Financial Services Guide

Service provider: SendFX Limited ACN 617 647 220 (‘Send’)
Contact details: Registered office: 11/13 Hickson Road, Dawes Point NSW 2000 Tel: +61 7 56 195 700
Email: info@sendpayments.com
Website: www.sendpayments.com
Australian Financial Services Licence: 509635
FSG version: 1.1 FSG Issue date: 29 March 2022

Purpose
This Financial Services Guide contains important information to assist you in making an informed decision about whether to utilise our Services. The purpose of this guide is to provide you with material information before you enter into a transaction with Send for our Services, including the following information:

If you need further information, please contact us at info@sendpayments.com. Send’s services Australian Financial Services Licence (‘AFSL’) Authorisation Send is the holder of an AFSL (licence number 509635), and is authorised pursuant to this licence to carry on a financial services business to:

  1. provide general financial product advice for the following classes of financial products:
  2. deposit and payment products limited to non-cash payment products; and
  3. foreign exchange contracts;
  4. deal in a financial product by:
  5. issuing, applying for, acquiring, varying or disposing of a financial product in respect of the following classes of financial products:

(A) deposit and payment products limited to non-cash payment products; and

(B) foreign exchange contracts; and

  1. applying for, acquiring, varying or disposing of a financial product on behalf of another person in respect of the following classes of products:

(A) deposit and payment products limited to non-cash payment products; and

(B) foreign exchange contracts where money is made available or cause to be made available to a person nominated by the client; and

  1. make a market for foreign exchange contracts – limited to foreign exchange contracts where money is made available or caused to be made available to a person nominated by the client;

to retail and wholesale clients.

Send’s Services

Send provides the following services:

Methods of providing Services

When utilising our Services, we may accept instructions from you in person, by telephone, online via the Send platform, or by another method mutually agreed by us, including via any Send[1]developed products such as an API.

Who do we act for?

Unless advised to the contrary, we act for you as principal when providing the Services. Where a client is made up of more than one person, we act for those persons jointly unless mutually agreed to the contrary.

Documentation

Send will provide important documentation to you to assist in the provision of our Services and to help you make informed decisions. These may include:

Copies of our Terms and Conditions, Product Disclosure Statement and this Financial Services Guide will be available on our website, or by email request to info@sendpayments.com.

General advice warning

We will only ever provide you with general advice regarding any transaction you enter into with Send. This advice will not take into account your personal situation and objectives or your specific financial circumstances.

Accordingly, you will need to make your own assessment as to whether our Services are appropriate for you. We recommend that you take all necessary steps to understand the risks and implications of utilising our Services and obtain independent advice from a licenced professional regarding the suitability of our Services for you prior to retaining Send’s Services.

While Send will take all reasonable steps to ensure the information and general advice provided is accurate and reliable, Send makes no representations about the accuracy, completeness or currency of any information or general advice given. No responsibility is assumed regarding the accuracy, completeness or currency of any information or general advice provided, by Send or by its directors, employees, officers, agents, associates, contractors or sub-contractors.

Send’s record keeping obligations

Send will maintain accurate records of all transactions entered into and any advice given. Send may record telephone calls and retain those recordings in accordance with our call recording and data retention policies. These recordings may be used for training purposes and in the event that there is a dispute with you or otherwise in accordance with our Privacy Policy.

Remuneration, commission and benefits

Send’s income

Send is generally remunerated for its services from profit generated from the spread applied to foreign currency exchange transactions (‘margin’). That is, the difference between the wholesale market rate that we purchase from our liquidity providers, and the trade price which is then sold and provided to you. Send’s income is incorporated into the exchange rates quoted to you and is not an additional fee.

Our margin and subsequent profit amount will vary depending on the currency, the market, and arrangements we enter into with third parties, including our liquidity provider/s.

Third party transaction and processing fees

While Send does not charge any fees for the use of its Services, in some instances transaction and processing fees may be charged by third party banks. For example, where payment failure or intermediary bank fees are charged. These fees are set and charged by the third-party provider without notice to Send and will be passed on to you.

Third party transactions and processing fees are outside Send’s control will vary depending on the relevant charge and the third party.

In addition to the above, Send may from time to time and at its sole discretion integrate certain pay-in methods which attract a third-party fee for use. These fees are the cost charged by the third-party pay-in service provider to utilise that pay-in method and may be passed on to you. These fees will vary but are typically a set fee or a percentage of the value transferring (or a combination of both) – Send does not set the fees or make any profit on the fees. Send will display the fee to you at the point of transfer so you can decide whether to proceed with that pay-in method. You can opt out of paying these fees by utilising a pay-in method that does not attract fees (for example by paying via payID).

Commissions and Remunerations paid by us

Our staff and representatives receive remuneration from us and may receive commission for assisting you with providing our Services. The calculation of commission varies depending on the staff member or representative, their role and experience.

Referral Agreements

We may enter into referral agreements with partners and pay commission to those partners in respect of referrals made by them. Commission structures will vary depending on the partner, but will typically be calculated as a percentage of the net profit generated by each transaction made by a client referred by the partner.

Particulars of commissions

You may request further particulars of commission or other benefits payable in respect of our Services, however this request must be made within a reasonable time after being given this Financial Services Guide and before any Service identified in this guide is provided to you.

Conflict of interest disclosure

Subject to any further disclosures outlined in our Product Disclosure Statement or this FSG, we do not have any relationships or associations which might influence us or result in a conflict when providing you with our Services.

Professional indemnity insurance

Send’s professional indemnity insurance complies with the requirements for compensation arrangements outlined under section 912B of the Corporations Act 2001 (C’th), and applies to claims made for loss or damage suffered because of legislative breaches by Send or its representatives (including representatives that no longer work for Send).

Privacy

Your privacy is important to us. We are committed to complying with our legislative obligations under the Privacy Act 1988 (C’th) and all other relevant regulations, and we have implemented policies to safeguard your information, including secure data storage and access procedures, and technology[1]based security and access mechanisms.

By agreeing to our Terms and Conditions, you agree and consent to our use of your personal information in the manner outlined under our Privacy Policy, which is available on our website. Send will not otherwise disclose your personal information without your consent.

If you have any concerns regarding the use of your Personal Information or our Privacy Policy, or would like to receive a copy of our Privacy Policy please contact us at info@sendpayments.com.

Complaints handling

We have an internal dispute resolution process in place to handle any concerns or complaints that you may have as quickly and fairly as possible.

In the first instance, any concerns or complaints you have should first be raised with your usual contact at Send. If the matter is not resolved to your satisfaction, you may escalate your complaint in writing to our management team who will conduct an investigation and attempt to resolve the matter or provide a final response within 30 days, or such other time period that is reasonably necessary having regard to the circumstances.

If, after 30 days you are not satisfied with the outcome of our internal investigation you have the right to complain to the Australian Financial Complaints Authority (‘AFCA’). AFCA is an approved external dispute resolution scheme of which Send is a member, and provides an independent financial services dispute resolution process which is free for consumers.

You can contact AFCA as follows: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001 Tel: 1800 931 678 (free call) Email: info@afca.org.au Website: www.afca.org.au