Treasury Technologies

1. Introduction and scope

These Website Terms of Use and Privacy Policy (the “Terms”) govern your access to and use of the website available at www.treasury.tech, including any subdomains, pages, content, and features made available through it (together, the “Website”). They also apply to communications initiated via the Website, such as contact forms, enquiries, and requests for information.

These Terms constitute a legally binding agreement between you and the Website Operator (as defined below) in relation to the Website.

Important: These Terms do not govern, and do not create any contractual relationship for the provision of regulated or other commercial services by any member of the Treasury Group. Any such services are provided only under a separate written agreement entered into directly between you and the relevant Treasury Group entity (the “Service Agreement”, from time to time). The Service Agreement will set out the applicable terms (including fees, onboarding, KYC/AML requirements, transaction rules, liability, and governing law) for that specific service.

By accessing or using the Website, you confirm that you have read, understood, and agree to be bound by these Terms. If you do not agree, you must not use the Website.

2. Definitions

In these Terms:

“Treasury Technologies Ltd” means Treasury Technologies Ltd, Company No.: 15760089 (England and Wales), registered office: 52 New Crane Wharf, 8 New Crane Place, London, England, E1W 3TX.
“Treasury Technologies sp. z o.o.” means Treasury Technologies spółka z ograniczoną odpowiedzialnością, KRS No.: 0001102306 (Poland), registered office: Mokotowska 5/10, 00-640 Warsaw, Poland.
“Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with Treasury Technologies Ltd and/or Treasury Technologies sp. z o.o. (and “control” means the direct or indirect power to direct the management and policies of an entity, whether through ownership of voting securities, by contract, or otherwise).
“Treasury Group” means Treasury Technologies Ltd, Treasury Technologies sp. z o.o., and any Affiliate, which may change from time to time.
“Treasury” means the Treasury Group.
“Website Operator”, “we”, “us”, or “our” means the Treasury Group entity that operates the Website and is responsible for these Terms. Unless the Website clearly states otherwise, the Website Operator is Treasury Technologies Ltd.
“Group Services” means any services that may be offered from time to time by one or more members of the Treasury Group, including money remittance services and/or virtual asset services, but excluding the Website itself.
“Money Remittance Services” means services involving the acceptance, processing, and transmission of money (including cross-border remittances) and related payment services, from time to time, where offered by the relevant Treasury Group entity under a Service Agreement.
“Virtual Asset Services” means services involving virtual assets / virtual currencies (including exchange, brokerage, transfer, and related services, from time to time), where offered by the relevant Treasury Group entity under a Service Agreement.
“EEA” means the European Economic Area.
“Third-Party Providers” means third-party suppliers, partners and service providers engaged by any Treasury Group entity from time to time for operational, regulatory, risk-management, compliance or technical reasons, including (without limitation) banks, correspondent banks, payment processors, payout networks/agents, foreign exchange providers, liquidity providers, custodians or wallet infrastructure providers, identity verification and screening providers, fraud prevention providers, IT/hosting providers and professional advisers.

3. Using the Website

You may use the Website for lawful purposes, including to learn about the Treasury Group, to contact us, and to request information.

When using the Website, you must:

comply with all applicable laws and regulations;
provide accurate information if you submit an enquiry or otherwise interact with us through the Website;
not attempt to gain unauthorised access to the Website or any systems or networks connected to it;
not interfere with or disrupt the integrity or performance of the Website; and
not use the Website to distribute malware or to conduct any harmful or abusive activity.

The Website is intended for use by persons aged 18 or over. If you are under 18, you must not submit enquiries or provide personal information via the Website.

4. Availability of Group Services (summary information only)

The Treasury Group operates across multiple jurisdictions. Depending on the specific product, regulatory permissions, and your location, certain Group Services may be available only to:

customers in Australia (some services);
customers in the EEA (some services);
customers in the United Kingdom (some services); and/or
customers in other jurisdictions.

Accordingly, the availability and scope of any Group Services will depend on (i) the relevant Treasury Group entity providing the service, (ii) the jurisdiction in which you are located and/or established, and (iii) applicable laws, regulations, sanctions, and internal risk policies. Where we are permitted to do so, we will identify the contracting entity and the applicable service terms before you use a Group Service. Group Services (if and when provided under a Service Agreement) may be delivered in whole or in part through, or with the assistance of, Third-Party Providers for operational, regulatory, compliance, sanctions, risk-management or technical reasons.

Nothing on the Website constitutes an offer to provide Group Services in any jurisdiction where such services are prohibited or restricted. We may restrict, suspend, or refuse access to any Group Services at any time, including for legal, regulatory, sanctions, risk, or compliance reasons.

5. Treasury Group services overview (non-contractual)

The Website may include general descriptions of the Treasury Group’s activities. These descriptions are provided for information only and do not form part of any Service Agreement.

5.1 Money Remittance Services

Money Remittance Services (where offered) are provided by an Affiliate of the Treasury Group. The entity is registered with AUSTRAC as a remittance service provider and is subject to the Australian Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and related regulations.

Subject to applicable licences/registrations and the Service Agreement, Money Remittance Services may include, for example:

facilitating domestic and international remittances and payment transfers;
arranging the transmission of funds to beneficiaries through banking partners and payout networks;
where permitted, currency conversion as part of a remittance or payment transaction; and
compliance screening and transaction monitoring required by applicable AML/CTF laws.

5.2 Virtual Asset Services

Virtual Asset Services (where offered) may be provided by an Affiliate of the Treasury Group. The entity conducts activity in the scope of virtual currencies (including as a registered virtual asset service provider, where applicable).

Subject to applicable registrations and the Service Agreement, Virtual Asset Services may include, for example:

exchange between virtual assets and fiat currencies;
exchange between different virtual assets;
intermediation / brokerage services relating to virtual asset transactions;
transfer and execution of virtual asset transactions, including (where offered) through third-party liquidity providers; and
the operation of virtual asset accounts and/or wallets, where offered and permitted by law.

5.3 UK and EEA services

Where the Treasury Group offers services specifically in the UK and/or the EEA, those services will be provided by the relevant Treasury Group entity authorised or permitted to do so in the applicable jurisdiction, as identified in the Service Agreement.

5.4 Use of Third-Party Providers

To deliver Group Services efficiently and in compliance with operational and regulatory requirements, the relevant Treasury Group entity may provide parts of a Group Service through, or with the assistance of, Third-Party Providers. This may include (without limitation) banks and correspondent banks, payment processors, payout networks/agents, foreign exchange and liquidity providers, custodians or wallet infrastructure providers, identity verification and screening vendors, and other regulated or technical service providers.

Where you or your recipient uses a Third-Party Provider in connection with a Group Service (for example, a bank account, payout location, or a third-party wallet), that Third-Party Provider’s terms and privacy practices may also apply.

6. No service relationship; separate Service Agreements

Using the Website (including contacting us through the Website) does not:

create a customer relationship for any Group Services;
constitute an application for, or acceptance of, any Group Services; or
oblige any Treasury Group entity to provide any Group Services to you.

Any onboarding, acceptance, or provision of Group Services is subject to (among other things) eligibility, jurisdictional availability, successful completion of KYC/AML checks, and your acceptance of the relevant Service Agreement.

7. Intellectual property

Unless otherwise indicated, the Website and all content on it (including text, graphics, logos, software, and other materials) are owned by or licensed to the Treasury Group and are protected by intellectual property laws.

You are granted a limited, non-exclusive, non-transferable licence to access and use the Website for its intended purposes. You must not copy, modify, distribute, sell, lease, sublicense, reverse engineer, or create derivative works from the Website or its content, except to the extent permitted by applicable law or with our prior written consent.

8. Prohibited conduct

You must not:

use the Website in any way that is unlawful, fraudulent, or harmful;
use any robot, spider, scraper, or other automated means to access the Website without our prior written consent;
attempt to probe, scan, or test the vulnerability of the Website or any system or network connected to it;
introduce viruses, trojans, worms, logic bombs, or other material that is malicious or technologically harmful;
use the Website to transmit unsolicited or unauthorised advertising or promotional material (spam); or
misrepresent your identity or affiliation when submitting enquiries or communicating with us.

9. Third-party websites and services

The Website may contain links to third-party websites or services. Those third-party websites or services are not controlled by us. We are not responsible for their content, terms, privacy practices, or availability. Any link is provided for convenience only and does not constitute an endorsement.

10. Disclaimers and limitation of liability

The Website is provided on an “as is” and “as available” basis. To the maximum extent permitted by law, we disclaim all warranties and representations (express, implied, or statutory) in relation to the Website.

Nothing in these Terms excludes, restricts, or modifies any guarantee, right, or remedy you may have under the Australian Consumer Law or other applicable law that cannot be excluded, restricted, or modified by agreement.

To the extent permitted by law, we will not be liable for any indirect, incidental, special, or consequential loss (including loss of profits, loss of business, loss of goodwill, or loss of data) arising out of or in connection with your use of (or inability to use) the Website.

To the extent permitted by law, our total aggregate liability for claims arising out of or in connection with the Website or these Terms will not exceed AUD 100. This cap does not apply to liability that cannot be limited by law.

11. AML/CTF, sanctions and KYC

Although these Terms do not govern the provision of Group Services, the Treasury Group operates in regulated environments. If you apply for or use any Group Services, you acknowledge and agree that the relevant Treasury Group entity may be required to comply with anti-money laundering, counter-terrorism financing, sanctions, and other compliance obligations.

Accordingly, when you apply for or use Group Services, we may (to the extent permitted by law and as set out in the relevant Service Agreement):

conduct customer identification and verification (KYC) checks and ongoing monitoring;
screen you (and, where relevant, your directors, beneficial owners, authorised representatives, counterparties, and beneficiaries) against sanctions and restricted persons lists;
request additional information and documents, including source of funds and source of wealth information;
perform enhanced due diligence for higher-risk customers, products, or transactions;
delay, refuse, suspend, cancel, reverse, freeze, or block transactions, accounts, or access to services where required or permitted by law, or where we reasonably consider it necessary to manage legal, regulatory, sanctions, or financial crime risk;
report suspicious matters, transactions, or other information to competent authorities (including AUSTRAC or other regulators) where required; and
decline to onboard you or terminate a business relationship at any time in accordance with applicable law and the relevant Service Agreement.

In some circumstances, we may be legally restricted from providing reasons for certain actions (for example, where “tipping off” prohibitions apply).

12. Privacy Policy

12.1 Who is the data controller?

For the purposes of applicable data protection laws, the data controller for personal data collected through the Website is generally the Website Operator (Treasury Technologies Ltd), unless stated otherwise or unless your interaction clearly relates to another Treasury Group entity (for example, an enquiry directed specifically to Treasury Technologies sp. z o.o.).

For Group Services, the data controller will be the contracting entity identified in the relevant Service Agreement and/or in the service-specific privacy information provided to you.

12.2 What personal data we collect

We may collect the following categories of personal data through the Website:

Identity and contact data (such as your name, email address, telephone number, company name, job title, and country).
Enquiry data (the content of your messages, requests, and communications with us).
Technical and usage data (such as IP address, browser type, device identifiers, operating system, referral URLs, pages viewed, and time spent on the Website).
Cookie and similar technology data (see Section 12.11).

If you apply for or use Group Services, we may collect additional personal data for KYC/AML and service delivery purposes (for example, identification documents, transaction information, and other information required by law). Such collection and processing will be governed by the relevant Service Agreement and service-specific privacy information.

12.3 How we collect personal data

We collect personal data:

directly from you when you submit a form, send us an email, or otherwise communicate with us;
automatically when you use the Website (for example through server logs and cookies); and
from third parties where permitted by law (for example, analytics providers or fraud prevention services).

12.4 Purposes and legal bases for processing (GDPR/UK GDPR)

Where the EU GDPR or UK GDPR applies, we process personal data only where we have a lawful basis, including:

Contract: where processing is necessary to take steps at your request prior to entering into a contract, or to perform a contract (for example, a Service Agreement).
Legal obligation: where processing is necessary to comply with a legal obligation (including AML/CTF record-keeping and reporting obligations).
Legitimate interests: where processing is necessary for our legitimate interests (such as operating, securing, and improving the Website; responding to enquiries; preventing fraud; and ensuring network and information security), provided those interests are not overridden by your rights.
Consent: where you have given consent (for example, for certain cookies or marketing communications where required by law).

We use personal data collected through the Website primarily to:

operate, secure, and maintain the Website;
respond to your enquiries and communicate with you;
provide you with information you request about the Treasury Group and, where relevant, about Group Services;
improve the Website and understand how it is used;
prevent and detect fraud, security incidents, and misuse; and
comply with applicable laws and enforce our legal rights.

12.5 Marketing communications

Where permitted by law, we may send you communications about the Treasury Group or Group Services. You can opt out of marketing communications at any time by using the unsubscribe link in the message or by contacting us. Where required by law, we will obtain your consent before sending marketing communications.

12.6 Sharing of personal data

We may share personal data with:

other Treasury Group entities where necessary to respond to your enquiry, operate the Website, or for internal administrative purposes;
service providers who support our Website and business operations (for example, IT hosting providers, analytics providers, communications providers, and professional advisers), acting as processors or sub-processors;
competent authorities, regulators, law enforcement agencies, courts, and other third parties where required by law or to protect our rights;
a buyer or potential buyer of any Treasury Group business or assets (and their advisers) in connection with a corporate transaction, subject to appropriate safeguards; and
banking partners, payout networks/agents, payment processors, foreign exchange providers, liquidity providers and (where applicable) custodians or wallet infrastructure providers involved in delivering Group Services under a Service Agreement — these third parties may act as processors or as separate controllers depending on the circumstances and applicable law.

Some Third-Party Providers will process personal data as independent controllers (for example, banks, payment networks or wallet providers). Where this is the case, their own privacy notices will apply in addition to this Privacy Policy.

12.7 International transfers

Because the Treasury Group operates internationally, personal data may be transferred to, stored in, or accessed from countries outside your country of residence, including outside the UK and/or the EEA, such as Australia.

Where the EU GDPR or UK GDPR applies and personal data is transferred outside the EEA or the UK to a country that does not provide an adequate level of protection, we will implement appropriate safeguards, such as Standard Contractual Clauses (and, for UK transfers, the UK addendum or other UK-approved transfer mechanism), or rely on another lawful transfer mechanism available under applicable law.

12.8 Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including to respond to enquiries, operate the Website, comply with legal obligations, resolve disputes, and enforce our agreements. Where we process data for AML/CTF compliance in connection with Group Services, retention periods may be longer and will be determined by applicable law and the relevant Service Agreement.

12.9 Data security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. However, no website or system is completely secure.

12.10 Your rights

Depending on your location and the laws that apply, you may have certain rights in relation to your personal data.

Where the EU GDPR applies, you may have the right to:

request access to your personal data;
request correction of inaccurate or incomplete personal data;
request deletion of personal data (in certain circumstances);
request restriction of processing (in certain circumstances);
object to processing (in certain circumstances, including objection to processing based on legitimate interests);
request data portability (in certain circumstances); and
withdraw consent where we rely on consent (without affecting processing carried out before withdrawal).

Where the UK GDPR and the Data Protection Act 2018 apply, you have similar rights. Where the Australian Privacy Act 1988 applies, you generally have the right to access and correct personal information we hold about you, subject to certain exceptions.

12.10.1 Complaints

If you have a concern about our processing of your personal data, we encourage you to contact us first so we can try to resolve it. You may also have the right to lodge a complaint with your local data protection authority. For example:

United Kingdom: the Information Commissioner’s Office (ICO).
Poland: the President of the Personal Data Protection Office (UODO).
Australia: the Office of the Australian Information Commissioner (OAIC).
EEA: your local supervisory authority in your country of residence or work.

12.11 Cookies and similar technologies

We may use cookies and similar technologies to operate the Website, enhance security, and analyse usage. Where required by law, we will obtain your consent before placing non-essential cookies. You can control cookies through your browser settings; however, disabling certain cookies may affect Website functionality.

12.12 Required information and automated decisions

Where personal data is requested in connection with an enquiry or a potential Service Agreement, providing the information may be necessary to respond to you or to comply with legal obligations. If you do not provide requested information, we may be unable to respond to your enquiry or provide Group Services.

We may use automated tools to help detect and prevent fraud and to comply with sanctions and AML/CTF requirements. Where automated decision-making produces legal effects for you or similarly significantly affects you, we will take steps required by applicable law, including providing information about the logic involved and your rights.

12.13 Children

The Website is not intended for children. We do not knowingly collect personal information from persons under 18. If you believe a child has provided personal data to us via the Website, please contact us so we can take appropriate steps.

12.14 Contacting us about privacy

To exercise your rights or ask questions about this Privacy Policy, please contact us using the details in Section 14.

12.15 Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top of this document indicates when it was last revised.

13. Changes to these Terms

We may amend these Terms from time to time by posting an updated version on the Website and updating the “Last Updated” date. Your continued use of the Website after changes take effect constitutes acceptance of the updated Terms.

14. Contact information

General enquiries: operations@treasury-technologies.com

Registered offices:

Treasury Technologies Ltd (England and Wales), Company No.: 15760089, 52 New Crane Wharf, 8 New Crane Place, London, England, E1W 3TX.
Treasury Technologies sp. z o.o. (Poland), KRS No.: 0001102306, Mokotowska 5/10, 00-640 Warsaw, Poland.

If you need to send a formal notice relating to these Terms, you should send it to the Website Operator at its registered office, unless we provide a different notice address on the Website.

15. Governing law and jurisdiction

These Terms (and any dispute or claim arising out of or in connection with them or the Website) are governed by the laws of the Commonwealth of Australia, without regard to conflict of laws principles.

Subject to any mandatory rights you may have under applicable law (including any right to bring proceedings in your local courts), you agree that the courts of Australia have jurisdiction to settle any dispute or claim arising out of or in connection with these Terms or the Website.

For the avoidance of doubt, the governing law and jurisdiction applicable to any Group Services will be set out in the relevant Service Agreement and may differ from this Section 15.

Terms of Use & Privacy Policy