Privacy Policy

1. What is a Privacy Policy?

1.1 This Privacy Policy ("Policy") is provided in accordance with the Australian Privacy Act 1988 (Cth) ("Privacy Act"), the Australian Privacy Principles (APPs), and the New Zealand Privacy Act 2020 ("NZ Privacy Act") (if applicable). It outlines how Damasca Pty Ltd (ACN 641 281 307) trading as Localcoin ("we", "us", or "our") collects, stores, uses, discloses, manages, and protects your Personal Information.

1.2 Website: This refers to:

• Australia: https://localcoinatm.com/en-au/
• New Zealand: https://localcoinatm.com/en-nz/
• And all sub-domains.

1.3 By:

• (a) Using and engaging our services generally;
• (b) Accessing, subscribing to, downloading, or using content or functions of our Website or kiosks;
• (c) Requesting information, making enquiries, providing feedback, or using our services;
• (d) Providing or consenting to the collection of your Personal Information;

You acknowledge and consent to our collection, use, storage, and disclosure of your Personal Information in line with this Policy and applicable laws.

1.4 If you do not agree with this Policy, we will not be able to provide you with our services and you should not provide us with your Personal Information.

2. What is Personal Information?

2.1 In line with the Privacy Act, Personal Information is defined as:

“Information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) Whether the information or opinion is true or not; and (b) Whether the information or opinion is recorded in a material form or not.”

3. What kinds of Personal Information might we collect and hold?

The type of information we collect depends on your relationship with us (e.g. customer, job applicant, volunteer, or website visitor).

3.1 Customers and Prospective Customers

We may collect:

• (a) Name, address, email, phone number, and identification information
• (b) Age, date of birth, occupation, nationality, marital status
• (c) Government identifiers (e.g. Medicare)
• (d) Identity documents (e.g. driver’s licence, passport)
• (e) Records of interaction (e.g. enquiries, complaints, feedback)
• (f) Digital data (e.g. IP address, device details, location)
• (g) Call recordings (with notification)
• (h) Usage data (e.g. transactions, service usage)
• (i) Information required for requested services
• (j) Photographs and selfie verification images
• (k) Device location for service functionality
• (l) Any other directly provided information

Sensitive Information

May include racial origin, political beliefs, sexual orientation, health data, criminal records, and biometric information.

We only collect Sensitive Information:

• When necessary and directly related to our services
• With your explicit consent
• Where required or permitted by law

You may request destruction or de-identification of your Sensitive Information unless we are legally required to retain it.

3.2 Prospective Employees, Volunteers, or Applicants

We collect:

• Name, contact info, qualifications, employment history
• Tax File Number (TFN) or IRD Number, superannuation info
• Background checks (e.g. for working with children)
• Referee or recruiter-sourced information

TFNs are managed in accordance with the Privacy (Tax File Number) Rule 2015 and Taxation Administration Act 1953.

3.3 Marketing, Research, Website Visitors

You can browse our website anonymously. If you identify yourself (e.g. through an enquiry), your Personal Information is subject to this Policy.

4. How do we collect Personal Information?

We collect it:

• (a) Directly from you (e.g. via forms, calls, emails)
• (b) Through service provision
• (c) Through participation in marketing activities
• (d) From authorised third parties
• (e) From publicly available sources (e.g. social media)

5. How do we hold and secure your Personal Information?

• 5.1 Stored both digitally and in hard copy
• 5.2 Digital info secured via password-protected systems and secure networks
• 5.3 Data stored with providers like Google Cloud (primarily in Australia)
• 5.4 International storage may occur (e.g. Canada); NZ data is managed per NZ Privacy Act
• 5.5 Secure destruction or de-identification when no longer required
• 5.6 Regular audits of compliance

6. Why do we collect, hold, use and disclose Personal Information?

We collect it to:

• (a) Provide services or information
• (b) Respond to enquiries
• (c) Verify identity and comply with AML/CTF laws
• (d) Maintain service consistency and improve our services
• (e) Tailor services
• (f) Notify of changes
• (g) Conduct internal business processes
• (h) Market our services
• (i) Publish testimonials
• (j) Comply with legal/regulatory obligations
• (k) Investigate legal matters
• (l) Prevent fraud
• (m) Protect business risks
• (n) Corporate governance and record keeping

We do not sell your information to third parties for their direct marketing.

7. What do we do with your Personal Information?

We may:

• (a) Use it as outlined above
• (b) Store it securely
• (c) Share with affiliated entities or business partners
• (d) Provide to service providers (e.g. IT, legal, accounting)
• (e) Disclose where required by law (e.g. regulators)

8. Do you use my information for Direct Marketing?

Yes. We may use it to promote our services.

If you wish to opt-out, contact us or use the unsubscribe option in our communications. We’ll remove you from marketing lists as soon as practicable.

9. What about Cookies, Pixels, and Analytics?

• 9.1 We use cookies, pixels, and analytics tools
• 9.2 They help us recognize returning visitors, personalise content, and optimise experience
• 9.3 We typically do not collect personal info through them, but we may collect your IP and device details
• 9.4 You can configure your browser to accept or reject cookies

10. Do we ever send your information overseas?

Yes. Your information may be stored in:

• Cloud platforms like Google Suite (e.g. in the USA and Canada)
• Social media or websites hosted overseas

We comply with all relevant data transfer laws.

11. Can you access your Personal Information or request correction?

• 11.1 Yes, contact us to make a request
• 11.2 We must verify your identity; an administrative fee may apply
• 11.3 We respond within 20 working days
• 11.4 Requests may be denied if: (a) Frivolous or vexatious (b) Identity not verified (c) Admin fee not paid
• 11.5 You may also request correction of errors or have a statement attached noting disputed corrections

12. Can you remain anonymous or use a pseudonym?

Yes, but it may limit our ability to:

• Provide accurate services
• Investigate issues or complaints

13. Sale or Transfer of Business

If we sell or restructure, your Personal Information may be transferred. You will be notified via:

• (a) Our website
• (b) Social media
• (c) Email or text
• (d) Regular mail

You consent to these forms of notice.

14. Can this Policy change?

Yes. Changes will be:

• Highlighted in yellow for 14 days
• Posted on our website
• Communicated by other reasonable means (e.g. email)

Please check regularly for updates.

15. Questions or Complaints

Contact us at: 📧 [email protected]

We aim to respond within 30 days, unless the complaint is frivolous, vexatious, or unverified.

If unsatisfied, you may contact:

• Australia: Office of the Australian Information Commissioner
• New Zealand: Office of the NZ Privacy Commissioner

LAST UPDATED: MARCH 19, 2025