Acceptable Use Policy

1. Why this policy exists

Altego is a platform shared by many regulated businesses, and it holds some of the most sensitive data those businesses have. What one customer does on the platform can affect the security and the data of others.

This policy forms part of our Terms and Conditions. If you breach it, we may suspend or close your account. Where a breach is serious we may do so immediately and without prior notice.

2. Who this applies to

• Businesses and account holders who subscribe to Altego;
• staff, contractors and anyone else who accesses the platform under a business account;
• anyone who visits altego.com.au.

As an account holder you are responsible for making sure everyone who accesses the platform through your account follows this policy.

3. AML/CTF specific rules

These rules exist because of what Altego is for. They are the ones most likely to be a breach of law as well as a breach of this policy.

You must not:

• use Altego to evade, frustrate or conceal an obligation under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), or to help any other party do so;
• tip off. The AML/CTF Act restricts disclosure of information about a suspicious matter, including the fact that a report has been formed, prepared or lodged. You must not use Altego, or information taken from it, to disclose that to a customer or to any other person who is not entitled to it, and you must set your user permissions so that only those entitled to see it can;
• alter, backdate, delete or fabricate a record, a decision, a reason or an audit entry, or attempt to do so, in order to misrepresent what happened or when;
• enter data about a person or a business that you are not authorised to hold;
• configure a rule, a threshold or a screening setting for the purpose of suppressing alerts you would otherwise be required to consider, rather than for a genuine risk-based reason;
• represent to any person, including a regulator, that Altego performs a function it does not perform, that a check was made that was not made, or that use of Altego discharges an obligation that it does not.

4. What you must not do generally

4.1 Illegal activity. You must not use Altego to facilitate, assist or conceal any criminal offence under Australian or international law; to process or record activity involving fraud or money laundering other than for the purpose of your own compliance obligations; to handle personal information in breach of the Privacy Act 1988 (Cth); or to engage in any activity that would expose Altren Group to liability.

4.2 Harmful or offensive content. You must not upload, store, transmit or display content that is defamatory, threatening, harassing or designed to intimidate; that is obscene or otherwise offensive; that incites violence, hatred or discrimination; that exploits or endangers children; or that infringes anyone's intellectual property rights.

4.3 Security and system integrity. You must not attempt to gain unauthorised access to any part of the platform, our servers, or any connected system; probe, scan or test the security of the platform without our express written permission; introduce malware or any other malicious code; attempt to overload, disrupt or degrade the platform; or intercept, monitor or modify data in transit that is not your own.

4.4 Reaching another business's data. The platform separates businesses at the data layer. You must not access or attempt to access another business's account or data, by any means, including by exploiting a defect. Attempting it is a serious breach of this policy whether or not it succeeds, and we will treat it as such.

4.5 Unauthorised access and misuse. You must not share your credentials with anyone outside your authorised team; allow more than one individual to use a single user position; use the platform to provide services to third parties, such as running it as a service bureau for other reporting entities, without our written permission; or resell, sublicense or transfer your account or subscription without our written consent.

4.6 Reverse engineering and copying. You must not reverse engineer, decompile, disassemble or attempt to derive the source code of the platform; copy or create derivative works of it or of its rule libraries, templates or typologies; frame or embed the platform in another site or application without our written permission; or use automated tools, bots or scrapers to extract data other than through our authorised API.

4.7 Spam. You must not use the platform to send unsolicited commercial electronic messages in breach of the Spam Act 2003 (Cth), to send bulk messages without a valid unsubscribe mechanism, or to impersonate any person or business.

5. Responsible use

Beyond the specific rules above, we expect you to use Altego honestly and with respect for the other businesses on the platform. That means keeping your account information accurate and current; using the platform consistently with its purpose; not exploiting a defect or error for your own advantage; and reporting any security vulnerability you discover to us promptly at security@altego.com.au rather than exploiting it.

6. Data and privacy

When you use Altego to hold personal information about your customers, your staff or others, you remain responsible for your own obligations under Australian privacy law and under the AML/CTF Act. That includes having a lawful basis for collecting and using the information, collecting only what is reasonably necessary, keeping it secure, and responding to access and correction requests from the individuals concerned, subject to the retention and disclosure restrictions the AML/CTF Act imposes.

Altego provides the tools. You remain the responsible party for how you use them. Our Privacy Policy at altego.com.au/privacy explains how we handle your data.

7. What happens if you breach this policy

Depending on the seriousness of the breach we may issue a warning and ask you to stop; temporarily suspend your access; permanently close your account; remove or restrict content; or report the activity to relevant authorities, including AUSTRAC and law enforcement, where we are required or permitted to do so.

For serious breaches, particularly those involving illegal activity, an attempt to reach another business's data, tipping off, falsifying a record, or a security threat, we may suspend or close your account immediately and without prior notice.

Closing your account for a breach does not release you from any amounts you owe us, and it does not relieve you of any obligation you owe under the AML/CTF Act. You remain responsible for monitoring, record keeping and reporting, by other means if necessary.

8. Reporting a breach or a vulnerability

If you become aware of activity on the platform that appears to breach this policy, or you discover a security vulnerability, report it to security@altego.com.au for a security issue, or hello@altego.com.au for anything else, with the subject line "Policy Breach" or "Security Issue". We acknowledge a security report within 24 hours.

We take every report seriously and will investigate promptly. We appreciate responsible disclosure and will not pursue anyone who reports a genuine issue in good faith.

9. Changes to this policy

We may update this policy from time to time. When we make a material change we will notify you by email and post the updated policy at altego.com.au/acceptable-use. If you continue to use the platform after the updated policy takes effect, you are taken to have accepted the change.

10. Questions

• Email: hello@altego.com.au
• Security: security@altego.com.au
• Privacy: altegoprivacy@altego.com.au
• Phone: 1300 556 527, during Business Hours
• Website: altego.com.au

Altren Group Pty Ltd · ABN 32 700 087 332 · Melbourne, Victoria, Australia