Terms and Conditions

These Terms and Conditions (the “Terms”) constitute a legally binding agreement between you (the “User”, “Customer”, or “you”) and Vaz Capital Pvt Ltd as trustee for the Vaz Capital Trust (ABN 28 247 067 155), trading as FreeAML (the “Operator”, “we”, “us”, or “our”), being the platform operator behind the product known as FreeAML and the website freeaml.com.au (together with related applications, dashboards, APIs, documentation, and communications, the “Platform”).

The Operator is Vaz Capital Pvt Ltd, acting as trustee for the Vaz Capital Trust (ABN 28 247 067 155), trading as FreeAML. Notices may be sent to team@freeaml.com.au. Nothing in these Terms represents that the Operator is an AUSTRAC-licensed, AUSTRAC-approved, or AUSTRAC-endorsed person, or that the Operator acts as a reporting entity on the User’s behalf.

By accessing, browsing, creating an account, sending or completing a verification, initiating a payment, clicking to accept, or otherwise using the Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms and by our Privacy Policy. If you do not agree, you must not use the Platform.

If you use the Platform on behalf of a business, partnership, company, trust, or other organisation, you represent and warrant that you have authority to bind that organisation, and “you” includes that organisation and its personnel.

In these Terms, unless the context otherwise requires:

• “ACL” means the Australian Consumer Law in Schedule 2 to the Competition and Consumer Act 2010 (Cth).
• “AML/CTF Laws” means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the AML/CTF Rules, related regulations, AUSTRAC guidance, and any other applicable Australian or foreign anti-money laundering, sanctions, counter-terrorism financing, or know-your-customer laws.
• “AUSTRAC” means the Australian Transaction Reports and Analysis Centre, and includes any successor regulator.
• “Client” means an individual or entity in respect of whom a User initiates, or who themselves completes, a verification or related workflow on the Platform.
• “Fees” means amounts payable for use of the Platform, including per-check charges, service charges (mark-ups), and any applicable taxes.
• “Outputs” means reports, statuses, templates, program drafts, risk assessments, training records, messages, and other materials generated or displayed by the Platform.
• “Personr” means the independent identity-verification provider used by the Platform to perform identity, biometric, document, entity, and related checks, and includes its affiliates, subprocessors, and successor providers.
• “Stripe” means Stripe, Inc., Stripe Payments Australia Pty Ltd, and related Stripe entities used to process payments and, where enabled, Stripe Connect transfers.
• “Third-Party Services” means services of independent providers used to operate the Platform, including without limitation Stripe, Personr, email and SMS providers, hosting (Vercel), analytics (PostHog), and database hosting (Supabase).
• “Tranche 2” means the reforms extending AML/CTF obligations to additional Australian sectors (including, without limitation, certain real estate, professional services, and high-value goods businesses), as applicable from time to time.

The Platform is a software-as-a-service product. It provides tools, workflows, and related services that use first-party systems and Third-Party Services to help Users manage aspects of customer due diligence, identity verification, entity verification, beneficial-ownership capture, record-keeping aids, templates, training modules, and similar operational tasks that may be relevant to AML/CTF programmes, including those oriented to AUSTRAC Tranche 2.

The Platform does not itself: (a) enrol you with AUSTRAC; (b) file suspicious matter reports, threshold transaction reports, or other regulatory reports on your behalf unless a specific feature expressly states otherwise and is actually used by you; (c) act as your AML/CTF compliance officer, governing body, or independent reviewer; (d) supervise your designated services; or (e) determine that any particular person, transaction, or business is “compliant”.

Outputs are generated from information you, your Clients, and Third-Party Services supply. They are tools to assist your own processes. You remain solely responsible for reviewing Outputs, exercising professional judgement, applying your AML/CTF programme, and deciding whether additional steps are required.

All information, templates, checklists, risk-assessment questionnaires, programme generators, training content, blog material, and Outputs are provided for general informational and operational-assistance purposes only. They do not constitute legal advice, accounting advice, regulatory advice, or a legal opinion. No solicitor-client, fiduciary, or similar relationship is created by use of the Platform.

The Operator makes no representation or warranty that use of the Platform constitutes, in whole or in part, compliance with AML/CTF Laws, AUSTRAC expectations, professional-body rules, or any other legal obligation. Mere use of the Platform is not an AUSTRAC-approved, AUSTRAC-certified, or AUSTRAC-endorsed solution. The Operator does not claim any AUSTRAC licence, registration, or endorsement by reason of these Terms or the availability of the Platform.

You should obtain independent legal and compliance advice appropriate to your circumstances, designated services, risk profile, and industry.

YOU, AND NOT THE OPERATOR, BEAR FULL RESPONSIBILITY for ensuring that customer identification, customer due diligence (including enhanced due diligence where required), beneficial-ownership identification, ongoing monitoring, record-keeping, reporting, training, governance, risk assessment, and all other AML/CTF measures meet AUSTRAC expectations and applicable AML/CTF Laws for your business.

Without limiting the foregoing, you are solely responsible for:

• determining whether you are a reporting entity, the designated services you provide, and your enrolment, registration, and programme obligations;
• deciding when a check is required, which check type is appropriate, whether a result is adequate, and whether to proceed, pause, or refuse a customer or matter;
• verifying that identity, entity, and ownership information, including information returned by Personr or displayed in Outputs, is sufficient for your legal obligations;
• retaining records for the periods required by law, independently of any retention practised by the Platform;
• making any reports to AUSTRAC or other authorities that you are obliged to make; and
• the acts and omissions of your personnel, contractors, and Clients in connection with the Platform.

A “complete”, “approved”, “clear”, “verified”, or similar status on the Platform is an operational outcome of the relevant workflow and Third-Party Service. It is not a determination that you have complied with AML/CTF Laws, nor a substitute for your own assessment.

To the maximum extent permitted by law, the Operator bears no responsibility to AUSTRAC (or any equivalent regulator, law enforcement agency, or professional body) for the User’s compliance, non-compliance, or purported compliance with AML/CTF Laws. The Operator does not undertake to AUSTRAC, to your customers, or to any third party that your use of the Platform will satisfy your statutory or regulatory duties.

You acknowledge that regulators may take action against reporting entities regardless of software used, and that the Operator is not your agent for regulatory purposes merely because you use the Platform. If any authority contacts the Operator about your use of the Platform, the Operator may, where permitted or required by law, cooperate and disclose relevant information, without assuming any compliance obligation on your behalf.

You must be capable of forming a binding contract under Australian law. The Platform is directed at Australian businesses and professional users. You must provide accurate contact and billing information and keep it current.

Some features may be used without creating a standing account (for example, sending a verification link). Other features (including service-charge payouts, dashboards, team access, or payout settings) may require authentication, including one-time passcodes or session credentials. The Operator may refuse, limit, or discontinue access at its discretion, including where we reasonably suspect fraud, abuse, or legal risk.

You must not impersonate another person, misstate your relationship to a Client, or use the Platform to verify persons without a legitimate business purpose consistent with AML/CTF Laws and privacy law.

You are responsible for maintaining the confidentiality of logins, one-time codes, session tokens, verification links, short codes, and devices used to access the Platform. You must notify us promptly at team@freeaml.com.au if you suspect unauthorised access.

Verification links and similar URLs may allow a holder to commence or continue a Client workflow. You must transmit them only to the intended recipient and by reasonably secure means. The Operator is not liable for loss arising from your sharing, forwarding, or inadequate protection of links or credentials, to the maximum extent permitted by law.

You are responsible for all activity occurring under your accounts, contact details, and organisation profiles, whether or not authorised by you, except to the extent caused by the Operator’s fraud or wilful misconduct.

You must not, and must not permit others to:

• use the Platform in breach of AML/CTF Laws, privacy laws, sanctions, consumer law, or any other applicable law;
• use the Platform to facilitate money laundering, terrorism financing, fraud, identity theft, or evasion of lawful due diligence;
• attempt to reverse engineer, scrape at scale, overload, probe, or circumvent security or usage limits, except as permitted by non-excludable law;
• upload malware, or interfere with other users or Third-Party Services;
• submit information you know is false or misleading in connection with a verification or payment;
• resell Platform access except as expressly permitted (including any documented client-pays or mark-up features);
• use Outputs to claim that the Operator or AUSTRAC has certified a person or transaction; or
• use the Platform if you are a competitor solely to benchmark or copy features, except with prior written consent.

The Operator may investigate suspected misuse and may suspend access, withhold Outputs, or involve payment providers or authorities where reasonably necessary.

Identity document capture, biometric / liveness / selfie checks, government-database matching, watchlist screening, and related identity-proofing steps are performed by Personr (or a successor provider) under Personr’s terms, privacy notices, and technical processes. The Operator does not operate those capture interfaces as a government Document Verification Service, and does not warrant Personr’s accuracy, availability, coverage, or legal sufficiency for your programme.

When you or a Client proceeds with a verification, you instruct the Operator to arrange the relevant Personr workflow and to receive back such status, outcomes, reference identifiers, and related result metadata as are reasonably required to operate the Platform (including generating reports and updating order state). Responsibility for the collection and processing of identity documents and biometric identifiers for the verification itself resides with Personr, subject to Personr’s terms. You must ensure you have a lawful basis and any required notices or consents before sending a Client to verification.

Personr (and other Third-Party Services) may approve, reject, expire, or fail a check for reasons outside the Operator’s control, including poor image quality, unsupported documents, name mismatches, watchlist hits, or provider outages. You must not treat a declined or failed check as a determination by the Operator of criminality, and you must apply your own procedures for unsuccessful CDD.

The Platform depends on first-party systems and Third-Party Services, including without limitation:

• Stripe — payment processing, invoices/receipts as Stripe provides, and Stripe Connect where Pro mark-up payouts are enabled;
• Personr — identity, entity, and related verification;
• email and SMS providers (including transactional email and telephony providers used from time to time) — notices, one-time codes, and verification links;
• Vercel — application hosting and related edge/infrastructure;
• PostHog — product analytics, including (where enabled) event capture, session replay, and autocapture; and
• Supabase — database and related backend hosting.

Third-Party Services are provided by independent controllers or processors under their own terms. The Operator does not warrant their uninterrupted availability, security certifications, or fitness for your regulatory programme, and does not adopt any certification, insurance, or licence that a provider may hold as the Operator’s own unless expressly stated in writing. Your use of a provider’s hosted flow (for example, Stripe Checkout or Personr’s verification interface) is also subject to that provider’s terms.

To the maximum extent permitted by law, the Operator is not liable for delays, errors, data handling, or outages of Third-Party Services, or for fees those providers charge you directly.

Fees are as displayed on the Platform at the time of purchase or as otherwise agreed, typically on a per-check basis and, where you elect Pro features, a recurring subscription. Indicative public pricing (which may change) has included amounts such as individual verification, entity verification, beneficial-owner checks, and a Pro subscription with optional client-facing mark-up. Amounts may be stated as including GST where the Operator is registered or required to charge GST.

Where client-pays is selected, the Client (or other paying party) is charged through Stripe for the applicable amount, which may include your mark-up. Where Stripe Connect is used, mark-up may be transferred to your connected account subject to Stripe’s processes, reserves, and fees. You are responsible for your tax treatment of mark-up and for completing any Stripe Connect onboarding truthfully.

Payment obligations are processed by Stripe. The Operator does not store full card numbers. You authorise the Operator and Stripe to charge the selected payment method for Fees, taxes, and retries as permitted by Stripe.

Except where the ACL or other non-excludable law requires otherwise, Fees are non-refundable once a verification or paid feature has been initiated, including where a Client does not complete a check, a check is declined, expired, or unsuccessful, or you are dissatisfied with a regulatory outcome. Subscriptions may be cancelled to stop future renewals in accordance with the cancellation controls then available; amounts already billed are not generally prorated unless required by law or expressly offered.

The Operator may change Fees by updating the pricing pages or in-product amounts. Changes apply to future purchases. Continued use after a change constitutes acceptance of the new Fees for subsequent transactions.

Credits and the referral program

FreeAML credits are prepaid balances denominated in Australian dollars. One account can unlock $15 of credits once, by inviting a single valid work email. We check that the address belongs to a person (not a shared role inbox), can receive mail, and is not a personal, disposable, or same-organisation address.

After that unlock, you can send more invitations with your share link or the invite box. Those further invitations do not add more unlock credits.

If a new person creates a FreeAML account using your link — the last referral link they opened before signing up — you earn $15 of credits when they complete their first verification paid by card. That includes I’ll pay (the reporter’s card) and Client pays (the client’s card), whether or not a mark-up is added. There is one referrer per friend. A link used after they already have an account does nothing, and if they signed up with no referral link there is no referral credit.

You do not earn that referral credit if your friend’s first verification is paid with FreeAML credits. A later card payment does not make up for it. The referral credit is minted once per friend. It is not capped across different friends.

Same-organisation addresses, your own address, and other ineligible emails are blocked and do not qualify. Referral credits have no cash value except as a balance toward FreeAML verification fees, and we may refuse or reverse a credit that was obtained in breach of these Terms.

The Platform may store order metadata, contact details, payment status, mark-up amounts, verification statuses, reference identifiers, questionnaire answers, organisation settings, and result payloads returned by Personr and other providers, as reasonably required to operate, support, and improve the service and to generate Outputs.

The Operator does not warrant that Platform storage will satisfy your statutory record-keeping period or format requirements. You must export, download, and independently retain all records you are legally required to keep. The Operator may delete, anonymise, or archive data in accordance with its operational practices, the Privacy Policy, and legal obligations, including after account inactivity or termination.

The Operator and its licensors own all right, title, and interest in the Platform, including software, branding, layout, documentation, and templates, excluding Third-Party Services and excluding identity documents and personal information that remain subject to applicable privacy and identity-provider terms.

Subject to these Terms and timely payment of Fees, the Operator grants you a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform for your internal business purposes in Australia. You must not copy, modify, or create derivative works of the Platform except as the ordinary use of Outputs for your compliance files contemplates.

You grant the Operator a worldwide, non-exclusive licence to host, process, and display content you submit solely to provide, secure, and improve the Platform, to generate Outputs, and as described in the Privacy Policy.

Each party must keep confidential the other party’s non-public business information obtained in connection with the Platform, except information that is public (other than by breach), independently developed, or required to be disclosed by law, court order, or a regulator (including AUSTRAC). The Operator may disclose information to Third-Party Services and professional advisers under comparable confidentiality obligations, and as set out in the Privacy Policy.

To the maximum extent permitted by law, the Platform and Outputs are provided on an “as is” and “as available” basis. The Operator excludes all warranties, representations, and guarantees that are not expressly set out in these Terms and that may be excluded, including implied warranties of merchantability, fitness for a particular purpose, non-infringement, accuracy, and uninterrupted or error-free operation.

Without limiting the foregoing, the Operator does not warrant that: (a) the Platform will meet AUSTRAC or other regulatory requirements applicable to you; (b) verification results are complete, current, or free from false positives or false negatives; (c) watchlist or registry data is exhaustive; or (d) the Platform will be available at any particular time.

To the maximum extent permitted by law, the Operator is not liable to you or any third party for any indirect, incidental, special, consequential, exemplary, or punitive loss; lost profits, revenue, goodwill, or data; business interruption; regulatory fines or penalties imposed on you; costs of alternative compliance arrangements; or loss arising from your customers, counterparties, or regulators — whether in contract, tort (including negligence), statute, or otherwise, even if advised of the possibility.

To the maximum extent permitted by law, the Operator’s aggregate liability arising out of or in connection with the Platform or these Terms is limited to the greater of: (a) the Fees you paid to the Operator for the specific paid check or subscription period giving rise to the claim; and (b) AUD 100.

Nothing in these Terms limits liability for fraud, fraudulent misrepresentation, or any liability that cannot be limited under applicable law (including, where applicable, the ACL as addressed below).

If you are a consumer or otherwise entitled to the protections of the ACL, the Operator’s goods and services come with guarantees that cannot be excluded. Where the Operator’s liability for a failure to comply with a consumer guarantee can be limited under the ACL (including section 64A in relation to services that are not of a kind ordinarily acquired for personal, domestic, or household use), the Operator’s liability is limited, at the Operator’s option, to the resupply of the services or the payment of the cost of having the services supplied again.

These Terms are to be read subject to the ACL and any other non-excludable rights. If there is inconsistency, those rights prevail to the extent of the inconsistency.

You indemnify and hold harmless the Operator and its officers, employees, and contractors from and against all claims, losses, damages, costs (including reasonable legal costs), and liabilities arising out of or in connection with: (a) your use of the Platform; (b) your breach of these Terms; (c) your failure to comply with AML/CTF Laws, privacy laws, or AUSTRAC expectations; (d) information you or your Clients submit; (e) disputes between you and a Client, paying party, or regulator; and (f) your mark-up, marketing, or representations about the Platform, except to the extent caused by the Operator’s fraud or wilful misconduct.

The Operator may suspend, restrict, or terminate access immediately if: Fees are unpaid; we reasonably suspect breach, fraud, or unlawful activity; a Third-Party Service requires it; we are required by law; or continuation would present an unacceptable legal, security, or reputational risk.

You may stop using the Platform at any time and, where a subscription exists, cancel in accordance with the then-available cancellation method. Termination does not affect accrued payment obligations or clauses that by nature should survive (including intellectual property, disclaimers, limitations, indemnity, confidentiality, and governing law).

Upon termination the Operator may disable access. You remain responsible for exporting records you require. The Operator has no obligation to retain data after termination except as required by law or as described in the Privacy Policy.

The Operator may amend these Terms from time to time by publishing an updated version on freeaml.com.au. The “Current as at” date will be revised. Material changes may also be notified via email or in-product notice where reasonably practicable.

Continued use of the Platform after the effective date of updated Terms constitutes acceptance. If you do not agree, you must cease use. No variation by you is effective unless agreed in writing by the Operator.

The Operator is not liable for delay or failure to perform caused by events beyond its reasonable control, including failures of Third-Party Services, internet or power outages, industrial action, epidemic, governmental action, or natural disaster.

The Operator may give notices by email to the address associated with your use of the Platform, by SMS where you have provided a mobile number, by in-product message, or by posting on the website. You may give notices to the Operator at team@freeaml.com.au. Notices are deemed received on sending (if not bounced) or on posting, as applicable.

These Terms are governed by the laws of the State of Victoria, Australia. The parties submit to the exclusive jurisdiction of the courts of Victoria, Australia, and courts of appeal from them, except that the Operator may seek injunctive or urgent relief in any jurisdiction.

Before commencing proceedings (other than for urgent relief), each party must attempt in good faith to resolve the dispute by written notice and a reasonable period of negotiation.

These Terms, together with the Privacy Policy and any in-product order confirmation, constitute the entire agreement regarding the Platform and supersede prior representations about it. If a provision is invalid, it is to be read down or severed and the remainder continues. A failure to enforce a right is not a waiver. You may not assign these Terms without the Operator’s prior written consent; the Operator may assign to an affiliate or successor. Nothing in these Terms creates a partnership, joint venture, or employment relationship. Electronic acceptance is valid. Headings are for convenience only.

In the event of conflict between these Terms and marketing copy on the website (including statements that reports are “AUSTRAC-compliant”), these Terms prevail. Marketing language is descriptive of intended functionality and does not vary the allocation of compliance responsibility set out herein.

Questions about these Terms may be sent to team@freeaml.com.au. Please include “Terms and Conditions” in the subject line.

Vaz Capital Pvt Ltd as trustee for the Vaz Capital Trust (ABN 28 247 067 155), trading as FreeAML · FreeAML (freeaml.com.au) · Current as at 24 September 2026 (Melbourne, Australia)