Privacy Policy

1. We respect your privacy

(a) TWMT Pty Ltd ACN 621 581 584 (“TWMT”, “we”, “us”, or “our”) respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and treat your personal information.

(b) We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) ("Privacy Act").

(c) "Personal information" is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.

(d) You may contact us in writing at C/- MGISQ, Level 1, 200 Mary Street, Brisbane 4000 for further information about this Privacy Policy.

(e) This Privacy Policy is intended to operate in conjunction with our Website Terms and Conditions, and adopts the definitions and terms set out in that document unless otherwise specified. 

2. What personal information is collected

(a) TWMT will, from time to time, receive and store personal information you submit to our website, provided to us directly or given to us in other forms.

(b) You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order.

(c) We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

(d) Additionally, we may also collect any other information you provide while interacting with us.

3. Who we collect personal information about

(a) The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:

(i) customers;

(ii) potential customers;

(iii) visitors to the Website; and

(iv) service providers.

4. How we collect your personal information

(a) TWMT collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our Website and when we engage in business activities with you. We may receive personal information from third parties such as identity verification services or referrers. If we do, we will protect it as set out in this Privacy Policy.

(b) By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.

(c) We will not collect sensitive information about you without your consent, unless an exemption in the Australian Privacy Principles applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to unlawful activity of serious misconduct.

(d) We will not give you the option of dealing with us anonymously, or using a pseudonym if it is illegal or impractical for us to deal with individuals who are not identified.

(e) We may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to our purposes for collecting personal information. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.

5. How we use your personal information

(a) TWMT may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services and opportunities available to you.

(b) TWMT will use personal information only for the purposes that you consent to. This may include to:

(i) provide you with products and services during the usual course of our business activities;

(ii) administer our business activities;

(iii) manage, research and develop our products and services;

(iv) provide you with information about our products and services;

(v) communicate with you by a variety of measures including, but not limited to, by telephone, email, sms or mail;

(vi) investigate any complaints;

(vii) comply with relevant laws, regulations and other legal obligations; and 

(viii) for market research to help us improve the services to our customers and enhance our business and performance

(c) We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.

(d) If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our Website. We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.

(e) Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.

6. Disclosure of your personal information

(a) TWMT may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.

(b) If you ask us to, we will share your personal information with your financial adviser, or other professional and business advisers (such as lawyers and auditors). This could include information held in your Account available for viewing by your advisers through the Website.  

(c) If we do disclose your personal information to a third party, we will protect it in accordance with this privacy policy during the disclosure process.

7. Direct marketing

(a) We and/or our carefully selected business partners may send you direct marketing communications and information about our products and services, special offers, promotions and events that may be of interest to you. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Privacy Act. 

(b) You may opt-out of receiving marketing materials from us by following the unsubscribe link in any email or by contacting us at [email protected]. 

(c) You cannot opt out of receiving important service-related communications (e.g., security alerts, changes to terms).

8. Hosting and International Data Transfers

(a) Information we collect may from time to time be stored, processed or transferred between our offices or service providers located in Australia or overseas. Any overseas disclosures are conducted in accordance with Australian Privacy Principle 8. We take reasonable steps to ensure that personal information disclosed offshore is handled in a way that is consistent with the Privacy Act.

(b) You acknowledge that where you or an authorised adviser export or transmit your personal information to third-party systems outside our platform (such as accounting software or tax tools), TWMT is not responsible for how those systems handle your data.

(c) You acknowledge that personal data that you submit for publication through our Website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

9. Security of your personal information

(a) TWMT is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

(b) Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the Privacy Act and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.

(c) The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

(d) If you grant Adviser Access or use platform integrations that transmit your data externally, you acknowledge that such actions may fall outside of TWMT’s control. While TWMT applies security controls to our systems, we cannot guarantee the security of information once it has been accessed or exported by an authorised third party.

10. Access to your personal information

(a) You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected].

(b) We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law.

(c) We will require identity verification and specification of what information is required. An administrative fee may be charged which includes the cost of our staff to compile the records requested, any postage charges and development costs for any bespoke data requests. 

11. Data Retention

We retain your personal information only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law. This may include retaining your records to comply with anti-money laundering laws, financial reporting obligations, or audit requirements. Once your information is no longer required, we will securely delete or de-identify it.

12. Complaints about privacy

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to [email protected]. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

13. Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

14. Website

When you come to our Website (www.twmt.com.au, coinstash.com.au, coinstash.io), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

15. Cookies

We may from time to time use cookies on our Website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our Website. Our Website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.

You can manage cookie preferences through your browser. By continuing to use our Website, you consent to our use of cookies, unless you disable them.

16. Third party sites

Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that TWMT is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our Website, to read the privacy statements of each and every website that collects personal identifiable information.

Last updated: 16 July 2025

Updated on: 16/07/2025