How Fluenccy collects, uses and protects personal information. Last updated 26 August 2026.
This Privacy Policy is made on behalf of Fluenccy Pty Ltd (ABN 82 641 857 169) and its related body corporates (“Fluenccy”, “we”, “us”, “our”). It explains what personal information we collect, why, how we use, hold and disclose it, how you can access or correct it, how to make a complaint, and — because our clients are businesses — how we handle information about the individuals connected with a client's account who are not themselves our client.
Fluenccy is committed to protecting personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth). Where we handle personal information about individuals in the European Union or United Kingdom, we also comply with the GDPR (see section 11).
“Personal information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not. It includes things like your name, address, date of birth, account details, and information about transactions made through your account.
When you use the Fluenccy platform, we generate analytics and insights from your account and transaction data — for example, foreign exchange exposure analysis, rate and market benchmarking, and reporting designed to help you manage currency risk (Analytics Outputs).
We may also compile Aggregated Data — information drawn from multiple clients' transactions that is combined or de-identified so that no individual client or person can be identified from it — and use it for benchmarking, improving our products, and market commentary. A corporate client cannot identify you personally from Aggregated Data we share with them.
Because our clients are businesses, opening an account or applying for credit with us — including through our banking and credit partners — requires us to collect information about individuals connected with the account who are not themselves the applicant. This can include the name, date of birth and residential address of directors, beneficial owners and authorised signatories or users.
Where this information is collected from your business rather than directly from the individual concerned, Australian Privacy Principle 5 requires us to take reasonable steps to notify that individual (or otherwise ensure they are aware) of the matters this policy covers, including who we are, why we collect the information, and their rights to access and correct it.
We collect information directly from you — when you apply to become a client, use our services, complete a form, or contact us. We may also collect information indirectly, from third parties (for example your representatives, our banking partners, or publicly available sources such as company registers) or through cookies on our website (see section 7).
We may use your personal information to send you information about products and services that may be relevant to you. You can opt out of marketing at any time using the unsubscribe mechanism in any marketing communication, or by contacting us (see section 16). We will not disclose your information to other organisations so that they can market to you directly.
When you visit our website, we may collect information such as your browser type, operating system, and the site you visited immediately before ours. We use this information, in aggregate, to understand how people use our site and to improve it.
We may use cookies — small files that let our website recognise you when you return and remember details about your visit. Most browsers accept cookies by default; you can choose to reject them in your browser settings, though this may limit some features of our website.
Where we disclose your credit-related personal information to a credit reporting body, we are required by law to notify you of certain matters, set out below. We primarily deal with CreditorWatch, a credit reporting body operating in Australia. You can contact CreditorWatch by phone on 1300 50 13 12, or by writing to GPO Box 276, Sydney NSW 2001.
CreditorWatch may include the credit-related personal information we provide in reports to other credit providers, to help them assess your creditworthiness. If you fail to meet payment obligations owed to us, or we believe you have committed a serious credit infringement, we may disclose this to CreditorWatch.
Under the Privacy Act, you may ask a credit reporting body not to use your credit information for “pre-screening” direct marketing assessments, free of charge. If you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud, you can ask a credit reporting body to place a 21-day “ban period” on use or disclosure of your credit reporting information, which can be extended on request.
We take appropriate steps to protect personal information that is processed or stored outside Australia, including by our overseas service providers and banking partners. Where practicable, we will disclose the countries to which your information may be sent.
If you are an individual in the EU or UK, you have rights under the GDPR in relation to your personal information, including the right to be informed how it's used, to access a copy of it, to correct or delete it, to restrict or object to its processing, and to object to automated decision-making. You can exercise these rights by contacting us (see section 16); we may ask you to verify your identity first.
We apply a framework of policies, procedures and technical measures designed to protect your personal information, and our staff are subject to confidentiality obligations. As transmission over the internet can never be guaranteed completely secure, we cannot guarantee the security of information transmitted to us electronically, though we take reasonable steps to protect it.
We keep personal information only for as long as it's needed for the purpose we collected it, or as required by law. In most cases, given our record-keeping obligations under anti-money laundering law, this means retaining records for 7 years from their creation, or 7 years from when your account is closed.
You can ask us for an overview of the personal information we hold about you, and ask us to correct it if it's wrong. If we've shared incorrect information with a third party, we'll notify them of the correction too. You can deal with us anonymously or under a pseudonym in some circumstances, though given the nature of our services (and our AML/CTF obligations) this won't usually be possible once you become a client.
If you have a complaint — whether about how we've handled your personal information, or about our services, a credit decision, or a transaction — please contact us using the details in section 16, with as much detail as you can give us about your concern.
We will acknowledge your complaint promptly and aim to investigate it and provide you with a decision within 30 days of receiving it, in line with the internal dispute resolution timeframes required of financial services providers under ASIC's Regulatory Guide 271. If we need more time, we will let you know why and give you a revised timeframe.
If you're not satisfied with our response, or we haven't heard back within that timeframe, where you take your complaint next depends on what it's about:
Complaints about how we've handled your personal information can be taken to the Office of the Australian Information Commissioner (OAIC):
Complaints about our services, a credit decision, or a transaction can be taken to the Australian Financial Complaints Authority (AFCA), our external dispute resolution scheme:
You can contact us about this policy, to make an access or correction request, to opt out of marketing, or to make a complaint:
This policy was last updated on 26 August 2026. We may update it from time to time to reflect changes in the law or in how we handle personal information. The current version is always available at fluenccy.com/legal/privacy-policy.