subprocessors data sharing · Privacy Policy
CollectWise policy finding
“ b. Controller and Beneficial Owner Information : due to the customer due diligence rule requirements under the Bank Secrecy Act, when corporate entities open business Verified Customer Record (“VCR”) accounts, we need to collect controller and beneficial owner information of that end user, which will be passed to certain API providers. A controller is a natural person who holds significant responsibilities to control, manage or direct a company or other corporate entity (e.g. CEO, CFO, General Partner, President, etc). A company may have more than one controller, but only one controller’s information must be collected. A beneficial owner is a natural person who — directly or indirectly — owns 25 percent or more of a company. If there are no natural persons who own 25 percent or more of a company, then no information needs to be collected. A beneficial owner cannot be another company (or other corporate entity), nor a nominee owner. We also need to collect a certification from the person creating the business VCR account in order to verify that the information is accurate.”
- Document
- Privacy Policy
- Captured
- 2026-07-20
- Location
- § 2 (Collection of User Data)
- Snapshot SHA-256
- 541f5080bae0cc4666b43f056d57d1475d330c29e6097009cdc8a8518c33e644
Informational only, not legal advice. Terms change; verify the source and capture date.