Who We Are
ClientCheck is an AML screening and due-diligence platform operated by Altieri Firm LLC, a UAE-licensed legal entity headquartered at the EDB Building, 7th Floor, Dubai, United Arab Emirates. References in this policy to "ClientCheck", "we", "us", or "our" mean Altieri Firm LLC acting in its capacity as the operator of the ClientCheck platform.
What Data We Collect
We collect two categories of data:
Account data — information you provide when you create an account or run a screening on behalf of your firm. This includes your full name, the firm or business you represent, your email address, and your phone number.
Screening subject data — information you provide about the individual or entity you are screening. This typically includes the subject's name, date of birth, nationality, identification document numbers, address, and (for corporate screenings) registration details and the names of beneficial owners.
How We Use It
We use the data you provide for one purpose only: to perform AML screening on your behalf. Screening subject data is transmitted in real time to our screening partners — ComplyAdvantage and Themis — via secure APIs in order to query international sanctions lists, PEP registries, watchlists, and adverse media databases. The results are returned to your account and stored as a permanent Screening Record in your audit log.
We do not use your data for advertising, profiling outside of AML screening, or any commercial purpose unrelated to the platform. Your data is never sold, rented, or licensed to third parties.
Data Processors
We rely on the following data processors to deliver the screening service. Each is named here so you can review their own privacy practices:
- ComplyAdvantage — sanctions, PEP, adverse media, and watchlist screening provider.
- Themis — enhanced due diligence and risk intelligence provider.
These processors act on our instructions and are bound by data processing agreements that restrict the use of your data to performing the screening service requested.
Data Retention
We retain Screening Records and the underlying data for seven (7) years from the date of screening. This retention period is mandated by the UAE Ministry of Economy under Federal Decree-Law No. 10 of 2025, which requires regulated businesses and the platforms they use to maintain a complete audit trail of customer due-diligence activity. Records are retained even if you cancel your subscription, in order to remain produceable for the regulator within the mandated period.
Your Rights Under UAE PDPL
Under Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL), you have the right to:
- Access the personal data we hold about you;
- Request correction of inaccurate or incomplete personal data;
- Request erasure of your personal data, subject to our legal obligation to retain Screening Records for the period set out above;
- Restrict or object to processing in defined circumstances;
- Request transfer of your personal data to another service in a structured, machine-readable format;
- Withdraw consent where processing is based on consent.
To exercise any of these rights, contact us at the address below. We will respond within the timeframes prescribed by the PDPL.
Contact
For privacy questions, data subject requests, or any concern relating to how your data is handled, contact us at hello@clientcheck.ae.