Our Services are not directed to persons under 18 years of age. AirPay does not knowingly collect Personal Information from minors. If we become aware that we have collected data from a minor without proper consent, we will promptly delete it.
WHO WE ARE
AirPay Financial Technologies Pty Ltd, Level 35, Tower One, 100 Barangaroo Avenue, Barangaroo NSW 2000
What We Collect
Name, contact details, ID documents, business registration, payment & transaction data, device & usage data
Why We Collect It
To provide Services, verify identity (KYC/AML/CTF), process payments, prevent fraud, comply with regulators
Who We Share With
Trusted service providers, financial partners, AUSTRAC, ASIC, ATO where required. We do NOT sell your data.
How Long We Keep It
At least 7 years for AML/CTF records (AML/CTF Act s105); otherwise for as long as reasonably necessary
Your Rights
Access, correction, complaint escalation to OAIC. Contact: admin@airpayfintech.com
Contents
Introduction
This Privacy Policy explains how AirPay Financial Technologies Pty Ltd (“AirPay”, “we”, “our”, or “us”) collects, uses, discloses, stores, and protects your Personal Information. It applies to all users of AirPay’s products, services, platforms, and technologies in Australia, including merchants, business representatives, end users, and visitors to our websites, mobile applications, and digital channels.
This Policy is issued under and complies with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Privacy (Credit Reporting) Code 2014, and the Notifiable Data Breaches (NDB) scheme. The AML/CTF Amendment Act 2024 (Cth) applies to the collection and handling of information for compliance purposes.
SECTION 1
Scope of This Policy
This Policy applies when you interact with AirPay as:
- a Merchant — a business entity or sole trader who has registered with AirPay;
- a Representative — an individual acting on behalf of a Merchant;
- an End User — an individual making a payment to a Merchant via AirPay-supported payment methods; or
- a Visitor — an individual who visits our Sites or interacts with us without creating an account.
SECTION 2
Personal Information We Collect
2.1 Information You Provide Directly
- Identity and contact: full name, business name, address, email, phone number
- Identification documents: driver’s licence, passport, ABN, ACN, company registration details
- Financial information: bank account details, merchant settlement account information, transaction details, and beneficiary information
- Business information: directors, partners, UBOs, ANZSIC codes, trust deed details
- Voluntary information: survey responses, feedback, support enquiries, and promotional participation
2.2 Information Collected Automatically
- Device and browser information: IP address, operating system, device type, browser type
- Usage data: pages viewed, clicks, transaction timestamps
- Diagnostic and log data: access times, error reports
- General location data derived from your device or network for security and compliance purposes
2.3 Information from Third Parties
We may receive information from external sources, including acquiring banks, payment network partners, authorised resellers, financial institutions, regulatory authorities, and third-party service providers who assist with identity verification, due diligence, and fraud detection.
2.4 Identity Verification — Document Verification Service (DVS)
Where required by the AML/CTF Rules, AirPay uses the government-operated Document Verification Service (DVS) and other electronic identity verification systems to verify the authenticity of identification documents you provide.
- Where AirPay deploys facial recognition technology, such information is handled as sensitive information in accordance with Australian Privacy Principles 3, 6, 10, and 11 of the Privacy Act 1988 (Cth). AirPay will notify you of the specific verification method used at the time of collection.
2.5 Cookies and Similar Technologies
We use cookies and similar technologies to recognise users, prevent fraud, secure our systems, and enhance your experience. You may manage or disable cookies through your browser settings; however, doing so may affect some Service features.
SECTION 3
How We Use Your Personal Information
3.1 Provide and Manage Our Services
- Establish and manage your AirPay account
- Process transactions and manage settlements
- Verify your identity and authorise access
- Provide customer support and resolve service issues
3.2 Comply with Legal and Regulatory Obligations
- Conduct KYC and customer due diligence (CDD/EDD) under the AML/CTF Act
- File IFTI reports to AUSTRAC within 10 business days
- File SMRs within 24 hours for terrorism financing matters; within 3 business days for all other suspicious matters
- Maintain records for a minimum of 7 years under s105 of the AML/CTF Act
- Screen customers and transactions against the DFAT Consolidated Sanctions List and UN Security Council sanctions lists
- AirPay and its staff are prohibited under s123 of the AML/CTF Act from disclosing that an SMR has been, is being, or is to be submitted to AUSTRAC. This obligation cannot be overridden by any other provision.
3.3 Prevent Fraud and Ensure Security
- Detect, investigate, and prevent fraud, money laundering, terrorism financing, and other unlawful activity
- Monitor transactions for suspicious patterns
- Conduct random compliance testing
3.4 Marketing (with Consent)
We may send promotional materials and event invitations where you have expressly consented under the Spam Act 2003 (Cth). You may unsubscribe at any time. Opting out of marketing will not affect receipt of essential service notifications.
SECTION 4
Disclosure of Personal Information
AirPay only shares Personal Information where necessary to deliver our Services, comply with legal obligations, or protect our legitimate interests. We do not sell, rent, or trade your Personal Information for marketing purposes.
We may disclose your Personal Information to:
- Service providers and partners: trusted third-party service providers who assist in delivering our Services (payment processing, cloud hosting, fraud prevention, identity verification, data storage, and customer support).
- Regulatory and government authorities: including AUSTRAC, ASIC, the ATO, and the Australian Federal Police, where required by law, regulation, or court order.
- Payment networks: card schemes (Visa, Mastercard, UnionPay), alternative payment platforms (Alipay, WeChat Pay), and banking institutions involved in processing transactions.
- Corporate transactions: if AirPay undergoes a merger, acquisition, restructuring, or sale of assets, your information may be transferred as part of that transaction.
- With your consent: to third parties where you have expressly consented or made a specific request.
SECTION 5
International Data Transfers and Storage
AirPay stores and processes your Personal Information primarily in Australia. To support certain payment, settlement, or compliance functions, limited information may be securely transferred to trusted service providers or financial partners located in other jurisdictions, including Singapore or Hong Kong.
- AirPay will take reasonable steps to ensure that overseas recipients handle your information consistently with the Australian Privacy Principles, as required under APP 8.1 of the Privacy Act 1988 (Cth). AirPay complies with APP 8.1 (reasonable steps for overseas recipients) — not GDPR or other non-Australian frameworks.
SECTION 6
Data Retention
AirPay retains Personal Information only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to support legitimate business operations.
Under Australian law, including the AML/CTF Act 2006 (Cth) as amended by the AML/CTF Amendment Act 2024 (Cth), AirPay is required to retain certain transaction and identification records for a minimum of seven (7) years after the completion of a transaction or termination of a business relationship.
When the applicable retention period expires and information is no longer required, AirPay will securely destroy or de-identify it in accordance with APP 11.2.
SECTION 7
Your Rights and Choices
- Access (APP 12)
You may request access to the Personal Information we hold about you. AirPay will respond within 30 calendar days. A reasonable administrative fee may apply.
- Correction (APP 13)
If information we hold is inaccurate, incomplete, or out of date, you may request correction. If we disagree, we will provide a written explanation.
- Withdrawal of Consent
Where you have provided consent for specific processing (e.g. marketing), you may withdraw consent at any time by contacting us.
- Opt-Out of Marketing
You may opt out of marketing communications at any time by following the unsubscribe instructions in our messages or contacting admin@airpayfintech.com.
SECTION 8
Device, Marketing and Analytics
8.1 Device Permissions
When using our mobile applications, certain device permissions may be requested (for example, camera or location access). You may manage or revoke these through your device settings.
8.2 Service Notifications
AirPay may send administrative notifications (for example, security alerts, service updates, or payment confirmations) as necessary to operate our Services or meet legal obligations. These cannot be unsubscribed from as they are not marketing messages.
8.3 Marketing Communications
In accordance with the Spam Act 2003 (Cth), AirPay will only send marketing or promotional materials with your express consent. AirPay complies with the Do Not Call Register Act 2006 (Cth) in respect of any telephone-based marketing activities.
8.4 Analytics
AirPay may use analytics tools and limited advertising technologies to understand how our Services are used and to improve functionality. AirPay does not use third-party tracking tools to deliver personalised advertising without your consent.
SECTION 9
Security
AirPay implements appropriate technical, organisational, and physical safeguards to protect your Personal Information, including:
- encryption of sensitive data in transit and at rest;
- role-based access control and multi-factor authentication;
- secure data centres with physical access controls;
- continuous monitoring for suspicious activity; and
- staff training on privacy and data security obligations.
- AirPay will notify affected individuals and the OAIC of an eligible data breach as required under Part IIIC of the Privacy Act 1988 (Cth) (Notifiable Data Breaches scheme).
SECTION 10
Credit Reporting
To the extent AirPay handles credit information, it does so in accordance with Part IIIA of the Privacy Act 1988 (Cth) and the Privacy (Credit Reporting) Code 2014. Credit information collected and used by AirPay includes information about credit applications, credit history, and default information provided by credit reporting bodies.
SECTION 11
Third-Party Links and Services
Our websites and applications may contain links to, or integrations with, third-party services. AirPay does not control and is not responsible for the privacy practices of these third-party services. We encourage you to review the privacy policies of any third-party service you access.
SECTION 12
Updates to This Policy
AirPay reserves the right to update this Policy at any time by posting a revised version on our website. For material changes that reduce your privacy protections or impose new obligations, AirPay will provide at least thirty (30) days’ advance notice by email or prominent notice on our website. For minor or administrative changes, the revised Policy will take effect upon posting.
Your continued use of our Services after the notice period constitutes acceptance of any updates. Previous versions of this Policy are available on request.
SECTION 13
Contact Information
AirPay Financial Technologies Pty Ltd
company
AirPay Financial Technologies Pty Ltd
Phone
+61280467682
ADDRESS
Level 35, Tower One, 100 Barangaroo Avenue, Barangaroo NSW 2000
Website
www.airpayfintech.com/privacy-policy/
AirPay will acknowledge your complaint within five (5) Business Days and resolve it within thirty (30) calendar days. If you are not satisfied with our response, you may escalate your complaint to:
AirPay Financial Technologies Pty Ltd
SECTION 14
Australia-Specific Terms
This Policy applies to all users and merchants of AirPay in Australia. AirPay complies with Australian privacy law. AirPay does not apply GDPR or other non-Australian data protection frameworks to its Australian operations, except where required by law.
14.1 Language
This Policy is prepared in English. Any translation is for convenience only; the English version prevails.
14.2 Children's Privacy
Innovative Financial Solutions Empowering the Digital Economy
AirPay Financial Technologies Pty Ltd maintains compliance with its obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and applicable New Zealand AML/CFT legislation.
Contact Info
- admin@airpayfintech.com
- +61 2 8046 7682
- Tower One, 100 Barangaroo Ave, Barangaroo NSW 2000
Useful Links
Financial License
AFSL 526194
AAN 100844285
FSP 557526
AUSTRAC IND100844285-001
NZBN 9429046088413
© 2026 AIRPAY FINANCIAL TECHNOLOGIES PTY LTD. ABN 99 615 157 572. All Rights Reserved.
Compliant with AML/CTF Regulations