • information about your use of Flex AML Hub;
  • feedback, comments and suggestions you provide;
  • communications you send to us; and
  • technical, security and usage information necessary to operate, protect and improve the Hub.

Compliance Calculator information

The Compliance Calculator allows users to enter information about a customer or prospective customer to receive an AML sense-check.

Depending on what you enter, this may include information relating to companies, directors, beneficial owners, persons with significant control or other individuals connected with a customer.

You are responsible for ensuring that you have an appropriate lawful basis for entering personal information about another person into Flex AML Hub.

Please only enter information reasonably necessary to use the Calculator. Do not upload identity documents, passwords, payment information or unnecessary sensitive personal information unless a feature specifically requests it.

Calculator assessments may be stored to allow users to review previous assessments and to operate, maintain and improve the Calculator. Assessment data will be retained for no longer than reasonably necessary for these purposes and will be deleted or anonymised when it is no longer required, subject to any legal or security requirements that require longer retention.

3. How we use information

We may use personal information to:

  • create and manage Flex AML Hub accounts;
  • provide access to the free trial;
  • operate the Compliance Calculator and AML Courses;
  • record course progress and completion;
  • provide support and respond to enquiries;
  • operate, maintain and secure the Hub;
  • understand how the Hub is being used;
  • identify and correct problems;
  • review feedback;
  • develop and improve our tools, courses and functionality;
  • test new functionality; and
  • send important communications relating to an account or the service.

The free trial is also intended to help us understand how Flex AML Hub is used and improve the product ahead of wider launch. We do not sell personal information.

4. Our lawful bases

Depending on the circumstances, we may rely on:

  • Contract – where processing is necessary to provide an account or Flex AML Hub service requested by you.
  • Legitimate interests – where necessary for our legitimate interests in operating, securing, testing, analysing and improving Flex AML Hub and developing our services, provided those interests are not overridden by your rights and interests.
  • Consent – where you have specifically chosen to receive marketing or where we otherwise ask for consent.
  • Legal obligation – where processing is necessary for us to comply with a legal requirement.

5. Feedback and product development

If you provide feedback, comments or suggestions during the free trial, we may use them to develop and improve Flex AML Hub, including the Compliance Calculator, AML Courses and future Flex AML products.

Where practical, we will remove or separate identifying information when we no longer need to know who provided the feedback.

6. AI and automated technology

Flex AML Hub may use artificial intelligence, automated rules and other technology to support functionality and to help us develop, test and improve the service.

Where an external AI provider processes personal information on our behalf, we will take appropriate steps to ensure suitable data protection arrangements are in place. We do not sell personal information to AI providers.

The Compliance Calculator provides decision-support information. Flex AML does not use the Calculator to make legally binding or similarly significant automated decisions about the individuals whose information may be entered into it.

Your data is not used for any training purposes of AI models.

7. Who we share information with

We may use trusted service providers to develop, host and operate Flex AML Hub.

These include or may include:

  • DigitalOcean – hosting and infrastructure;
  • GitHub – software development and code management;
  • AI service providers – where used within or to support Flex AML Hub;
  • email and communications providers – to provide account communications and, where permitted, marketing communications; and
  • other technical providers reasonably necessary to operate and secure the service.

We may also disclose information where required by law or where necessary to establish, exercise or defend legal rights.

Where third parties process personal information on our behalf, we will use appropriate data protection arrangements.

8. International transfers

Some technology providers may process information outside the UK.

Where personal information is transferred internationally, we will take appropriate steps to ensure that the transfer is permitted under UK data protection law and that appropriate safeguards are in place where required.

You can contact [email protected] for further information about applicable safeguards.

9. Marketing and service communications

We may send communications necessary to provide and administer your Flex AML Hub account, such as account, security, access and important service updates.

These are separate from marketing communications.

Where you have opted in to marketing, we may send occasional emails about Flex AML products, new tools, AML Courses, events, product updates and early-access opportunities.

You can unsubscribe from marketing at any time using the unsubscribe option provided or by contacting [email protected].

Where you unsubscribe, we may retain limited information necessary to record your preference and ensure that you are not inadvertently added back to marketing communications.

10. How long we keep information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, taking into account the nature of the information, the purpose of processing, our legitimate business and security needs, and any applicable legal, tax, accounting or regulatory requirements.

Our retention periods may differ depending on the type of information:

Account and profile information is generally retained while your Flex AML Hub account remains active. If an account is closed, we will generally delete or anonymise personal information that we no longer need within a reasonable period, unless we have a legitimate reason or legal obligation to retain it.

Compliance Calculator assessments are retained only for as long as reasonably necessary to provide the Calculator functionality, allow users to access previous assessments where applicable, maintain security, resolve disputes, or meet applicable legal requirements.

Course progress and completion information may be retained while your account remains active and for a reasonable period afterwards where necessary to maintain completion records, provide support or meet legal or contractual requirements.

Marketing preferences and suppression records may be retained for as long as necessary to ensure that we respect your marketing preferences and do not send unwanted communications.

Technical, security and usage information may be retained for a limited period appropriate to the purpose for which it was collected, including security monitoring, troubleshooting and preventing misuse.

Information that we are required to retain for legal, tax, accounting, regulatory or legal-claims purposes may be retained for the period required for that purpose.

We regularly review whether personal information is still required. When it is no longer required, we will securely delete it or anonymise it so that it can no longer reasonably be used to identify an individual. Where personal information is held in backups, deletion may take place as part of the normal backup retention cycle.

Where this applies, deleted information will be placed beyond ordinary use and will not be restored or otherwise processed except where necessary for disaster recovery, security or legal purposes. If you request deletion of your personal information, we will assess the request and, where the right to erasure applies, take reasonable steps to delete the relevant information from our active systems and instruct relevant service providers to do the same where required.

11. Security

Access to personal information is limited to those who reasonably require it to operate, support or develop Flex AML Hub. To protect your personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use, we implement robust technical and organizational measures. These include:

  • Industry-standard SSL/TLS encryption for data in transit.
  • Advanced AES-256 encryption for data at rest, where supported by the relevant infrastructure or service.
  • Strict role-based access controls and Multi-Factor Authentication (MFA) for administrative access.
  • Regular vulnerability assessments and security reviews, where appropriate.
  • Access to personal data is limited to authorised persons and service providers who need it for the purposes described in this Privacy Notice.
  • Personal data is subject to retention and deletion procedures designed to prevent it being kept for longer than necessary.

Users are responsible for keeping their account credentials secure.

12. Storage Location:

Personal data collected through Flex AML Hub is stored using trusted hosting and technology providers in locations appropriate to the services they provide. Where data is stored or processed outside the UK, EU or EEA, we will ensure that appropriate safeguards are in place as required by applicable data protection law.

13. Your rights

Depending on the circumstances and the lawful basis involved, you may have rights to:

  • access personal information we hold about you;
  • correct inaccurate information;
  • request deletion of your information;
  • request restriction of processing;
  • object to certain processing;
  • receive certain information in a portable format; and
  • withdraw consent where processing is based on consent.

You also have the right to object to the use of your personal information for direct marketing at any time.

You also have the right to object to the use of your personal information for direct marketing at any time. These rights are not absolute and may depend on the circumstances.

To make a request, contact [email protected]. We may ask for information reasonably necessary to verify your identity before dealing with a request.

We will normally respond to a valid request without undue delay and within one calendar month, subject to any permitted extension or other applicable legal requirements. If we cannot comply with a request in whole or in part, we will explain the reason, where we are legally permitted to do so.

14. Cookies and similar technologies

Flex AML Hub may use cookies, local storage or similar technologies necessary to operate the service, maintain login sessions, remember settings and protect accounts.

If we introduce non-essential analytics, advertising or other tracking technologies that require consent, we will provide appropriate information and obtain consent where required.

15. Changes to this Privacy Notice

Flex AML Hub is an evolving product and this Privacy Notice may be updated as functionality, technology providers or our use of information changes.

The current version will be available through Flex AML Hub.

Where a change materially affects how we use personal information, we will take reasonable steps to bring it to users' attention.

16. Complaints

If you have concerns about how we use your personal information, please contact:

[email protected]