Privacy Policy - ELRC TRADING

This Privacy Policy describes how ELRC TRADING Pty Ltd (ACN 686 501 995) ("ELRC", "we", "us", or "our") collects, uses, discloses, and protects your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. Information We Collect

We may collect the following types of information:

Corporate Information: Company name, ACN/ABN, registered address, ASIC extracts, and business activity details.
Personal Information of Directors/Officers: Full names, dates of birth, residential addresses, government-issued identification documents, and contact details.
Ultimate Beneficial Owner (UBO) Information: Identity and ownership details of individuals who ultimately own or control the client entity.
Transaction Information: Details of digital currency exchange and remittance transactions.
Communication Records: Emails, phone records, and correspondence related to our services.
Website Usage Data: IP addresses, browser type, pages visited, and other analytics data.

2. How We Use Your Information

We use collected information for the following purposes:

Verifying identity and conducting KYB due diligence;
Providing our OTC exchange and remittance services;
Complying with AML/CTF obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
Submitting reports to AUSTRAC as required by law;
Detecting and preventing fraud, money laundering, and terrorist financing;
Communicating with you about our services;
Improving our website and services; and
Meeting other legal and regulatory obligations.

3. Legal Basis for Processing

We process personal information on the following legal bases:

Compliance with legal obligations (AML/CTF Act, AUSTRAC reporting requirements);
Performance of our contractual obligations to clients;
Legitimate business interests; and
Consent, where applicable.

4. Disclosure of Information

We may disclose your information to:

AUSTRAC: As required under the AML/CTF Act for suspicious matter reports, threshold transaction reports, and other mandatory reporting;
Law Enforcement: In response to lawful requests from Australian or international law enforcement agencies;
Service Providers: Third-party service providers who assist us in operating our business (e.g., ComplyAdvantage for sanctions screening), subject to appropriate confidentiality agreements;
Professional Advisors: Legal, accounting, and auditing professionals; and
As Required by Law: Where disclosure is required or authorised by Australian law.

5. Data Security

We implement appropriate technical and organisational measures to protect personal information against unauthorised access, loss, or misuse. These measures include encryption, access controls, secure storage, and regular security assessments.

6. Data Retention

We retain personal information for as long as necessary to fulfil the purposes outlined in this policy, and as required by law. Under the AML/CTF Act, certain records must be retained for a minimum of seven (7) years after the end of the client relationship.

7. Your Rights

Under the Australian Privacy Principles, you have the right to:

Access the personal information we hold about you;
Request correction of inaccurate or incomplete information;
Lodge a complaint about our handling of your personal information.

Please note that certain information must be retained under the AML/CTF Act and may not be deleted upon request.

8. Cookies and Website Analytics

Our website may use cookies and analytics tools to improve user experience. You can control cookie settings through your browser preferences.

9. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised date.

10. Contact Us

For privacy-related enquiries or to exercise your rights, please contact our Privacy Officer:

ELRC TRADING Pty Ltd
Email: compliance@elrctrading.com
Phone: 03 8658 7856
Address: Suites 101 & 101A, 486 Whitehorse Road, Surrey Hills VIC 3127, Australia

Last updated: February 2026 | Document Reference: ELRC_TRADING_PRIVACY_POLICY v1.0