Privacy Policy
Last updated 13 May 2025
KttiPay Pty Ltd (ACN 657 958 195) of PO Box 4, Northbridge, NSW 1560 (“we”, “us” or “our”) and its operation of the KttiPay mobile application (together referred to as the “Platform”) is committed to respecting your privacy and upholding your rights under the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (“Privacy Laws”).
This Privacy Policy sets out how we collect, use, process, store and disclose your Personal Information.
By accessing and using our Platform, products and services, you freely and expressly consent to the collection, use, processing, storage and disclosure of Personal Information by us as set out in this Privacy Policy.
1. Your Information
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. This may include information such as your name, address, date of birth, and contact details including email address and mobile phone number.
We require you to provide accurate, up to date and complete Personal Information at the time it is collected so we can provide services and products to you.
We will not request sensitive information from you. We ask that you do not send or disclose to us, any sensitive information (such as information related to racial or ethnic origin, religion or other beliefs, health, criminal background or trade union membership) on or through the Platform or otherwise. If you do provide any sensitive personal information you consent to us collecting and handling that information in accordance with this Privacy Policy.
2. Why we collect your information
The Personal Information we request from you will be reasonably necessary for one or more of our functions or activities. This includes to verify your identity, communicate with you, and provide you with services and products on our Platform. We may also collect your Personal Information to improve the services we provide to you.
3. How we collect your information
We will collect Personal Information only by lawful and fair means and not in an unreasonably intrusive way. We collect Personal Information from you when you apply for KttiPay products, enter a draw, communicate with us, visit our Platform, provide us with feedback, complete online surveys or participate in competitions.Generally, we will collect Personal Information directly from you.
We may collect Personal Information about you that you have provided to our business partners or from third parties and in respect of which you have given the third-party permission to share with us.
If you log into the Platform using your social network account (including Apple ID, Facebook or Google) we will receive information that is necessary for us to authenticate your access. The social network will provide us with access to certain information that you have provided to it, including your name, profile image and email address, in accordance with the social network service provider’s privacy policy. We use such information, together with any other information you directly provide to us when registering or using our products or services, to create your account and to communicate with you about the information, products and services that you request from us.
4. How we use your information
We use your Personal Information for the purposes for which the information is collected, that is providing you with our products and services, or for a directly related purpose, including (but not limited to):
- Providing our Platform, products and services to you;
- Allowing you or other registered users to request, spend or send money via our Platform;
- Conducting Draws;
- Disclosing Personal Information to the retailer or card issuer of any product displayed on our Platform (“Retailer”) to, process payments and enable them to provide and deliver products or services to you;
- Administering, protecting, improving or optimising our Platform, products and services (including performing data analytics, conducting research and for advertising and marketing purposes);
- Creating industry reports from de-identified data;
- Verifying your age;
- Billing you for purchasing or using our products or services;
- Money recovery efforts where fraud or error has occurred;
- Taking steps to recover amounts owed to us (including via insurance claims) and to allow us to pursue available remedies or limit damages that we may sustain;
- Informing you about our Platform, Draws, products, services, rewards, surveys, contests, or other promotional activities or events sponsored or managed by us, the Retailers or our business partners;
- Responding to any inquiries or comments that you submit to us;
- Verifying your identity;
- Any other purpose you have consented to; and
- Any use which is required or authorised by a relevant Privacy Law.
5. Disclosure of your personal information
We may disclose your Personal Information to:
- third parties we ordinarily engage from time to time to perform functions on our behalf for the purpose of providing the products or services offered through our Platform;
- any person or entity to whom you have expressly consented to us disclosing your Personal Information to;
- our external business advisors, auditors, lawyers, insurers and financiers;
- our payment processing or banking service providers;
- other users of KttiPay; and,
- any person or entity to whom we are required or authorised to disclose your Personal Information to in accordance with the relevant Privacy Laws.
When entering into a transaction with us you consent to your Personal Information being disclosed or transferred to such Recipients. We will take reasonably necessary steps to ensure your Personal Information is treated securely and in accordance with this Privacy Policy. We use reasonable endeavours to ensure that each Recipient receiving your Personal Information is bound by the relevant Privacy Laws.
5.1 Verifying your identity to provide you with products and services
We are required to verify your identity in specific circumstances, for example, when you apply for a financial product or service.
We may disclose your identity documents to the Document Verification Service (DVS) where you have provided them for the purposes of verifying your identity. The Document Verification Process checks via a secure communications pathway whether the identification information you have provided matches the original record.
5.2 Disclosing personal information outside Australia
We may disclose Personal Information outside of Australia to our service providers who provide risk assessment and transaction monitoring (Politically Exposed Persons and sanctions checking) who are based in the United Kingdom and the United States of America. These providers include ComplyAdvantage and Twilio. We will take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the APPs.
6. Storing and securing your personal information
We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. We use a number of physical, administrative, personnel and technical measures to protect your Personal Information. All Personal Information held or stored by us in our database is fully encrypted. This means that the personal information is scrambled in such a way that only the parties who have the key to unscramble it can access it. Even with these measures, we cannot guarantee the security of any Personal Information transmitted over the internet and therefore you disclose your Personal Information to us at your own risk.
7. Destroying or deidentifying your personal information
If we no longer need your Personal Information for any of the purposes set out in this Privacy Policy, or as otherwise required by law, we will take such steps as are reasonable in the circumstances to destroy or de-identify your Personal Information.
8. Correction of your personal information
We are required to take reasonable steps to correct Personal Information to ensure that, having regard to the purpose for which it is held, it is accurate, up-to-date, complete, relevant and not misleading. We may correct your Personal Information if we are satisfied the personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading, having regard to a purpose for which it is held, or you have requested a correction. If you ask, we must take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or authorises or requires us not to.
You may be required to provide us with proof the information we hold about you is either inaccurate, out-of-date, incomplete, irrelevant or misleading. To seek correction of your personal information, either update your information via our Platform or send an email to [email protected] outlining the details of your request.
9. Access to your personal information
You may request access to the Personal Information we hold about you. To seek access to your personal information, send an email to [email protected] outlining the details of your request.
If you ask, we must give you access to your personal information, unless there is a law that allows or authorises or requires us not to.
10. Direct marketing
Direct marketing involves the use of your Personal Information, for example your email address, to communicate directly with you to promote goods and services. We may use your collected information for the purposes of direct marketing, such as sending you information about products and services we believe are suited to you and your interests or we may invite you to attend special events.
At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, updating your settings via the app, or by contacting us in writing at [email protected].
11. Complaints
Where you would like to complain to us about our handling of your personal information, please detail your complaint in writing and send it to the Privacy Officer at [email protected].
We will acknowledge receipt of your complaint within two (2) business days and respond within 30 business days. If you are not happy with our response, you may complain to the Australian Financial Complaints Authority (AFCA) or the Office of the Australian Information Commissioner (OAIC).
To complain to AFCA:
Website: www.afca.org.au
Telephone: 1800 931 678 (free call)
Email: [email protected]
In writing to: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001
To complain to OAIC:
Website: https://www.oaic.gov.au/
Telephone: 1300 363 992
In writing to: Office of the Australian Information Commissioner, GPO Box 5288, Sydney NSW 2001
