Privacy Policy

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Smart collects and processes your personal information through your use of this website, and when you deal with us whether by phone, letter, email or by meeting with us in person, including any personal information you may provide through this website when you sign up to our newsletter, request guides or information or use any of our services including engaging in any transactions with us.

What personal information do we collect about you?

Smart must only collect personal information that is necessary for our functions and activities. As a financial services organisation, we are subject to legislative and regulatory requirements that require us to obtain and hold the personal information of our clients. Personal information may include things such as your contact details, name, date of birth, and bank account details.
We may update the information we hold about you during our communications. You should contact us if any personal information we hold is inaccurate or out of date. Please see the “Contact details” information below.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 02/04/2026.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Contact details

Our full details are:

Full name of legal entity:
Smart Currency Exchange Pty Limited

Email address: [email protected]
Postal address: C / – Intertrust Australia Pty Ltd SE 2 L 25, 100 Miller Street, North Sydney NSW 2060
Telephone number: 1300 779 106

Websites: www.smartcurrencyexchange.com.au and www.smartcurrencybusiness.com.au

You have the right to make a complaint at any time to the Office of the Australian Information Commissioner (OAIC) for privacy and data protection issue at https://www.oaic.gov.au/ or 1300 363 992 or by mail at GPO Box 5288, Sydney NSW 2001. We would, however, appreciate the chance to deal with your concerns before you approach the OAIC so please contact us in the first instance.

Personal data, or personal information, means any information about an individual from which that person can reasonably be identified or an opinion about an identified individual or an individual who is reasonably identifiable.

It does not include data where the identity has been removed (anonymous data) and will always relate to the main purpose of which the information was collected, per paragraph 4 below.

We may collect, use, store and transfer different kinds of personal information about you, reasonably required by us to carry on our financial services business, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone
• Financial Data includes bank account and payment
• Transaction Data includes details about payments to and from you and other details of transactions carried out on your account with us, including any trades you transact with us and / or payments made by us for you to third parties as part of any service you have obtained from
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password in relation to your use of our website and/or any trading account you apply for or establish with us and any purchases or orders made by you, your interests, preferences, feedback and survey
• Usage Data includes information about how you use our website, products and
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this data will NOT directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

We do not collect any sensitive information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal information collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• or
• give us some

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:

• Technical Data from the following parties:
• analytics providers such as Google based in AUS / outside AUS;
• advertising networks such as Google and Bing, based in AUS / outside AUS and
• search information providers such as Google based in AUS / outside AUS.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as your bank or your lawyer or other professional representatives, or the bank of a beneficiary to whom you wish to direct a payment transaction which may be based in Australia and or outside the Australia depending on your instructions and your and the beneficiary’s banking arrangements in each case.

Identity and Contact Data and Financial Data from credit reference or other data brokers or aggregators based in AUS / outside AUS for the purpose of undertaking such credit checks and identity verification as may be appropriate to any of our services you require or use and in order for us to meet the requirements of the AML/CTF Act 2006 (Cth) and all similar laws and regulations that apply to us and the services we provide to you.

Identity and Contact Data from publicly availably sources such as ASIC Company Registers or the ASIC Professional Registers or ABN Lookup or voting authority for which you are registered is outside of Australia, then such registers outside of Australia.

Identity and Contact Data from third parties who introduce you to us, and in this respect, we only deal with third parties who confirm to us that they are providing us with this information for a legitimate purpose (for instance where you request them to do so, or seek information about us or our services from that third party).

Smart will always take steps, that are reasonable under the circumstances to ensure that the personal information we collect and disclose on an ongoing basis from you is accurate, up-to-date and complete. We will not collect sensitive personal information unless required by law.

We will only use your personal information when the law allows us to or when it is related to the main purpose for which the information was collected. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw your consent to marketing at any time by contacting us.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information on more than one lawful ground depending on the specific purpose or purposes for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity(b) Contact	Performance of a contract with you
To process and deliver your order including:(a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity(b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/ services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, systemmaintenance, support, reporting and hosting of data)	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/ services, marketing, customer relationships and experiences	(a) Technical(b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data usage, particularly around marketing and advertising. If at any time you do not wish to receive further marketing emails from us you may click the “Unsubscribe” option contained in each of our marketing emails. Alternatively, you may ask to have your email address removed from our marketing address lists by contacting us by email at [email protected].

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us or registered for a promotion and, in any case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of Smart Currency’s Corporate Group for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of any of our services or transactions with us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may

become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table detailed in the data usage section

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we have collected personal information for a particular purpose (the primary purpose), we will not use or disclose your personal information for another purpose (the secondary purpose) unless you have given consent, or it would be reasonably expected that we would use this information for a secondary purpose.

We share your personal information within the Smart Currency Corporate Group, this does involve transferring your data outside of Australia, generally into the United Kingdom and EU which also strictly abides by the Data Protection Act 2018 and General Data Protection Regulation, which maintains similar privacy requirements and responsibilities akin to Australian regulation.

Many of our external third parties are based outside of Australia so their processing of your personal information will involve a transfer of data outside Australia. This is particularly so where, either you are based outside of Australia or you require any information, product, services or transaction which relates at least in part to a person or legal entity or property based outside of Australia and or which requires communication with you or any other party outside of Australia in relation to that information, product, service or transaction.

Whenever we transfer your personal information out of Australia, we ensure a similar degree of protection is afforded to it by ensuring per Australian Privacy Principle 8, that we will take reasonable steps to ensure that all transfers of personal information overseas, handles data in a way consistent with the Australian Privacy Principles. In this regard we have deemed that the UK and EU maintain comparable privacy protections.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Australia.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

Notifiable Data Breach

If we become aware of any data breach concerning personal information, we are required under the Act to determine whether any “eligible data breach” (as defined in the Act) has occurred.

We have put in place procedures to deal with any suspected personal data. If we determine that there has been an eligible data breach, then we are required to notify the affected individuals as soon as practicable of the details of the breach and the recommended steps that the relevant individuals should take in response.  We may also be required to notify the Office of the Australian Information Commissioner.

How long will you use my personal information for?

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for regulatory and AML/CTF purposes.

If you provide personal information we did not request, we will only retain it where permitted or required by law and will protect it in accordance with this Privacy Policy.

After this period, information may be anonymised, securely destroyed or retained where legally permitted.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

Identity verification may be required before requests are processed. We will respond to your request within 30 business days of receipt of your request.  If we consider that the information does not need correcting then we will let you know the reasons why, when we respond.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 30 business days from the date of receipt of your request. Occasionally it could take us longer than 30 business days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative)

and your rights before we process your personal information for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal Third Parties

Other companies in the Smart Currency Corporate Group who may require disclosures of your personal information who are based England, Spain and Portugal and provide administration services and undertake leadership reporting

External Third Parties

Service providers, based in the UK, Spain and Portugal who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers based in the UK, Spain and Portugal who provide consultancy, banking, legal, insurance and accounting services.

Regulators such as the Australian Securities and Investment Commission and or the Australian Transaction Reports and Analysis Centre, Australian Financial Complaints Authority and Office of the Australian Information Commissioner and other authorities who may require personal information to be disclosed to in Australia or based overseas if relevant to any of your transactions with us who require reporting of activities in certain circumstances.

The Police, Australian Federal Police or other crime prevention agencies and authorities based in Australia and internationally where relevant.

Your legal rights

You have the right to:

Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Right to make a complaint where you are dissatisfied with our use or disclosure of your personal information. You may make such complaints to us or to the OAIC. See the ‘Contact Details’ paragraph of this Privacy Policy.