Shop 14, 224 Belmont Ave Cloverdale WA 61040410 009 485info@etemad.com.au
ETEMAD

Privacy Policy

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Last Updated: November 19, 2025

1. Our Commitment to Your Privacy

Sarafi Etemad (ABN 73 669 653 052) (referred to as "we", "us", or "our") is committed to protecting your privacy. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

This Privacy Policy outlines how we collect, use, hold, and disclose your personal information. It also covers your rights to access and correct your information and how to make a complaint.

This policy is available free of charge on our website: www.etemad.com.au

2. What Personal Information We Collect

We collect personal information that is reasonably necessary for us to provide our products and services to you. The types of information we may collect and hold include:

  • Identity Information: e.g., Full name, date of birth, occupation.
  • Contact Information: e.g., Proof of address, phone numbers, email addresses.
  • Identification Documents: e.g., Australian Driving Licence, Australian Government-issued ID, or International Passport (and the information contained within).
  • Financial Information: e.g., Beneficiary bank account details, transaction history.
  • Technical Information: e.g., IP address, device type (see Section 7 on Cookies).

We will not collect sensitive information about you (such as information about your health, race, or political opinions) without your consent, unless an exemption in the APPs applies.

3. How and Why We Collect Your Information

We collect your information in the following ways:

Directly from You:

When you register for an account, fill out forms, contact us by phone or email, or use our services.

From Third Parties:

We may collect information from third parties such as:

  • • Electronic verification services (e.g., the Document Verification Service (DVS)) to verify your identity.
  • • Referrers or marketing agencies.
  • • Publicly available sources.

If we receive information from a third party, we will take reasonable steps to ensure you are made aware of it.

Unsolicited Information:

If we receive personal information about you that we did not solicit, we will determine if we could have lawfully collected it. If not, we will destroy or de-identify it as soon as practicable.

Why we collect it:

Our primary purpose for collecting your information is to provide you with our financial exchange services. This includes:

  • • Verifying your identity in line with our legal obligations.
  • • Processing your transactions.
  • • Communicating with you about your account and our services.
  • • Managing our risks and legal obligations.

If you do not provide the personal information we request, we may not be able to provide you with our services.

4. Anonymity and Pseudonymity

We do not give you the option of dealing with us anonymously or under a pseudonym. This is because it is impracticable and, in most cases, illegal for us to provide our services to unidentified individuals (for example, due to our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006).

5. How We Use and Disclose Your Information

We do not sell, share, or rent your personal information to third parties for their promotional purposes. We will only use or disclose your information for the purposes we collected it, or for a related purpose you would reasonably expect.

This may include disclosure to:

Service Providers:

Third parties who help us with our business operations, such as transaction processing, IT support, marketing, and fraud prevention. These providers are contractually bound to protect your information and only use it for the services we engage them for.

Law Enforcement and Regulators:

We may disclose information to government officials or law enforcement in connection with a formal request, subpoena, or similar legal procedure, or where we believe in good faith that disclosure is necessary to comply with the law, report suspected illegal activity.

Change of Control:

If our business is sold, merged, or acquired, your personal information may be part of the transferred assets. We will notify you of any such change.

Direct Marketing

We may use your personal information to offer you products and services we believe may interest you.

Cross-Border (Overseas) Disclosure

To process your transactions, we may need to disclose your personal information to recipients located outside Australia.

This commonly includes:

  • • Beneficiary financial institutions in the destination country of your transfer.
  • • Our international payment processors, correspondent banks, and global settlement network partners.
  • • Third-party service providers who assist us with fraud prevention, identity verification, or data storage, who may be located or process data overseas.

We will take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your information. However, by using our services, you consent to this disclosure, and you acknowledge that we may not be able to ensure the overseas recipient's compliance with the APPs.

Government-Related Identifiers

We do not adopt, use, or disclose government-related identifiers (like Tax File Numbers or Driver's Licence numbers) as our own identifier for you. We only collect and use these identifiers as required or authorised by law (e.g., for identity verification).

6. How We Hold and Secure Your Information

We hold your personal information in a combination of secure computer databases and, in some cases, paper files.

We take reasonable steps to protect your information from misuse, interference, loss, and from unauthorised access, modification, or disclosure. These steps include:

Technical Measures: Using passwords, data encryption during transmission, firewalls, and two-factor authentication.
Access Controls: Restricting employee access to personal information on a "need-to-know" basis, with audit logging to track access.
Physical Security: Storing any paper files in secure areas.
Remote Work Security: Enforcing strict policies for employees working remotely, including device security, locked screens, and prohibitions on copying or sharing data via personal accounts or devices.

7. Cookies and Website Analytics

When you visit our website, we may use cookies and other tracking technologies. Cookies are small text files transferred to your computer that help our website recognise your browser and capture certain information.

We use cookies to:

  • • Facilitate your access and use of our online platform.
  • • Understand how you interact with our website.
  • • Compile aggregate data about site traffic and user behaviour to improve our services.

By using our website, you consent to our use of cookies. You can manage, refuse, or delete cookies through your web browser settings. However, if you refuse cookies, you may not be able to use all features of our website.

Information collected by cookies is generally anonymous, but it may be combined with other information that could identify you. We handle this information with the same-level of security as all other personal information.

8. Your Rights: Access and Correction

You have the right to request access to and correction of the personal information we hold about you.

Access (APP 12)

You can request access to your information by contacting our Privacy Officer (details below). We will require you to verify your identity before providing access.

We will respond to your request within a reasonable period (generally within 30 days). We may charge a reasonable administrative fee for search and copying costs. We will not refuse access unless a valid exception under the Privacy Act applies (e.g., if it would prejudice a legal investigation). If we refuse, we will provide you with a written explanation.

Correction (APP 13)

We are committed to ensuring your information is accurate, up-to-date, and complete. If you believe the information we hold is incorrect, please contact us.

We will take reasonable steps to correct the information within 30 days. We will not charge you for making a correction request. If we have previously disclosed incorrect information to a third party, we will notify them of the correction.

9. How to Make a Complaint

If you have a question, concern, or complaint about how we have handled your personal information, please contact us first.

Step 1: Contact our Privacy Officer

Please lodge your complaint in writing to our Privacy Officer with specific details. We will investigate the complaint and provide you with a written response within a reasonable period.

Mail

Shop 14 224 Belmont Ave Cloverdale WA 6104

Step 2: Contact the Office of the Australian Information Commissioner (OAIC)

If you are not satisfied with our response or how we handled your complaint, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

10. Changes to This Policy

We may review and update this Privacy Policy from time to time to account for new laws, technologies, and changes to our operations. The most current version will always be available on our website.

11. Contact Us

For any privacy-related queries, please contact us:

Mail

Shop 14 224 Belmont Ave Cloverdale WA 6104

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