1. Our role: controller or processor
Which obligations apply to us depends on whose data it is and why we hold it. There are two distinct situations, and confusing them is the commonest source of misunderstanding about a platform like ours.
| We are a processor | For personal data about your clients, prospective clients, counterparties and their beneficial owners, which you submit to or generate in the platform for your own AML purposes. You are the controller. You decide who is screened and why, on a legal-obligation basis under applicable AML law. We act on your documented instructions under our Data Processing Agreement. |
| We are a controller | For the screening datasets we compile (sanctions, politically exposed persons, adverse media), and for personal data about our website visitors, the individual users of our platform, our business contacts and job candidates. |
2. Who we are and how to reach us
JUSTE AI Ltd, a company registered in England and Wales under number 15983150, with its registered office at 71–75 Shelton Street, London WC2H 9JQ, United Kingdom.
- Data protection enquiries: dpo@juste.ai
- To exercise your rights: mypersonaldata@juste.ai
- General enquiries: hello@juste.ai
We are registered with the UK Information Commissioner's Office.
3. Client data processed for AML purposes
When a subscribing firm screens or onboards a client through JUSTE, we process personal data about that individual or entity on the firm's behalf. This typically includes identity details and identity document images, contact details, nationality and residence, the entity's structure and beneficial ownership where relevant, the results of screening against sanctions, politically exposed person and adverse media sources, the risk classification reached, the due-diligence questions and answers, and the record of who reviewed and approved the outcome.
The firm is the controller of this data and determines the lawful basis, which is ordinarily compliance with a legal obligation under applicable AML law. If you are a client of a firm that uses JUSTE and you want to exercise your rights or understand why you were screened, the firm is your first point of contact. We will assist them, and we will forward any request that reaches us directly.
Sanctions, adverse media and politically exposed person screening can involve personal data relating to criminal convictions, offences or alleged offences. We process it only for AML and counter-terrorist financing purposes, only to the extent necessary, and under the additional safeguards our and our customers' obligations require.
4. Our screening datasets
As controller, we compile and maintain the datasets against which screening runs. These are built from publicly available sources:
- Sanctions, warnings, fitness and probity. Information from publicly available government lists covering sanctions, the prevention and detection of unlawful acts, and other protective functions — typically a name, a year or date of birth, the reason for listing, and the period covered.
- Politically exposed persons. Publicly available information about individuals in prominent public positions, their family members, close associates and business interests: names, dates or years of birth, positions or connections giving rise to the designation, nationality, residence, and the period the designation was active.
- Adverse media. Links to publicly available news articles naming individuals in connection with financial crime, terrorist financing or other relevant conduct, together with any age information those articles contain.
We structure this into consolidated profiles. Our lawful basis is legitimate interests: our customers have a legitimate interest in accessing high-quality, well-structured data in order to meet their sanctions and AML obligations, and we have a legitimate interest in developing products that serve that need. We have assessed this against the rights of the individuals concerned, taking into account that the underlying information is already public and is used for a purpose the law requires of our customers.
Access is controlled. Customers search against profiles for their own AML purposes; we do not permit open-ended searching of our customers' own personal information by other customers.
5. Automated processing and AI
AI is central to how the platform works, so it deserves a clear statement rather than a footnote.
5.1 No solely automated decisions
The AI produces a recommended risk level for each risk type. The subscribing firm's own codified risk policy governs the final classification and overrides the AI where its rules require. A named, competent human is then presented with the recommendation, its reasoning and its provenance, and acts on it before anything has consequence for the client relationship. High-risk files are blocked by the system until an MLRO or nominated senior authority authenticates and acts.
No decision producing legal or similarly significant effects is taken solely by automated means.
5.2 What the AI is applied to
AI agents run screening and matching, analyse adverse media, recommend risk levels, generate due-diligence questions targeted at identified risk drivers, and assess the completeness of answers. Every material output records the model used, the agent, the prompt version and the policy version in force.
5.3 Known limitations affecting individuals
Name matching across jurisdictions, scripts and transliterations can produce false positives — an individual may be matched to a listing that is not them. The workflows are designed to surface and resolve this through verification and human review rather than to assume it away. If you believe you have been wrongly matched, contact the firm that screened you, or us at mypersonaldata@juste.ai.
Customer data and end-client data are never used to train, fine-tune or otherwise improve our models or those of our sub-processors, in any form. This is a contractual commitment rather than a configurable setting.
6. Website visitors
What we collect. How you use the site — pages visited, browser and device information, time zone, visit duration and frequency, and navigation paths — together with your IP address and identifiers tied to cookies.
Why. To analyse aggregated behaviour and improve the site's content, layout and relevance.
Basis. Legitimate interests in understanding and improving how we present our services, and consent where cookies require it. See our Cookie Policy.
Retention. Determined by cookie expiry periods.
Recipients. Our marketing personnel, and our analytics and marketing-automation providers.
7. Platform users
When your firm gives you access to JUSTE, we process your name, work contact details, role, department, reporting line, scope, permissions, authentication data, and records of your training, policy acknowledgements and the actions you take in the platform — including the decisions you approve, adjust or escalate.
That last part matters: the platform is an evidence system, so your actions are attributable to you by design. Your firm relies on this to demonstrate supervision, and a supervisor may examine it. We process it as processor on your firm's instructions; your firm is the controller and can tell you how long it retains these records.
8. Business contacts and sales
We process names, contact details and professional information about people at organisations that may need AML infrastructure, obtained from you directly, from correspondence, from events, or from publicly available professional sources. We use it to contact you about our services, to manage our sales relationship, and to understand and improve how we market.
Basis. Consent for marketing emails; taking steps at your request before entering a contract; and legitimate interests in identifying relevant stakeholders and improving our sales process.
Retention. Newsletter details until you unsubscribe, after which we keep a suppression record so we do not contact you again. Sales interaction records for up to five years after we conclude there is no fit. Records of consent or other bases for six years from the date the basis lapsed.
You can unsubscribe from any marketing email using the link it contains.
9. Job candidates
We process the information you provide when applying, publicly available information relevant to your suitability, any introduction made on your behalf, and feedback from interviews and assessments. We use it to consider your application, contact you about it, and assess suitability for future roles.
Basis. Legitimate interests in building our team, and compliance with a legal obligation where record-keeping is required in connection with visa sponsorship.
Retention. Twelve months after we conclude an application, or longer where immigration record-keeping requires it. Successful candidates' data becomes subject to our employee privacy notice.
10. International transfers
Processing takes place predominantly in the United Kingdom and the European Economic Area. Certain sub-processors, including some AI model providers, process data in the United States.
Where personal data leaves the UK or EEA we rely on appropriate safeguards, which may include adequacy decisions, the UK International Data Transfer Agreement or Addendum, and European Commission standard contractual clauses, supported by transfer risk assessments where required.
11. Sub-processors
We use third parties to deliver the platform: cloud hosting and storage, AI model providers, identity verification and data source providers, and business tools including our CRM, support and analytics systems. Each is bound by written terms, processes data only on our instructions, and is subject to the same prohibition on training models with the data.
Our current sub-processor list is published at juste.ai/security-and-trust. We give notice of material changes so customers can object.
12. Retention
- Client AML records. Retained for the period your firm's retention policy and applicable AML law require — commonly five to ten years from the end of the business relationship, depending on jurisdiction. Your firm sets this.
- Screening datasets. Politically exposed person data is retained indefinitely, because some jurisdictions we serve treat a PEP as a PEP permanently. Where we remove data — for example, when it ceases to be relevant — it persists in backups for up to 30 days.
- Everything else. As set out in the relevant section above.
13. Security
We apply technical and organisational measures appropriate to the sensitivity of the data, including access controls and role-based permissions, encryption in transit and at rest, audit logging of material actions, and supplier due diligence. Our security practices and current certifications are described at juste.ai/security-and-trust.
14. Your rights
Depending on your relationship with us, you may ask us to give you access to your personal data, correct it, erase it, restrict or object to our processing, provide it in a portable form, or withdraw consent where processing is based on consent.
Email mypersonaldata@juste.ai. Where we act as processor for a subscribing firm, we will forward your request to that firm as controller and assist them in responding.
If you are concerned about how we handle your personal data you can complain to the UK Information Commissioner's Office, or to the supervisory authority in your country. We would rather you raised it with us first, but that is your choice, not a condition.
15. Changes
We update this policy as our processing changes. Material changes will be notified, and each version carries a number and date. Superseded versions are available on request.
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