Privacy Policy

1. Who we are

Transfer Guardian is a trading name of Poseidon Finance Pty Ltd (ABN 93 686 108 707) ("we", "us", "our"). We provide payment account verification services. We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. Information we collect

To verify that a bank account genuinely belongs to the intended recipient, and to meet our anti-money laundering and counter-terrorism financing (AML/CTF) obligations, we may collect:

• Identity information: full name, date of birth, residential address, and copies of identification documents such as a passport or driver licence.
• Contact information: email address, phone number and postal address.
• Business information: entity name, ABN/ACN or overseas company registration number, country of incorporation, registered address, directors and beneficial owners.
• Banking information: account name, BSB and account number, or for international accounts the SWIFT/BIC, IBAN, local bank code, bank name and address, and account currency.
• Supporting documents: bank statements, company extracts and other documents you upload.
• Technical information: IP address, browser type, and records of when verification links are viewed.

3. How we collect information

We collect information directly from you when you register, submit a verification request, create a partner account or contact us. We may also collect information from third parties and public sources, including the Australian Business Register, ASIC, overseas company registries, sanctions lists (including the DFAT Consolidated List), politically exposed person (PEP) databases, and electronic identity verification services.

4. Why we collect and use information

• To verify the identity of account holders and confirm bank account ownership.
• To issue verification certificates and verified payment links.
• To detect, prevent and investigate fraud, scams and other unlawful activity.
• To comply with our legal obligations, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
• To operate, maintain and improve our services and communicate with you.

5. Disclosure of information

We do not sell your personal information. We may disclose it to:

• Our payment network provider and licensed FX provider, where you choose to use their services.
• Identity verification, screening and cloud hosting providers who help us deliver our services.
• Government agencies and regulators, including AUSTRAC, where required or authorised by law.
• Partners who requested a verification, limited to the verification outcome and the details needed to make a payment.
• Professional advisers, and any other party where you have consented or the law requires it.

6. Overseas disclosure

Some of our service providers may store or process information outside Australia. Where you verify an international account, information may be disclosed to banks, registries or providers in the relevant country. We take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with the APPs.

7. Public verification records

When an account is verified, a public verification page may display limited details such as the account name, entity type, bank details needed for payment and the verification status. Identity documents, dates of birth, residential addresses and uploaded documents are never displayed publicly.

8. Storage, security and retention

Documents are stored in secure, access-controlled cloud storage and are only accessible to authorised staff. We use encryption in transit, access controls and audit logging to protect your information.

We generally retain customer identification and verification records for at least seven years, as required by AML/CTF laws. When information is no longer needed, we take reasonable steps to destroy or de-identify it.

9. Access and correction

You may request access to, or correction of, the personal information we hold about you by contacting us. We will respond within a reasonable period, usually 30 days. In some circumstances the law may permit or require us to refuse access, in which case we will explain why.

10. Complaints

If you have a concern about how we handle your personal information, please contact us at [email protected]. We will acknowledge your complaint and aim to resolve it within 30 days. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

11. Changes to this policy

We may update this Privacy Policy from time to time. The current version will always be available on this page.