Terms/Privacy Policy and AML/CTF Collection Notice
Paid On Exchange Pty Ltd | ABN 58 126 679 678 | www.paidonexchange.com.au
Last updated: 3 June 2026
AUSTRAC registration notice
Paid On Exchange Pty Ltd is registered with AUSTRAC as a reporting entity for applicable AML/CTF purposes.
AUSTRAC registration does not imply endorsement of Paid On Exchange or its services.
1. About this Privacy Policy
Paid On Exchange Pty Ltd, trading as PaidOnExchange, respects your privacy and is committed to protecting personal information.
This Privacy Policy explains how we collect, hold, use and disclose personal information when you visit our website, submit an enquiry, apply for commission advance funding, enter into an agreement with us, provide information as a director, principal, guarantor, authorised representative or beneficial owner, or otherwise deal with us.
This Privacy Policy is intended to comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles and, where applicable, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and related rules and guidance.
By using our website, submitting information to us, applying for funding or otherwise dealing with us, you acknowledge that we may handle your personal information in accordance with this Privacy Policy.
2. Who we are
Paid On Exchange provides commission advance and cash-flow funding solutions to real estate agents, agencies and related business customers.
In the course of providing our services, we may collect and verify information about applicants, customers, directors, principals, beneficial owners, guarantors, authorised representatives, agents, agency staff and other relevant parties.
3. What personal information we collect
The personal information we collect depends on the nature of your dealings with us.
We may collect information including:
• full name;
• date of birth;
• residential address;
• postal address;
• business address;
• email address;
• telephone number;
• occupation or position;
• driver licence, passport or other identification details;
• copies of identification documents;
• ABN, ACN and business registration details;
• real estate licence details;
• company, partnership, trust and business structure information;
• details of directors, shareholders, trustees, beneficiaries, beneficial owners and controlling persons;
• bank account details;
• agency and commission entitlement details;
• sales, settlement, listing, commission and transaction documents;
• information about rent rolls or business operations;
• credit, solvency, bankruptcy, insolvency or financial risk information where relevant and permitted by law;
• application, funding, repayment and account history;
• correspondence, call notes and records of communications with us;
• website usage information, cookies, analytics data and device information; and
• any other information reasonably required for our business, legal, risk management, fraud prevention, AML/CTF, funding, recovery or compliance purposes.
Where relevant, we may also collect information about emergency contacts, referees, professional advisers, settlement participants, banks, lawyers, accountants, conveyancers, brokers, real estate agencies and other parties connected with an application or funded transaction.
4. Sensitive information
We do not generally collect sensitive information unless it is reasonably necessary for our functions or activities, required or authorised by law, or provided by you with consent.
Sensitive information may include information about criminal history, sanctions exposure, politically exposed person status or other information relevant to legal, AML/CTF, fraud prevention, sanctions or regulatory obligations.
5. How we collect personal information
We may collect personal information directly from you when you:
• visit our website;
• submit an online enquiry;
• complete an application form;
• provide identification documents;
• provide business, banking, commission or settlement information;
• enter into a funding agreement;
• communicate with us by phone, email, online form or other method;
• provide information as a director, principal, guarantor, beneficial owner or authorised representative; or
• otherwise deal with us.
We may also collect information from third parties, including:
• real estate agencies;
• principals, directors, authorised representatives and guarantors;
• banks and payment providers;
• settlement participants;
• lawyers, conveyancers and accountants;
• credit reporting bodies and information providers, where permitted by law;
• identity verification providers;
• fraud prevention and AML/CTF screening providers;
• government registers and regulators;
• real estate licensing bodies;
• company, business, bankruptcy and insolvency registers;
• publicly available sources;
• professional advisers; and
• other persons or organisations relevant to an application, funded advance, repayment, recovery action or legal compliance.
6. Why we collect, use and disclose personal information
We collect, use and disclose personal information for purposes including:
• receiving and assessing enquiries and applications;
• verifying identity;
• verifying authority to act;
• verifying business, company, trust and beneficial ownership information;
• verifying real estate licence and agency details;
• assessing eligibility for funding;
• assessing credit, commercial, fraud, operational, legal, AML/CTF and repayment risk;
• verifying commission entitlement;
• verifying bank account details;
• processing, approving, declining, delaying, suspending or cancelling applications;
• funding commission advances;
• monitoring funded advances and repayments;
• communicating with customers, applicants, guarantors and related parties;
• administering customer accounts;
• recovering amounts owed to us;
• managing disputes, complaints, defaults and enforcement action;
• complying with legal and regulatory obligations;
• conducting customer due diligence, enhanced due diligence and ongoing monitoring;
• identifying and managing money laundering, terrorism financing, sanctions and other financial crime risks;
• reporting to AUSTRAC, law enforcement bodies, regulators or government agencies where required or permitted by law;
• preventing fraud, identity misuse and unlawful activity;
• improving our website, services, systems and customer experience;
• maintaining business records;
• obtaining professional advice; and
• protecting our business, customers, funders, investors, service providers and the integrity of the financial system.
7. AML/CTF collection notice
Paid On Exchange Pty Ltd is registered with AUSTRAC as a reporting entity for applicable AML/CTF purposes.
Paid On Exchange may be required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), related rules and regulatory guidance.
As part of our application, approval, funding, repayment, monitoring and compliance processes, we may collect, use and verify personal information about customers, applicants, directors, principals, beneficial owners, authorised representatives, guarantors and related parties.
This may include identity information, business information, company and trust information, beneficial ownership information, bank account information, transaction information, commission documents, settlement information and other information reasonably required for AML/CTF, sanctions, fraud prevention and legal compliance purposes.
We may verify this information using third-party verification providers, government registers, public records, banks, settlement participants, real estate agencies, professional advisers, credit reporting bodies, payment providers and other relevant parties.
If you do not provide information requested by us, or if we are unable to verify information to our satisfaction, we may be unable to provide funding, continue dealing with you or process a transaction.
In some circumstances, we may be legally restricted from telling you about certain actions we take, decisions we make or reports we submit.
8. Disclosure of personal information
We may disclose personal information to:
• our related bodies corporate, officers, employees, contractors and agents;
• identity verification providers;
• AML/CTF, sanctions and fraud screening providers;
• credit reporting bodies and information service providers, where permitted by law;
• banks, payment providers and financial institutions;
• real estate agencies and agency principals;
• settlement participants;
• lawyers, accountants, conveyancers, valuers, investigators and other professional advisers;
• debt collection and recovery agents;
• insurers;
• technology, website, hosting, document management, customer relationship management and cloud service providers;
• funders, investors, assignees, financiers or potential transaction counterparties, where relevant to a funding arrangement, sale, assignment, refinance, restructure or business transaction;
• courts, tribunals and dispute resolution bodies;
• AUSTRAC, ASIC, the ATO, law enforcement bodies, government agencies, regulators and licensing bodies; and
• any other person or organisation where required or permitted by law, or where reasonably necessary for our business, legal, funding, recovery, compliance or risk management purposes.
9. Overseas disclosure
Some of our service providers, technology platforms, verification providers, cloud hosting providers, communication providers or support services may store, access or process information outside Australia.
Where we disclose personal information overseas, we will take reasonable steps to ensure that the information is handled in a way that is consistent with applicable Australian privacy requirements, unless an exception applies under law.
Countries where information may be stored or accessed may include Australia, the United States, the United Kingdom, countries within the European Union, and other locations where our service providers or their systems operate.
10. Credit and commercial risk information
Where relevant and permitted by law, we may collect, use and disclose credit-related or commercial risk information to assess an application, verify information, manage repayment risk, recover amounts owing, prevent fraud or comply with legal obligations.
This may include information from credit reporting bodies, public registers, insolvency records, court records, commercial information providers, referees, professional advisers and other relevant sources.
Where we are required to comply with specific credit reporting obligations, we will handle credit information in accordance with those obligations.
11. Direct marketing
We may use your contact details to send you information about our services, updates, offers, newsletters or other communications that may be relevant to you.
You may opt out of direct marketing communications at any time by using the unsubscribe function in our emails or by contacting us.
Even if you opt out of marketing communications, we may still send you important service, legal, compliance, account, funding or repayment communications.
12. Website, cookies and analytics
When you visit our website, we may collect information such as your IP address, browser type, device type, pages visited, time spent on pages, referral source and other usage information.
We may use cookies, pixels, analytics tools and similar technologies to operate our website, improve user experience, understand website traffic, measure marketing performance, prevent fraud and improve our services.
You can adjust your browser settings to refuse cookies, but some website features may not work properly if cookies are disabled.
13. Security of personal information
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.
These steps may include secure systems, access controls, staff training, confidentiality obligations, document controls, data backups, monitoring, encryption, password protection and secure disposal processes.
No method of electronic transmission or storage is completely secure. However, we aim to use reasonable safeguards appropriate to the nature of the information and the risks involved.
14. Retention of personal information
We retain personal information for as long as reasonably necessary for the purposes for which it was collected, including business, legal, accounting, funding, recovery, dispute resolution, AML/CTF and regulatory purposes.
AML/CTF records, customer due diligence records, transaction records and related compliance records may need to be retained for at least 7 years after the end of the business relationship or the last relevant transaction, or for any other period required by law.
When personal information is no longer required, we will take reasonable steps to destroy it or de-identify it, unless we are required or permitted by law to retain it.
15. Accessing your personal information
You may request access to personal information we hold about you by contacting us.
We may need to verify your identity before responding to an access request.
We will respond to access requests within a reasonable period. In some circumstances, we may refuse access or provide limited access where permitted by law, including where access would affect another person’s privacy, prejudice legal proceedings, reveal commercially sensitive information, compromise fraud prevention or AML/CTF controls, or where we are legally restricted from disclosing information.
16. Correcting your personal information
You may ask us to correct personal information we hold about you if you believe it is inaccurate, incomplete, out of date, irrelevant or misleading.
We will take reasonable steps to correct information where appropriate.
Customers and applicants must promptly notify us of changes to identity information, business ownership, beneficial ownership, control, authority, bank account details, commission entitlement, settlement details, repayment arrangements or any other information relevant to an application or funded advance.
17. Anonymity and pseudonymity
Where lawful and practicable, you may deal with us anonymously or by using a pseudonym.
However, due to the nature of our services, we will usually need to identify and verify customers, applicants, directors, principals, beneficial owners, guarantors and authorised representatives before we can assess an application, provide funding, process a transaction or comply with legal obligations.
18. Data breaches
If we become aware of a data breach involving personal information, we will assess the incident and take appropriate steps in accordance with applicable law.
Where required, we will notify affected individuals and the Office of the Australian Information Commissioner.
19. Complaints
If you have a privacy complaint or concern, please contact us first so we can try to resolve the matter.
You can contact us at:
Privacy Officer
Paid On Exchange Pty Ltd
Email: info@paidonexchange.com.au
Website: www.paidonexchange.com.au
Please include your name, contact details and a clear description of your complaint or concern.
We will acknowledge your complaint within a reasonable time and aim to respond within 30 days.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.
20. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business, systems, services, legal obligations or regulatory guidance.
The current version will be published on our website with the effective date shown above.
21. “Anti-Money Laundering and Counter-Terrorism Financing Notice”.
Paid On Exchange Pty Ltd may be required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, related rules and AUSTRAC guidance. As part of our application, approval, funding, repayment and account management processes, we may collect, use and verify information about customers, applicants, directors, beneficial owners, authorised representatives, guarantors, investors, settlement participants and related parties.
This information may include name, date of birth, residential address, business address, contact details, identity information, ABN, ACN, real estate licence information, company and trust details, beneficial ownership and control information, bank account information, transaction information, commission statements, agency records, settlement documents, repayment documents and any other information reasonably required to verify identity, assess risk, process an application, fund an advance, recover an advance or comply with legal obligations.
We may verify information using third-party verification providers, government registers, publicly available sources, credit reporting bodies, professional advisers, settlement participants, real estate agencies, banks, payment providers and other relevant parties. We may use and disclose information for identity verification, fraud prevention, AML/CTF compliance, sanctions screening, credit assessment, funding approval, repayment, recovery, legal compliance and regulatory reporting purposes.
We may disclose information to AUSTRAC, law enforcement bodies, regulators, government agencies, courts, external advisers, verification providers, payment providers, banks and service providers where required or permitted by law. In some circumstances, we may be legally restricted from telling you about certain actions we take or reports we make. If you do not provide information requested by us, or if we are unable to verify information to our satisfaction, we may be unable to provide funding or continue dealing with you.
22. AML/CTF, Identity Verification and Funding Conditions.
Terms and Funding Agreement clause
The applicant, customer, guarantor and each authorised representative must provide all information and documents reasonably requested by Paid On Exchange Pty Ltd for identity verification, business verification, beneficial ownership verification, fraud prevention, AML/CTF compliance, sanctions screening, credit assessment, funding, repayment and recovery purposes. Paid On Exchange may conduct checks before funding, after funding and during the customer relationship.
Paid On Exchange may refuse, delay, suspend, cancel or terminate any application, approval, advance, facility or payment if requested information is not provided, information is incomplete or inconsistent, identity or authority cannot be verified, business details or beneficial ownership cannot be verified, bank account details or commission entitlement cannot be verified, a payment is requested to a third-party or unverified account, funding or repayment arrangements are unusual, or Paid On Exchange reasonably considers there is a fraud, legal, regulatory, AML/CTF, sanctions, credit or operational risk.
Paid On Exchange is not liable for any loss, cost, delay or damage arising from any action taken in good faith to comply with legal, regulatory, AML/CTF, sanctions, fraud prevention or risk management obligations. Paid On Exchange may be legally restricted from disclosing reasons for certain decisions, actions or reports.
23. Contact us
For questions about this Privacy Policy or how we handle personal information, contact:
Privacy Officer
Paid On Exchange Pty Ltd
Email: info@paidonexchange.com.au
Website: www.paidonexchange.com.au