Last Updated: 1 December 2025
Effective Date: 1 December 2025
1. INTRODUCTION AND SCOPE
Micro Pawn Technologies Pty Ltd (“Micro Pawn,” “we,” “us,” or “our”) is committed to protecting your privacy in accordance with Australian privacy laws. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you use our website, mobile application, platform, and related services (collectively, the “Services”).
This policy is designed to comply with:
- The Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs)
- The Information Privacy Act 2009 (Qld), including the Information Privacy Principles (IPPs)
- Other applicable Commonwealth, Queensland, and national privacy laws and regulations
It also addresses our obligations under related legislation, including:
- The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act)
- The Pawnbrokers Act 2014 (Qld) and relevant regulations
- The Second-Hand Dealers and Pawnbrokers Regulation 2021 (Qld)
By accessing or using our Services, providing information to us, or creating an account, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.
2. DEFINITIONS
- “Personal Information” has the meaning given in the Privacy Act and includes information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether recorded in a material form or not. Under Queensland law, this also includes information subject to the Information Privacy Act 2009 (Qld).
- “Sensitive Information” is a subset of personal information and includes information about an individual’s racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record, or health information.
- “Credit-Related Personal Information” means personal information that is used to assess an individual’s eligibility for consumer credit, as regulated by Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code 2014.
- “APPs” refers to the Australian Privacy Principles in Schedule 1 of the Privacy Act.
- “IPPs” refers to the Information Privacy Principles under the Information Privacy Act 2009 (Qld).
- “Platform” refers to the Micro Pawn financial technology marketplace connecting Pawnshops and Investors.
- “Queensland Pawnbroking Laws” refers collectively to the Pawnbrokers Act 2014 (Qld), *Second-Hand Dealers and Pawnbrokers Regulation 2021 (Qld)*, and associated regulatory instruments.
3. TYPES OF PERSONAL INFORMATION WE COLLECT
The types of personal information we collect depend on your interaction with us:
A. For All Users:
- Identity Information: Your name, date of birth, photograph (e.g., from government ID), and contact details (email, phone number, residential/business address).
- Account Information: Username, password, profile details, and communication preferences.
- Verification Information: Information required to verify your identity under the AML/CTF Act and Queensland Pawnbroking Laws, such as copies of:
- Queensland driver licence or adult proof of age card
- Australian passport or other recognised identification documents
- Utility bills or other documents confirming residential address
- Financial Information: Bank account details, BSB, payment history, and transactional data related to your use of the Services.
- Technical & Usage Data: IP address, device information (type, operating system, unique identifiers), browser type, log data, pages viewed, time spent, and other analytics collected via cookies and similar technologies. Please see our Cookie Policy for more detail.
- Communication Records: Records of your communications with us via email, support tickets, or phone calls.
B. For Pawnshops (Additional Information):
- Business Information: Business name, ABN, business address, details of directors, beneficial owners, and nominated managers as required under the Pawnbrokers Act 2014 (Qld).
- Licencing Information: Copies of your Queensland pawnbroker licence (issued by the Queensland Police Service), including licence number, conditions, and expiry dates.
- Professional Information: Insurance details (including public liability insurance as required by Queensland law), business financial information for creditworthiness assessment, and information about your pawn loan portfolio.
- Transaction Records: Information required to be collected and maintained under Queensland pawnbroking regulations, which may be processed through our Platform.
C. For Investors (Additional Information):
- Suitability Information: Information collected to assess your investment experience, objectives, and financial situation (e.g., income, assets, net worth) to determine your eligibility to use the platform, as required by the Corporations Act 2001 (Cth).
- Tax Information: Your Tax File Number (TFN) or reason for not quoting a TFN, for reporting purposes where applicable.
D. Sensitive Information:
We generally do not collect sensitive information. However, in limited circumstances, such as if you voluntarily provide it in correspondence or if it appears on an identification document, we may incidentally collect it. We will only collect sensitive information with your consent or as otherwise permitted by law, including under Queensland’s privacy framework.
4. HOW WE COLLECT PERSONAL INFORMATION
We collect personal information directly from you when you:
- Register for an account on the Platform;
- Complete application or verification forms;
- Use the Services to list, invest in, or manage a pawn loan;
- Contact our customer support team;
- Subscribe to our marketing communications; or
- Participate in surveys or promotions.
We may also collect information from third parties, such as:
- Identity Verification Services: From accredited third-party providers to verify your identity under AML/CTF obligations and Queensland Pawnbroking Laws.
- Credit Reporting Bodies (CRBs): We may obtain credit-related personal information about Pawnshops (as commercial credit applicants) from a CRB like Equifax, Illion, or Experian to assess creditworthiness.
- Government Registries: Such as the Australian Business Register (ABR) to confirm business details, and the Queensland Police Service for licence verification (where permitted).
- Publicly Available Sources: In line with our AML/CTF obligations, we may collect information from public registers or media.
- Service Providers: Such as payment processors and analytics providers.
- Other Pawnbrokers: Where permitted by law and with appropriate consent, for fraud prevention and regulatory compliance purposes.
5. PURPOSES FOR COLLECTING, USING, AND DISCLOSING PERSONAL INFORMATION
We collect, hold, use, and disclose your personal information for the following primary purposes:
A. To Provide and Operate the Services:
- To verify your identity and eligibility to use the Platform.
- To create and manage your account.
- To facilitate transactions between Pawnshops and Investors.
- To process payments and distribute earnings.
- To communicate with you about your account and transactions.
B. For Compliance with Australian and Queensland Laws (Primary Purpose):
- To meet our obligations under the AML/CTF Act, including conducting customer due diligence, ongoing monitoring, and reporting to AUSTRAC.
- To comply with the Pawnbrokers Act 2014 (Qld) and associated regulations, including maintaining required records, assisting with police investigations, and complying with reporting obligations to the Queensland Police Service.
- To comply with our licensing and regulatory obligations under the Corporations Act 2001 (Cth), if applicable.
- To comply with taxation laws (e.g., ATO reporting).
- To assist with law enforcement activities and regulatory investigations where required or authorised by law, including to Queensland Police and other regulatory bodies.
C. For Business Operations and Communication:
- To perform internal business operations, including risk management, audit, and accounting.
- To conduct research, analytics, and improve the Platform’s functionality and security.
- To send you important service-related notices and updates.
- To provide you with information about products, services, or offers, where you have consented to receive direct marketing. You can opt-out at any time.
D. To Protect Rights and Safety:
- To detect, prevent, and investigate fraud, security breaches, and other prohibited or illegal activities.
- To enforce our Terms of Service and other agreements.
6. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
We may disclose your personal information to the following types of third parties, both within and outside of Australia:
- Service Providers: We engage third parties to perform functions on our behalf, such as IT and data hosting, payment processing, identity verification, document signing, customer support, and marketing. These providers are contractually bound to handle your information confidentially and in accordance with privacy law.
- Financial Institutions & Payment Processors: To facilitate transactions, such as your nominated bank.
- Credit Reporting Bodies (CRBs): For the purpose of assessing a Pawnshop’s commercial credit application, as permitted by the Privacy Act.
- Other Platform Users: As necessary to facilitate a transaction. For example, an Investor’s username and funding amount may be visible to a Pawnshop for a loan they fund, and a Pawnshop’s business name and licence details may be visible to Investors.
- Regulatory and Government Authorities: Where required by law, such as to:
- AUSTRAC (for AML/CTF reporting)
- Queensland Police Service (as required under the Pawnbrokers Act 2014 (Qld))
- Office of Fair Trading (Queensland)
- Australian Securities and Investments Commission (ASIC)
- Australian Taxation Office (ATO)
- Other law enforcement or regulatory agencies
- Professional Advisers: To our lawyers, auditors, and accountants.
- In Connection with a Business Transaction: To a potential buyer, seller, or other successor in the event of a merger, acquisition, or sale of assets.
- With Your Consent: For any other purpose disclosed to you at the time of collection, with your consent.
7. CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION
Some of our service providers (e.g., cloud hosting, analytics, identity verification) may be located outside Australia, including in the United States, Singapore, and other countries. Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure the recipient is subject to:
- A law or binding scheme that protects the information in a substantially similar way to the APPs and IPPs; or
- Contractual obligations that provide a comparable standard of protection.
You consent to the disclosure of your personal information to overseas recipients on this basis. By providing your personal information, you acknowledge that APP 8.1 will not apply, and we will not be accountable under the Privacy Act for any subsequent breach by the overseas recipient.
8. DATA SECURITY AND RETENTION
Security: We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. These steps include physical security measures, electronic protections (like encryption and firewalls), and internal policies governing data handling. We comply with the mandatory data breach notification scheme under the Privacy Act. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security.
Retention: We retain your personal information for as long as necessary to fulfil the purposes outlined in this policy and to comply with our legal and regulatory obligations, including:
- AML/CTF Act: Minimum 7 years after the end of your relationship with us
- Queensland Pawnbroking Laws: As required by the *Second-Hand Dealers and Pawnbrokers Regulation 2021 (Qld)* (typically a minimum of 3-5 years for transaction records)
- Taxation Law: 5 years from when the records are prepared or obtained
We securely destroy or de-identify personal information when it is no longer needed.
9. YOUR RIGHTS AND CHOICES
Under the Privacy Act and Queensland privacy laws, you have rights to:
- Access: Request access to the personal information we hold about you.
- Correction: Request correction of any inaccurate, out-of-date, incomplete, irrelevant, or misleading personal information.
- Complaint: Lodge a complaint with us (see Section 12) or directly with the relevant privacy regulator.
- Anonymity: Where practicable, you may interact with us anonymously (e.g., to make a general enquiry). However, for the core Services, we cannot provide service without collecting necessary identifying information as required by law.
- Opt-Out of Direct Marketing: You can unsubscribe from our marketing communications at any time by using the link in any email or contacting us.
To exercise your access or correction rights, please contact our Privacy Officer using the details in Section 12. We will respond within a reasonable period (generally within 30 days for access requests) and may require verification of your identity. In some circumstances permitted by law, we may deny your request and provide you with written reasons.
10. CREDIT REPORTING
If we collect credit-related personal information about a Pawnshop (as a commercial credit applicant), we will handle it in accordance with Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code. This includes informing you:
- That we may obtain a credit report about you from a CRB.
- The name and contact details of the CRB we use.
- How you can access the CRB’s policy on managing credit-related personal information.
- Your rights to access and correct the information held by the CRB and to make a complaint.
11. COOKIES AND ONLINE ANALYTICS
Our website uses cookies and similar tracking technologies. For detailed information on the types of cookies we use, their purposes, and how you can manage your preferences, please refer to our separate Cookie Policy, available on our website.
12. COMPLAINTS AND CONTACT INFORMATION
Making a Privacy Complaint: If you have a complaint about how we have handled your personal information, please contact our Privacy Officer first. We will acknowledge your complaint within 7 business days and investigate and respond in writing within a reasonable period (typically 30 days).
Contacting Our Privacy Officer:
Email: contact@micropawn.com
Post: The Privacy Officer
Micro Pawn Technologies Pty Ltd
128 Collins Street, Nundah, Qld, 4012
13. GOVERNING LAW AND JURISDICTION
This Privacy Policy is governed by the laws of Queensland, Australia. You submit to the non-exclusive jurisdiction of the courts of Queensland and the Commonwealth of Australia.
14. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our Platform with a new “Last Updated” date and, where appropriate, by email. Your continued use of the Services after such notice constitutes your acceptance of the updated policy.
15. QUEENSLAND-SPECIFIC PROVISIONS
In addition to the Commonwealth Privacy Act, we comply with Queensland’s Information Privacy Act 2009 (IP Act) where applicable. If you are interacting with us in relation to Queensland government-related functions or where the IP Act otherwise applies, the following additional provisions apply:
- We will handle your personal information in accordance with the Information Privacy Principles (IPPs) under the IP Act.
- You have the right to apply for amendment of documents containing your personal information under the Right to Information Act 2009 (Qld) where applicable.
- Our information handling practices are designed to meet Queensland’s specific privacy requirements for regulated industries including pawnbroking.
This Privacy Policy should be read in conjunction with our Terms of Service and any other applicable policies provided to you.
