Refundly Pty Ltd (ABN 63 687 378 749) ("Refundly", "we", "our", "us") is committed to protecting your privacy and managing your personal information in an open and transparent way in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs"). This Privacy Policy outlines how we collect, hold, use, disclose, and protect your personal information.

A copy of the APPs is available from the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au

1. What is Personal Information?

"Personal Information" means information or an opinion that identifies or reasonably identifies an individual. Examples include:

• Full name

• Date of birth

• Contact details (address, email, phone number)

• Gender and age (or age range)

• Employment and occupancy history

• Identity verification documents (e.g., driver's licence, passport)

• Financial information (e.g., bank account details for refund transfers)

We may also collect technical data such as IP addresses, device/browser information, and usage data from cookies on our website.

We do not generally collect sensitive information (e.g., racial or ethnic origin, political opinions, health or criminal records). If we do, we will only collect it with your consent or where permitted or required by law.

2. Why Do We Collect Personal Information?

Refundly collects personal information for the following purposes:

• To verify your identity and entitlement to unclaimed money

• To prepare and lodge claims with government agencies and financial institutions

• To communicate with you throughout the claim process

• To provide customer support

• To comply with legal and regulatory obligations, including those under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)

• To send direct marketing communications, with your consent

• To improve our website and services

Where appropriate, we will notify you of the specific purpose at the time of collection.

3. How Do We Collect Personal Information?

We collect personal information directly from you when you:

• Submit a form on our website (e.g., "Free Search", Authority to Act)

• Communicate with us via phone, email, post, or social media

• Participate in an interview or verification process

We may also collect information:

• From government departments, public registers, or financial institutions

• From KYC providers or third-party verification services

• Via cookies and analytics tools on our website

• From third parties or publicly available sources

When we receive personal information indirectly, we take reasonable steps to notify you of the collection and the source.

4. Use and Disclosure of Personal Information

We use and disclose personal information solely for the purposes for which it was collected or as otherwise permitted under the APPs. This may include disclosure to:

• Government departments and agencies managing unclaimed monies

• Identity verification and compliance partners

• Financial institutions and registries

• IT service providers, cloud storage providers (based in Australia), and analytics services

• Real estate agencies or third parties for verification of address or identity

• Other third parties where you provide explicit consent

• Regulatory authorities where required by law (e.g., court orders, AUSTRAC)

We do not sell or rent your personal information to any third parties.

6. Direct Marketing

With your consent, we may use your personal information to send you updates, newsletters, or service-related offers. You may opt out at any time by clicking "unsubscribe" in our emails or contacting us directly.

7. Security of Personal Information

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. Security measures include:

• Secure servers and encrypted databases

• Access controls and authentication measures

• Staff privacy training and confidentiality agreements

We retain personal information for a minimum of 7 years where required by law or for record-keeping purposes. When no longer needed, we will securely destroy or de-identify the information.

8. Access and Correction

You have the right to:

• Request access to personal information we hold about you

• Request correction of inaccurate, incomplete, or outdated information

Requests can be made in writing to the contact details below. We may require proof of identity before responding. No charge applies for access requests, although we may charge a reasonable administrative fee for copies.

We aim to respond to access or correction requests within 30 calendar days.

9. Anonymity and Pseudonymity

Where lawful and practical, you may interact with us anonymously or using a pseudonym. However, in most cases, we will need to identify you to provide our services.

10. Cookies and Website Data

Our website uses cookies to enhance functionality and analyse user traffic. By using our site, you consent to our use of cookies. Third-party services (e.g., Google Analytics) may also collect data; their policies govern their use. We recommend reviewing those privacy policies separately. You may manage cookie preferences through your browser settings. We do not guarantee third-party privacy practices.

11. Data Breach Response

In the unlikely event of an eligible data breach, Refundly will notify affected individuals and report the breach to the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act.

12. Privacy Complaints and Contact Details

If you have a question, concern, or complaint about our handling of your personal information, please contact us:

Refundly Pty Ltd
PO Box 60, Mickleham, VIC 3064
Email: care@refundly.com.au
Website: www.refundly.com.au

We will investigate your complaint and respond within a reasonable timeframe. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Website: www.oaic.gov.au
Phone: 1300 363 992

13. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available at www.refundly.com.au. We encourage you to review it periodically.

Last updated: 19 June 2025