Privacy Policy

Effective date: 3 October 2026
Last updated: 3 October 2026

Draft for Australian legal review before public launch. Replace all square-bracket placeholders before publishing.

1. Who we are

This Privacy Policy explains how [Company Legal Name] Pty Ltd (ABN [ABN]), trading as LOKD money ("we", "us" or "our"), collects, uses, stores and shares personal information when you use our mobile application, website and related services (together, the Service).

The Service is designed to help people aged 15 and over build positive financial habits from their first pay onwards.

Privacy: privacy@lokdmoney.com
Support: support@lokdmoney.com
Address: [Australian business address]

2. The short version

We aim to collect only information we reasonably need to provide and improve the Service.

We may collect account details, age band, employment and pay information, Payday Rules, goals, payslip information you choose to provide, Coach relationships, subscription information, device information and app usage data.

We do not sell personal information. We do not use detailed financial information for third-party targeted advertising. We do not ask for or store your bank password. A Coach does not automatically see your individual purchases or detailed transaction information.

The current MVP does not move money, execute investments or provide credit.

You may ask to access, correct or delete personal information we hold about you, subject to legal requirements.

3. Who this policy applies to

This policy applies to:

people who create or use an account;
parents, guardians or trusted adults using Coach features;
people who contact our support team;
visitors to our website; and
participants in employer, education or community programs using the Service.

The Service is intended for people aged 15 years and older.

If we have reason to believe that a person under 15 has created an account, we may suspend the account and take reasonable steps to resolve the issue.

4. Young people and privacy

We design the Service so that important privacy choices can be understood by a young person.

Where practical, we will:

use age bands instead of collecting a full date of birth;
explain important privacy choices in clear language;
use privacy-protective defaults for young users;
collect only information reasonably needed for the Service;
limit what Coaches can see; and
avoid behavioural advertising based on financial information.

If we reasonably believe that a user cannot understand a privacy decision they are being asked to make, we may ask a parent or guardian to assist or provide consent where appropriate.

5. Personal information we collect

The information we collect depends on how you use the Service.

5.1 Account and profile information

This may include:

name or display name;
email address;
mobile number, if provided;
age band or age-related eligibility information;
preferred language and timezone;
profile settings;
authentication identifiers; and
subscription or entitlement status.

5.2 Employment and income information

You may provide information such as:

employer name;
role or job title;
hourly rate;
typical hours;
shifts or hours worked;
pay frequency;
expected payday;
gross pay;
net pay;
tax withheld;
superannuation amounts;
allowances; and
deductions.

5.3 Payday and financial-planning information

This may include:

Payday Rules;
NOW, NEXT, BUILD and FUTURE allocations;
savings goals;
contribution history;
target dates;
hypothetical investment assumptions;
illustrative financial projections; and
progress and achievement information.

5.4 Payslips and documents

If you choose to upload, share or forward a payslip or similar document, we may process it to identify information such as:

employer;
pay period;
hours;
pay rate;
gross pay;
net pay;
PAYG withholding;
superannuation;
allowances; and
deductions.

Where automated extraction is used, we may ask you to confirm the extracted information before it is treated as accurate.

In the current app, when you scan a payslip with your phone's camera or choose a photo of one, the photo is read on your device and deleted straight after. The photo itself is not uploaded to our servers or kept. Text you paste in is handled the same way: it is read on your device and not stored. We save only the figures you check and confirm, such as employer, pay period, gross and net pay, tax withheld, superannuation, hours and pay rate. You can view, download or delete these figures at any time.

Please use only your own payslip, or one you are authorised to provide.

We do not intend to collect or retain Tax File Numbers in the MVP. If a document contains a TFN or another government identifier that we do not need, we will seek to avoid retaining it and may redact, ignore or delete it where reasonably practicable.

5.5 Goals and preferences

This may include:

savings goals;
goal amounts;
selected allocation percentages;
financial priorities;
learning preferences;
notification preferences; and
learning progress.

5.6 Coach information

If you invite or connect a Coach, we may collect:

the Coach's name;
the Coach's email or account identifier;
relationship status;
permissions you grant; and
high-level progress information shared with the Coach.

A Coach does not automatically receive detailed purchase, merchant or transaction information.

5.7 Device, technical and usage information

We may collect information such as:

device type;
operating system;
app version;
approximate region;
device or installation identifiers;
crash and diagnostic information;
screens and features used;
notification interactions; and
session and performance information.

We aim to keep unnecessary financial values, payslip content and transaction descriptions out of analytics systems.

5.8 Support communications

If you contact us, we may collect your contact details, the contents of your message, attachments and information needed to investigate and respond.

5.9 Subscription and payment information

If you purchase a subscription, payment may be processed by Apple, Google, Stripe or another payment provider.

We generally do not receive your full payment-card number. We may receive subscription status, product or plan, purchase date, renewal date, receipt or transaction identifiers and payment status.

6. How we collect information

We may collect information:

directly from you;
when you create or update an account;
when you enter a pay event;
when you create goals or Payday Rules;
when you upload, share or forward a payslip;
from a Coach where you have authorised the relationship;
from an employer, school or program partner where you have been informed of the collection and it is permitted;
from authentication providers you choose to use;
automatically through the app or website; and
from connected services that you separately authorise.

Before enabling Open Banking, payroll, investment, money-movement or other connected financial integrations, we will provide any additional notices and consents required for those features.

7. Why we use personal information

We may collect, hold, use and disclose personal information to:

create and secure your account;
provide the Service;
calculate Payday allocations you configure;
track goals and progress;
provide financial education;
generate illustrative scenarios;
process payslips you choose to provide;
estimate expected pay;
send payday, goal and service notifications;
provide Coach features;
manage subscriptions and entitlements;
provide customer support;
prevent misuse, fraud or security incidents;
diagnose errors and improve reliability;
understand and improve the Service;
comply with legal obligations;
enforce our Terms of Use; and
protect users, our business and others.

We do not use detailed financial information to build advertising profiles for third-party targeted advertising.

8. Automated systems and AI

We may use software, algorithms or artificial intelligence to assist with functions such as:

extracting information from payslips;
identifying likely income information;
generating educational explanations;
calculating projections;
suggesting relevant learning content;
identifying errors or unusual data; and
supporting customer service.

Automated tools can produce inaccurate results. Important financial information extracted by automated tools should be presented for user confirmation where appropriate.

The current Service does not use AI to independently execute investments, move money, make lending decisions or make investment decisions for you.

If we introduce automated systems that make or materially inform decisions that could significantly affect a person's rights or interests, we will update our notices and privacy practices as required by applicable law.

9. Coach privacy

Coach features are designed for support, not surveillance.

Unless the user expressly enables additional sharing, a Coach may receive only limited information such as:

whether a Payday was completed;
high-level goal progress;
learning progress; and
milestone information.

We do not intend for Coaches to automatically receive:

merchant-by-merchant spending;
exact purchase locations;
detailed transaction descriptions; or
private support communications.

Users can review and change Coach permissions within the Service, subject to any lawful age-appropriate safeguards.

10. When we share personal information

We may share personal information with the following types of recipients.

Service providers

Providers that help us operate the Service, including cloud hosting, authentication, analytics, crash reporting, notifications, subscription management, payment processing, email delivery, document processing, customer support, security and AI services where enabled.

We aim to provide each provider only the information reasonably necessary for its role.

Coaches

Only where the user has established a Coach relationship and according to the applicable permissions.

Employers, schools and program sponsors

Where an employer, school, TAFE, government program or other organisation provides access to the Service, we may provide limited administrative, entitlement, de-identified or aggregated program information.

We will not provide detailed personal financial information merely because an organisation pays for access unless the user has been clearly informed and the disclosure is lawful and authorised.

Professional advisers and corporate transactions

We may disclose information to professional advisers or as reasonably necessary in connection with financing, acquisition, merger, restructure or sale, subject to appropriate confidentiality and legal requirements.

Legal and safety reasons

We may disclose information where required or authorised by law, court order or regulatory requirement, or where reasonably necessary to protect legal rights, safety or security.

11. We do not sell personal information

We do not sell personal information or financial information to data brokers, advertisers or other third parties.

We do not use detailed financial behaviour to target third-party advertising.

12. Overseas storage and disclosure

Some service providers may process or store information outside Australia.

Before public release, replace this paragraph with the confirmed countries in which overseas recipients are likely to be located where practicable. [Insert confirmed countries — likely examples may include the United States and countries in the European Economic Area, depending on selected providers.]

Where required, we will take reasonable steps to ensure overseas handling of personal information is consistent with applicable Australian privacy requirements.

13. Data security

We take reasonable technical and organisational measures designed to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.

Measures may include secure network connections, authentication, access controls, restricted administrative access, database security rules, secure secrets management, monitoring, logging, backups, security testing and vendor review.

No online service can guarantee absolute security. Users are responsible for keeping their account credentials and devices secure.

14. Data breaches

We maintain processes for identifying and responding to suspected data breaches.

Where required by law, we will notify affected individuals and the Office of the Australian Information Commissioner of an eligible data breach.

15. How long we keep information

We keep personal information only for as long as reasonably necessary for the purposes described in this policy, including to provide the Service, maintain history requested by the user, meet legal or accounting requirements, resolve disputes, prevent fraud and maintain legitimate business records.

When information is no longer required, we will take reasonable steps to delete or de-identify it unless we are legally required or permitted to retain it. Backups may take additional time to cycle out of our systems.

16. Access and correction

You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

Where available, common profile information can be updated directly in the Service.

For other requests, contact privacy@lokdmoney.com. We may need to verify your identity before actioning a request.

17. Account deletion

You may request deletion through Settings → Privacy → Delete account or by contacting privacy@lokdmoney.com.

Deleting an account does not necessarily require us to immediately delete information we are legally required or permitted to retain. We will explain any material retention that applies.

18. Marketing and notifications

Service messages needed to operate or secure your account are different from marketing.

Where required, marketing communications will include a simple way to unsubscribe.

Optional push notifications can be controlled through the Service or your device settings. Some security, account and legal notices may still be necessary.

19. Connected financial services

The MVP does not require Open Banking, execute investments or automatically move money.

If we later add Consumer Data Right/Open Banking, payroll connections, bank transaction feeds, money movement, investment accounts or superannuation connections, we will provide additional information about how data is collected and used and obtain any additional permissions or consents required before activation.

20. Privacy complaints

If you have a privacy concern or believe we have not handled your personal information appropriately, contact privacy@lokdmoney.com.

Please provide enough information for us to understand and investigate the issue. We will investigate and aim to respond within a reasonable period.

If you are not satisfied with our response, you may be able to complain to the Office of the Australian Information Commissioner (OAIC).

21. Changes to this policy

We may update this Privacy Policy as the Service develops or legal requirements change.

If a change materially affects how we handle personal information, we will provide reasonable notice through the Service, email or another appropriate method.

The current version will always show its effective date.

22. Contact us

[Company Legal Name] Pty Ltd
Trading as LOKD money

Privacy: privacy@lokdmoney.com
Support: support@lokdmoney.com
Address: [Australian business address]