Platform Privacy Policy

1. Introduction

Benamic (“we”, “our”, “us”), a company registered in Ireland with company number [Insert Company Number], trading as [Trading Name], is committed to protecting the privacy and confidentiality of the data we collect and process.This Privacy Policy explains how we collect, use, store, and disclose corporate and personal data, including data collected during onboarding for Anti-Money Laundering (AML) compliance, in accordance with:

The General Data Protection Regulation (EU) 2016/679 (“GDPR”)
The Data Protection Act 2018 (Ireland)
The Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010–2021

2. Information We Collect

2.1 Corporate Data

We collect and process data relating to companies and other legal entities, including:

Company name
Registered and/or trading address
Company registration number
Contact details for authorised representatives
Nature of business (where relevant)

2.2 Personal Data of Corporate Employees and Representatives

To process transactions and fulfil our services (including issuing employee vouchers and prepaid cards), we may collect and store personal information relating to employees or authorised representatives of our corporate clients, such as:

Full name
Corporate or personal email address
Role or job title
Value and details of any transactions linked to the individual (e.g., voucher issuance or card value)
Contact phone number (where applicable)

This information is collected:

To fulfil service requests related to employee vouchers or prepaid cards
To maintain accurate transaction records
To comply with contractual and legal obligations

2.3 Personal Data Collected for AML/Onboarding Purposes

To comply with applicable AML legislation, we may also collect personal information as part of our onboarding and due diligence processes. This may include data related to:

Company directors, beneficial owners, and authorised signatories

This data may include:

Full legal name
Date of birth
Residential address
Copy of valid photo ID (e.g., passport or national ID card)
Proof of address
Nationality and country of residence
Occupation
Source of funds or wealth (where necessary)

This data is collected and processed strictly to meet our legal obligations under AML regulations and will not be used for marketing or unrelated purposes.

3. Legal Basis for Processing

We process your data under the following legal bases:

Legal obligation - for AML compliance and statutory recordkeeping
Performance of a contract - to deliver services such as employee voucher fulfilment
Legitimate interests - for communication, internal administration, and fraud prevention, provided such interests are not overridden by individual rights
Consent - only where explicitly required (e.g., for optional communications)

4. How We Use the Data

We use your data for the following purposes:

To onboard new clients and perform due diligence (KYC/AML checks)
To fulfil client requests, including processing and delivering employee vouchers or prepaid cards
To manage business relationships and communicate with authorised individuals
To maintain accurate transaction records
To comply with legal, tax, and regulatory obligations
To prevent fraud and financial crime
To respond to lawful data requests from competent authorities

5. Google reCAPTCHA

Our website uses Google reCAPTCHA to protect against spam and abuse by distinguishing between human users and bots. This service collects data such as IP address, browser information, and user behaviour to make this distinction, using cookies to track interactions.

This data is processed by Google in line with their Privacy Policy and Terms of Service. You can manage your preferences for cookies, including those used by reCAPTCHA, through your browser settings or by reviewing our Cookie Policy. Please note that disabling cookies related to reCAPTCHA may impact your ability to use certain features of our website, such as submitting forms.

6. Data Sharing and Transfers

We do not sell or rent data. We may share data with third parties only where necessary and appropriate, such as:

AML verification service providers
IT and cloud service providers
Payment processors or financial institutions
Legal and regulatory bodies (e.g., the Revenue Commissioners, the Central Bank of Ireland)
Law enforcement authorities (where legally required)

If personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are in place (such as EU-approved Standard Contractual Clauses).

7. Data Retention

We retain data only for as long as necessary to:

Fulfil the purposes outlined in this policy
Meet AML and tax retention obligations (typically 5 years following the end of the client relationship)
Defend against legal claims

After the retention period expires, data is securely deleted or anonymised.

8. Data Security

We apply appropriate technical and organisational measures to protect your data, including:

Encrypted data storage and communications
Access controls and internal data governance policies
Regular review of data protection practices
Employee training on confidentiality and compliance

9. Your Rights and Choices

You may:

Request access to the personal data we hold about you
Request correction or deletion of your personal data
Withdraw your consent (if applicable)

To exercise any of these rights, contact us at: dpo@clunetech.com.
Please note: Some rights may be limited if we are required to retain data for AML or legal compliance purposes.

10. Cookies and Tracking Technologies

Our website may use cookies and similar technologies to:

Enable core site functionality
Improve user experience (e.g., saving form progress)
Gather anonymized usage statistics for performance optimization

Cookies are small text files stored on your device. You may control or delete cookies through your browser settings at any time.
By using our website, you consent to the placement of essential cookies unless you disable them in your browser. For more detailed information, please refer to our [Cookie Policy].

11. Contact Us

If you have questions or concerns about how we process your data, or wish to exercise your rights, please contact:
‍
Email: dpo@clunetech.com

Address: WorkBloom, IDA Business & Technology Park, Ring Road, Kilkenny, Ireland

This privacy policy was reviewed in August 2025.