This Product Disclosure Statement (PDS) is issued by Kuber Financial Pty Ltd (we or us) as the Corporate Authorised Representative of Flash Partners Pty Ltd (ACN 607 885 941), AFSL No. 48034 (Flash Payments) and relates to the use of Services by you (you or customer). The information set out in this PDS describes the services we offer, including the benefits, risks and associated costs of those services, together with other general information necessary to help you make an informed decision about whether to purchase the Services (defined below).

The information set out in this document is general in nature and does not take into account your individual objectives, financial situation and needs. As such, before acting on this information, you should assess whether the Services are right for you. You should consider this Combined FSG & PDS, in addition to speaking with an appropriate adviser, before making any decision about whether to acquire the Services. Please contact us or visit our website at www.kuberfinancial.com.au if you would like more information regarding the Services.

The information contained within this Combined FSG & PDS is correct as at the date of issue but may change from time to time in which case we will issue a supplementary PDS (“Supplementary PDS”). This PDS and any Supplementary PDSs will be published on our website at [www.kuberfinancial.com.au]. Should you wish to have a paper copy of this PDS and/or any Supplementary PDSs, please email us at support@kuberfinancial.com.au and we will provide you with the copies free of charge.

Offer only in Australia

The offer in this PDS is available only to persons receiving this PDS (electronically or otherwise) in Australia and does not constitute an offer or recommendation in any jurisdiction, or to any person to whom it would be unlawful to make such an offer.

Changes to your particulars

You must inform us immediately of any changes in your name or any other particulars such as address, contact number, etc. To do so, please email support@kuberfinancial.com.au and update your details. It may take up to 2 business days for us to process any change of details.

No Cooling-Off Period

No cooling-off period applies to the products and services covered by this PDS.

No ESG Considerations

Labour standards or environmental, social or ethical considerations do not form part of the considerations in connection with the Services.

Contact details

Kuber Financial Pty Ltd (ACN 607 885 941, No. Corporate Authorised Representative AFSL No. 480834)

Address : 8/10 Broughton Street Parramatta,NSW 2150

Website : https://www.kuberfinancial.com.au

Email : support@kuberfinancial.com.au

Corporate Authorised Representative of:

Flash Partners Pty Ltd (ACN 607 885 941, AFSL No. 480834)

Address : Level 26, 1 Blight Street, Sydney NSW 2000

Website : https://www.flash-payments.com

Email : Support@flash-payments.com

About This Document

This document is comprised of two parts:

Part A is our financial services guide (FSG), which tells you about the financial services we offer and is designed to help you decide whether to use them, and

Part B is the product disclosure statement (PDS), which tells you about the products issued by Kuber, including the Digital Wallet, and is designed to help you make a decision about whether or not to use those products. It includes general information about the Kuber Digital Wallet and other Kuber products and includes their features, benefits and risks and sets out the terms and conditions that govern their use. It also includes the meaning of some words used in the PDS

Things to note

Because the Kuber Digital Wallet, and the Top Up and Payout Services are part of our Kuber service, unless otherwise agreed, your use of the Digital Wallet, the Top Up and Payout Services are governed by:

The Kuber Terms & Conditions – https://kuberfinancial.com.au/privacypolicy.html

You should carefully read through those documents because they explain what we will do when providing the Kuber Digital Wallet, Top Up and Payout Services to you and what we expect from you. If you ask us, we’ll provide you with a PDF version.

A reference in this document to a working day is to a day (other than a Saturday, Sunday or public holiday) on which banks are open for general banking business in Sydney, Australia.

PART A: FINANCIAL SERVICES GUIDE

DATE OF ISSUE:

SECTION 1: ABOUT THIS FSG

This FSG is issued by Kuber Financial Pty Ltd (ACN 607 885 941, Corporate Authorised Representative of AFSL No.480834]) (we, us, our).

This FSG contains information about who we are and the financial services that we can offer you in respect of the Products and Services provided by us and is designed to help you decide whether to use those services.

It also includes information on the documents you may receive from us, how you can provide instructions to us, who we act for when providing financial services, how we and others are paid for the financial services we provide to you, our professional indemnity insurance, how you can raise any concerns or complaints about us and how you can contact us.

SECTION 2: THE ADVICE WE PROVIDE

We are only authorised to provide general advice so you should be aware that any material provided to you by us (including any statement of opinion or recommendation) will contain actual factual information or general advice only. This factual information or general advice does not take into account your objectives, financial situation or needs. You should consider the appropriateness of our offering in regard to your objectives, financial situation and needs before making a decision in relation to our financial services.

SECTION 3: WHO WE ARE AND THE SERVICES WE OFFER

We are the corporate authorised representative of an Australian financial services licensee and are authorised to provide the following relevant financial services to retail and wholesale clients:

Non-cash Payment Facility, the Kuber Digital Wallet, which includes:
1. Tap & Pay – a digital payment solution that facilitates real-time payments
2. Digital payment solution that can use Top Up services through PayID which is powered by Zai Australia Pty Ltd (Zai)
3. Digital payment solution that offers Pay-ins and Pay-outs services
4. Digital payment solution that can instantly send money to Kuber Digital Wallet users within Australia (person-to-person or merchant)
5. Track your Spending – a digital payment solution that offers personal finance features (i.e. budget tracking, record assets and liabilities, plan financial goals with progress tracking, etc.) as a subscription based model
6. Dutch-in – a digital payment solution that offers split payment features, enabling users to quickly and efficiently split payments and invoices.

SECTION 4: YOU WILL RECEIVE A PDS FROM US

We will give you a PDS (contained in Part B of this document). The PDS is designed to provide important information on the significant features, benefits and risks of the Products and Services we provide and the fees you will be required to pay when you use those Products and Services – you should carefully read this document because it can help you make an informed decision about Kuber’s Products and Services.

SECTION 5: HOW YOU CAN INSTRUCT US

You can give us instructions in respect of transactions in your Kuber Wallet through the Kuber app; or otherwise by emailing us on support@kuberfinancial.com.au.

SECTION 6: WHO WE ACT FOR WHEN PROVIDING FINANCIAL SERVICES

When we provide financial services, we act on our own behalf (although we are the Corporate Authorised Representative of an AFS Licensee).

SECTION 7: HOW WE AND OTHERS ARE PAID

How we are paid

If you decide to use the PayID to pay money into the Wallet, or out of the Wallet, or to top up funds, we receive product fees, which are set out in the PDS (contained in Part B of this document). In addition, if you use the budget and data visualisation feature, you will pay a subscription fee. This is also set out in the PDS (contained in Part B of this document).

Within a reasonable time of us providing you with this FSG, you may ask us to provide particulars of the remuneration or other benefits that our employees or affiliates receive in relation to the provision of the Kuber Products and Services, including the Top Up, Pay-ins and Pay-outs Services to you.

Our Staff

Our staff receive a salary plus superannuation.

SECTION 8: OUR PROFESSIONAL INDEMNITY INSURANCE

We have professional indemnity insurance, which provides cover for claims by retail clients that relate to the financial services that we and our representatives provide. This satisfies the compensation arrangements required under section 912B of the Corporations Act 2001 (Cth).

We are also covered for claims against former representatives while they acted on our behalf.

You do have a direct right to claim under this insurance.

SECTION 9: WHAT IF YOU HAVE A CONCERN?

If you are unhappy with us and would like to raise any concerns or complaints, please contact us at https://kuberfinancial.com.au/contact-us.html.

We’ll acknowledge your complaints as soon as practicable (and in any event, within 5 business days) and aim to resolve your complaint within 30 calendar days.

If you’re not satisfied with our response, you can contact the Australian Financial Complaints Authority (AFCA) (an independent and free dispute resolution body). Before AFCA can investigate the matter, you must have first given us the opportunity to review it.

The contact details for AFCA are:

Australian Financial Complaints Authority

https://www.afca.org.au

info@afca.org.au

1800 931 678 (free call)

GPO Box 3, Melbourne, VIC 3001

SECTION 10: HOW TO CONTACT US

You can contact us using the contact details set out on the front page of this document or through your Kuber Wallet account.

PART B: PRODUCT DISCLOSURE STATEMENT

ISSUE DATE: 29 April 2024

SECTION 1: ABOUT KUBER FINANCIAL

Kuber Wallet, powered by Kuber Financial Pty Ltd, is a dynamic digital wallet application designed to facilitate seamless financial transactions for both individual users and merchants. Leveraging state-of-the-art technology, Kuber Wallet aims to simplify the process of money management and transactions, making it quick, secure, and accessible from anywhere within Australia. It enables users to engage in real-time money transfers, payment services, and financial management through a user-friendly mobile platform.

Key Features of Kuber Wallet

Instant Real-Time Payments
1. Peer-to-Peer Transactions: Enables users to send and receive money instantly with other Kuber Wallet holders across Australia, fostering ease of transactions for personal and business purposes.
2. Merchant Payments: Merchants can receive payments directly from customers’ wallets, streamlining the sales process and reducing reliance on physical payment systems.

Advanced Financial Management Tools
1. Analytics Subscription: Users can opt for a premium feature that offers detailed visualizations and analytics on their spending and saving patterns, helping them make informed financial decisions.
2. Budgeting and Tracking: Provides tools for setting up customisable budgets, financial goals, and tracking expenses against these budgets.

User and Merchant Services
1. Flexible Loading and Withdrawal Options: Users can load money into their wallets using PayID and withdraw funds directly into linked bank accounts ensuring convenience and speed.
2. Analytics Subscription: Users can opt for a premium feature that offers detailed visualizations and analytics on their spending and saving patterns, helping them make informed financial decisions.

Security and Compliance
1. Robust Security Framework: Incorporates advanced security measures such as encryption, multi--factor authentication, and continuous fraud monitoring to protect user data and transaction integrity.
2. Compliance with Australian Regulations: Fully compliant with the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regulations and adheres to the standards set out in the Privacy Act 1988 (Cth).

No Internal Transaction Fees
1. Cost-Efficiency for Users: Encourages the user of Kuber Wallet for everyday transactions by eliminating fees for transfer between Kuber Wallets, promoting digital wallet adoption among users.

User Experience and Accessibility

Mobile-First Approach: Designed with a focus on user experience, accessible via iOS and Android devices to ensure functionality across a broad range of smartphones.
Customer Support: Dedicated support team available to assist with any queries or issues, ensuring a smooth user experience. Please contact us on [support@kuberfinancial.com.au] if you have any questions.

SECTION 3: WALLET

Wallet

Kuber Financial provides you with a non-cash payment facility through which funds can be held, sent and received electronically through the Kuber Platform (Wallet). Funds can only be held in the Wallet in Australian Dollars. Funds held in the Wallet can be used to make payments in Australia amongst Kuber users (individuals or merchants). You can load funds into your Wallet using PayID. You must have PayID in order to be able to use the Wallet.

It is important to understand that the Wallet is not a bank account, it is an electronic payment facility. Funds represented by the Wallet will be collected and pooled with funds of other clients of Kuber in one or more trust accounts with a licensed bank in Australia]. Your funds are at all times held separately from Kuber’s own funds. Kuber will be entitled keep the interest (if any) earned on these accounts. Please refer to Section 7 “Zai Partnership” for more information.

We may from time to time by notice to you require you to maintain a minimum balance in your Wallet in order to ensure that you have sufficient funds to settle transactions you may enter into from time to time.

SECTION 4: PayID AND WITHDRAWALS

PayID

PayID is an innovative service that allows users to make and receive payments using a unique identifier, such as email address or phone number, linked to their normal bank accounts. This feature is integrated into Kuber Wallet to enhance the user experience with the following functionalities:

Easy Pay-In or Up Load: User can easily send money directly to their Kuber Wallet, or load more funds into their Wallet if they are running low.
Simplified Payments: Users can send money directly to others using an easily memorable identifier (like a phone number or email), eliminating the need to enter complex bank account details
Instant Transactions: Transactions via PayID are processed in real-time, allowing for immediate transfer of funds between accounts, which is especially beneficial for urgent payments
Zero Fees: Transactions between Kuber users are processed in real-time and free of any fees. You save on bank fees. You only pay fees when you load money into your Wallet from your bank account or when you withdraw money from your Wallet into your bank account.
Enhanced Security: PayID reduces the risk of sending money to the wrong account as users can confirm the recipient’s name before finalizing the transaction.
Wide Acceptance: Supported by numerous banks and financial institutions across Australia, PayID makes Kuber Wallet more versatile for various types of transactions, both personal and commercial

Withdrawals

Withdrawals, another core service provided by Kuber, is crucial for efficient fund management within Kuber Wallet. This service facilitates the electronic transfer of funds directly into bank account and offers the following key features:

Seamless Fund Withdrawals: Users can easily transfer their Kuber Wallet balance into any Australian bank account by simply withdrawing funds from their Kuber Wallet, which is processed swiftly to ensure funds are available as needed. Withdrawals are usually settled in real time (although occasionally, some withdrawals may take longer).
Reduced Transaction Times: The Kuber Withdrawal feature ensures that the transactions are not only secure but also fast, reducing the typical processing time seen with traditional banking methods
Record Keeping: Every transaction is recorded and easily accessible within Kuber Wallet, aiding in better financial management and transparency for both individuals and businesses

Integration Benefits

Kuber has partnered with Zai Australia Pty Ltd (ABN 96 637 632 645). Zai is a key provider to Kuber of Application Programming Interface (APIs) that enable Kuber to provide PayID and Withdrawal services. Through the use of these APIs, the Kuber Wallet provides you a comprehensive and efficient financial tool tailored to your needs whether you are an individual or a business. This partnership allows Kuber Wallet to offer a seamless and enhanced user experience characterised by:

Real-Time Processing: Both PayID and Withdrawal support real-time transaction processing, which is crucial for users who need immediate access to funds or need to make instant payments
Broad Accessibility: These features ensure that Kuber Wallet users can interact easily with other bank accounts and financial services across Australia, expanding the usability of the Wallet
Cost Efficiency: Kuber Wallet can offer these services without the need for complex and cost infrastructure development internally

SECTION 5: KEY FEATURES

The Key Features of Kuber’s product is available to both individuals and merchants, and is set out below:

Sign up using the Kuber app through the mobile phone application downloaded via the Apple Store or the Google Play Store;
The Kuber Wallet provides users with a dashboard with the following functionality:
1. The user’s chosen nickname and KuberID;
2. Icon notifying of unread notifications;
3. Easy to see Kuber balance in your Kuber Wallet;
4. “Explore” which provides users with data analytics on their budget and spending behaviours;
5. QR Pay – enables the user to make real-time payments to other Kuber users using QR codes;
6. Tap and Pay – enables users to pay or request money. Payments are confirmed using a user’s unique PIN or biometric details
7. Dutch-in - for splitting payments between groups.
8. Send Money To – for sending money to other Kuber users using their unique KuberID or phone numbers. This function includes the ability to chat to users before you send or receive money. This payment chat also serves as a record of transactions between users.
9. Your Kuber Wallet – enables users to top up and withdraw funds from their Wallet to and from their bank accounts using PayID.
10. Transfer to Bank – enables users to withdraw funds from their Kuber Wallet to their pre-authorised bank account. A user can have only one bank account active at any particular time. This provides the user with additional protection by ensuring that fund withdrawals go only to your pre-approved bank account. You can change your bank account details by using the “Add Bank” functionality – just make sure no one else has access to your Kuber Wallet so they cannot change your bank account without your knowledge.
11. A ledger showing all Recent Transfers and Recent Payments to provide users with records of all their spending and receipts.

The Kuber Analytics provides users with the following functionality:
1. A detailed list of transactions made on Kuber which users can filter on the basis of date, category of transaction, particular merchant or individual user paid;
2. Interactive visualisations of a user’s spending pattern which can be filtered by month, fortnight or week, showing expenditure variations over time;
3. Categorisation of expenditure showing where users are spending most of their money;
4. Ability to set budgets for particular categories to help users cap their spending.
5. Ability to set custom reminders so that the Kuber app reminds them when they have reached their budget cap, or have breached their budget cap;
6. Ability to manually enter assets and liabilities for a visualisation of net worth;

SECTION 6: AML/CTF AND KYC PROCESS

Kuber complies with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (“AML/CTF Act”).

As a prospective user of Kuber’s Services and Products, you will be asked to undergo our KYC procedures to verify your identity. We may do this by requesting that you provide documents (including certified documents) and other information. You may also be asked at various times when you hold the Wallet to confirm the accuracy of information you have previously provided, or we may ask you to provide additional information. It is an offence under the AML/CTF Act to give false and/or misleading information in connection with our KYC procedures. If you fail to complete our KYC procedures, or if you provide us with incomplete or inaccurate information we will unable to provide you with the Services. The total amount of incoming and outgoing transfers from the Wallet cannot be more than A$200 unless you have completed our KYC procedures. As soon as funds hit the Wallet, our KYC procedures are triggered before you can use those funds.

SECTION 7: RISKS

Zai Partnership

As mentioned above, Kuber Financial Pty Ltd has established a strategic commercial partnership with Zai Australia Pty Ltd (Zai), a renowned provider of innovative payment solutions. This partnership is integral to the operation of Kuber Wallet, enhancing its capabilities to provide real-time financial transaction services.

Nature of Relationship

Kuber Wallet leverages Zai’s advanced Application Programming Interfaces (APIs) to enable robust payment functionalities within its platform. These APIs include but are not limited to PayID and Direct Credit services, which are crucial for the efficient execution of both pay-ins (loading funds into Kuber Wallet) and pay-outs (withdrawing funds to bank accounts).

There are some significant benefits from the Zai partnership, which include:

Real-Time Transaction Processing: Through Zai’s APIs, Kuber Wallet facilitates instant transfer of funds. This capability allows users to immediately add money to their Kuber Wallets and perform withdrawals, significantly enhancing user convenience and satisfaction.
Enhanced Service Offerings: The integration with Zai’s APIs enables Kuber Wallet to offer a broad spectrum of payment services that are competitive within the industry, providing Kuber Wallet users with a seamless and efficient payment experience.
Reliability and Security: Zai is known for its reliable and secure payment solutions. By partnering with Zai, Kuber Wallet ensures that all transactions are processed securely, maintaining high standards of data protection and financial security that comply with Australian regulations.

Commercial Terms

The relationship between Kuber Financial and Zai is governed by a commercial agreement that includes the provision of Zai’s payment APIs to Kuber Wallet. Under this agreement:

Administrative Fees: Transactions that involve pay-ins and pay-outs are subject to an administrative fee as stipulated in the terms of the agreement. These fees are transparently disclosed to users within the Kuber Wallet platform.
No Fee for Internal Transactions: It is important to note that all internal transactions, i.e., wallet-to-wallet transfers withing the Kuber Wallet platform, are not subject to any fees, promoting the use of Kuber Wallet for various types of transactions without additional costs.

There are also the following risks resulting from the Zai partnership:

Material Provider: Zai is a key provider of APIs to Kuber. Without the Zai APIs, Kuber would be unable to provide the any of the Kuber Products or Services, including the Wallet to you. If Zai were to become insolvent, we would lose the ability to provide you with Products or Services, and our Kuber Platform would likely be suspended;
Zai holds your funds: when you transfer your funds to upload them into your Wallet via PayID, they are held by Zai in a trust account with an Australian bank. However, there is a risk that Zai does not properly hold these funds in a trust account, or that they accidentally (or fraudulently) disperse these funds. If this occurs, we would seek to take action to recover your funds, but there would be no certainty of success and you may lose your funds forever.
API failure: if for any reason whatsoever any of Zai’s APIs or other software fails, then this will adversely impact our ability to provide the Kuber platform and Wallet to you.
Zai insolvency: if Zai were to become insolvent, there is a risk that you may lose your funds and/or that your funds are suspended and cannot be accessed pending the outcome of the Zai insolvency.

Technological Risks

System Downtime and Reliability:
1. Risk Detail: Both Kuber Wallet and Zai rely on complex technology infrastructure which is susceptible to downtimes due to system failures, maintenance, or external attacks. This can lead to service interruptions, affecting the ability to conduct transactions in real-time.
2. Impact: Users may experience delays in processing transactions which can be critical, especially for businesses relying on timely payments.

Cybersecurity Threats:
1. Risk Detail: Cyber threats such as hacking, data breaches, and phishing attacks pose significant risks. Since Kuber Wallet and Zai handle sensitive financial data, they are attractive targets for cybercriminals.
2. Impact: Any breach could lead to loss of sensitive data, financial loss for users, and damage to the reputation of Kuber Wallet and Zai.
3. Theft: The two founders of Kuber control the access to the Zai APIs and the flow of your funds as you direct. If, for any reason whatsoever, one or more of the founders is the victim of a cyber-crime, then your funds may be stolen and lost permanently. Whilst security measures are taken to protect against this happening, no guarantee can be given that it will not happen.
4. Failure to keep your Kuber Wallet details confidential: if another person, for any reason, gains access to your Kuber Wallet (either by stealing your mobile phone, or gaining your access passwords) they can change the bank account details on your Kuber app and withdraw the funds in your Kuber Wallet to their own bank account. It is therefore important that you always keep your mobile phone and/or passwords or access codes private and confidential.

Dependency on Third Party Services:
1. Risk Detail: Kuber Wallet’s operations rely heavily on the APIs and services provided by Zai, which in turn may depend on other third-party services for hosting, payment processing, etc.
2. Impact: Failures or disruptions in these third-party services could impact Kuber Wallet’s ability to provide seamless services, leading to transaction delays or failures.

Operational Risks

Compliance and Regulatory Risks:
1. Risk Detail: Financial services are highly regulated. Any changes in regulations related to financial transactions, data protection, or AML (Anti-Money Laundering) and CTF (CounterTerrorism Financing) could impact the operations of Kuber Wallet and Zai.
2. Impact: Non-compliance could lead to hefty fines, suspension of services, or more severe legal consequences.

Market Adoption and Competition:
1. Risk Detail: The success of Kuber Wallet heavily depends on market adoption by individual users and merchants. Additionally, the financial technology sector is highly competitive, with many players offering similar services.
2. Impact: Failure to differentiate from competitors or to capture a significant market share could limit revenue and growth prospects.

Partnership Dependencies:
1. Risk Detail: The strategic partnership with Zai is crucial for the functioning of Kuber Wallet. Any financial instability or operational challenges faced by Zai could directly affect their service offerings.
2. Impact: This could lead to a reduction in service quality, potentially resulting in user dissatisfaction and attrition.

Financial Risks

Liquidity Risk:
1. Risk Detail: Kuber Wallet needs to manage liquidity meticulously, especially concerning the funds held in user wallets and processed through transactions.
2. Impact: Mismanagement can lead to situations where Kuber Wallet may not be able to fulfill withdrawal requests promptly.

Credit Risk:
1. Risk Detail: Involves the risk that a counterparty will fail to meet its obligations in accordance with agreed terms, primarily concerning direct credit transactions.
2. Impact: This could result in financial losses, particularly if a large transaction fails.

Strategic Risks

Reputation Risk:
1. Risk Detail: As a financial service provider, maintaining user trust is crucial. Any negative incidents, such as service outages, data breaches, or compliance failures, can severely damage reputation.
2. Impact: Loss of reputation can lead to decreased user base, reduced transaction volume, and difficulties in securing future partnerships or funding.

Scalability Challenges:
1. Risk Detail: As Kuber Wallet grows, its infrastructure needs to scale accordingly. Inadequate scalability planning could lead to performance bottlenecks.
2. Impact: This can affect transaction speeds and reliability, impacting user satisfaction and growth.

Transaction Risks

Transaction Failure Risk:
1. Risk Detail: There's a risk of transaction failures due to technical issues, incorrect user input, or problems with the banking network. This includes failed transfers, delayed postings, or errors during the payment process.
2. Impact: Such failures can lead to financial discrepancies, user dissatisfaction, and potential financial loss for users awaiting critical payments.

Fraud Risk:
1. Risk Detail: Transaction fraud can occur in various forms, including identity theft, unauthorized access, and scam transactions. With digital platforms, the risk of sophisticated phishing attacks and other scams also increases.
2. Impact: Fraud can result in direct financial loss for users, erode trust in the Kuber Wallet platform, and lead to significant reputational damage.

Operational Risks

Service Availability:
1. Risk Detail: High reliance on continuous system availability means that any downtime, whether for maintenance or due to unforeseen issues, affects service accessibility.
2. Impact: This can disrupt user ability to perform transactions when needed, potentially leading to loss of business for merchant users and inconvenience for individual users.

Data Management Risks:
1. Risk Detail: Managing large volumes of sensitive user data poses significant risks, including data loss, theft, or misuse, especially if data handling practices are not up to regulatory standards.
2. Impact: Breaches could lead to severe legal and financial consequences, including penalties for noncompliance with data protection laws.

AML/CTF Compliance Risks

Non-Compliance Risk:
1. Risk Detail: Failing to adhere to AML/CTF regulations can occur if the company's internal controls and monitoring systems are inadequate. This includes failure to properly identify and verify customer identities, monitor transactions for suspicious activities, and report to regulatory bodies as required.
2. Impact: Noncompliance can lead to legal penalties, including fines and sanctions, as well as severe damage to the company’s reputation.

Sanctions Risk:
1. Risk Detail: Engaging in or facilitating transactions that violate international sanctions can expose Kuber Wallet to serious compliance risks.
2. Impact: Violations can result in hefty fines and restrictions on business operations, affecting the company's profitability and operational capabilities.

Account Suspension Risks

False Positives in Fraud Detection:
1. Risk Detail: Overly sensitive fraud detection systems can lead to false positives, incorrectly flagging legitimate user activities as suspicious.
2. Impact: This can lead to unwarranted account suspensions or freezes, causing frustration and potential loss of customers.

User Disputes and Resolutions:
1. Risk Detail: Ineffective dispute resolution processes can exacerbate issues related to account suspensions, particularly if users feel they are wrongly penalized.
2. Impact: Poor management of disputes can lead to increased customer dissatisfaction and damage to the platform’s reputation.

Legal and Regulatory Risks

Changing Regulatory Landscapes
1. Risk Detail: Financial services are subject to high regulatory scrutiny. Changes in laws or regulations regarding digital payments, or data protection could impose new compliance requirements.
2. Impact: Failure to comply with new regulations could result in fines, sanctions or forced modifications to business practices, impacting operations and growth.

Intellectual Property Risks
1. Risk Detail: There is a risk of infringement on intellectual property rights in a highly innovative sector, or conversely, others infringing on Kuber Wallet’s intellectual property
2. Impact: Legal disputes related to intellectual property could result in significant legal costs and operational distractions.

SECTION 8: FEES AND CHARGES

The fees and charges applicable to the Products and Services are detailed below.

All fees and charges are subject to change on notice from Kuber, which will be provided to users through the Kuber app and via a supplementary PDS. All payments will be made in Australian dollars unless otherwise agreed. The times at which the fees and charges will or may be payable are set out in the table below.

Products for Individuals	Fee (exclusive of GST)	When Payable and how calculated
Static QR Code	N/A	N/A
Custom QR Code	N/A	N/A
Payment Chat	N/A	N/A
Tap & Pay	N/A	N/A
Pay by Contact	N/A	N/A
Dutch-In	N/A	N/A
Track Your Spending (Analytics)	$3/week	At the time of subscription
Pay-In (Top-up)	Flat fee of $0.70	While topping up and calculated per transaction
Pay-Out (Withdrawal)	1.5% or $4 (whichever is lower)	While withdrawing, calculated per transaction. 1.5% of the withdrawal amount upto $4. It cannot be more than $4.

Worked Example for Fees payable by Individuals

For example: If a user pays-in $500 via PayID from their banking application into Kuber, an administrative fee of $0.70 will apply and the remainder of $499.30 will be credited into the user’s Kuber wallet as the balance.

If a user wishes to withdraw $100, then an administrative fee of 1.5% will apply and the user will receive $98.5 in their bank account. However, if the user wishes to withdraw $500, an administrative fee of $4 will apply as the 1.5% of the transaction amount becomes more than $4 which is the maximum administrative fee Kuber charges on withdrawals and the user will receive $496 in their bank account.

If a user decides to subscribe to the Analytics feature, they are shown a prompt including the amount which is $3/ week. They are also shown the dates to and from which their subscription will be active and when it will expire. They swipe and give their consent to this and Kuber deducts the $3 from their wallet balance. The users can also enable/disable the auto-renew feature of their Analytics subscription from their settings that automatically renews their subscription by deducting $3 per week from their wallet balance upon the expiration of their Analytics subscription.

The Fees payable by Merchant users are:

Products for Merchants	Fee (exclusive of GST)	When Payable
Static QR Code	N/A	N/A
Custom QR Code	N/A	N/A
Payment Chat	N/A	N/A
Tap & Pay	N/A	N/A
Pay by Contact	N/A	N/A
Dutch-In	N/A	N/A
Track Your Spending	$3/week	At the time of subscription
Pay-In (Top-up)	Flat fee of $0.70	While topping up and calculated per transaction
Pay-Out (Withdrawal)	1.5% or $4 (whichever is lower)	While withdrawing, calculated per transaction. 1.5% of the withdrawal amount upto $4. It cannot be more than $4.

Worked Example for Fees payable by Merchants

If a merchant pays-in $500 via PayID from their banking application into Kuber, an administrative fee of $0.70 will apply and the remainder of $499.30 will be credited into the user’s Kuber wallet as the balance.

If a merchant wishes to withdraw $100, then an administrative fee of 1.5% will apply and the user will receive $98.5 in their bank account. However, if the user wishes to withdraw $150, an administrative fee of only $4 will apply as the 1.5% of the transaction amount becomes more than $4 which is the maximum administrative fee, Kuber charges on withdrawals and the user will receive $496 in their bank account.

If a merchant decides to subscribe to the Analytics feature, they are shown a prompt including the amount which is $3/ week. They are also shown the dates to and from which their subscription will be active and when it will expire. They swipe and give their consent to this and Kuber deducts the $3 from their wallet balance. The users can also enable/disable the auto-renew feature of their Analytics subscription from their settings that automatically renews their subscription by deducting $3 from their wallet balance upon the expiration of their Analytics subscription

SECTION 9: TAXATION

The Products and Services may have tax implications for your business, depending on your own financial circumstances. You should seek advice from a tax specialist before purchasing any Products or Services.

SECTION 10: PRIVACY

Your privacy is important to us. The information you provide to Kuber and any other information provided by you in connection with the Services will primarily be used for providing you with the Services and for complying with certain laws and regulations.

Our privacy policy is available on our website at https://kuberfinancial.com.au/privacypolicy.html. It includes information such as:

How we collect, hold, use and disclose your personal information
Your rights and choices regarding the right to correct, amend or delete your information; and
How you can make a complaint regarding privacy concerns

We will update our privacy policy from time to time

SECTION 12: COMPLAINTS AND DISPUTES

Internal Dispute Resolution

Kuber prides itself on being honest about where we need to improve. We have a complaints procedure designed to make sure all concerns are addressed promptly and fairly. If you are unhappy with us and would like to raise any concerns or complaints in relation to the Services or any associated services, please contact us at https://kuberfinancial.com.au/contact-us.html.

We will acknowledge your complaint as soon as practicable (and in any event, within 5 business days) and aim to resolve your complaint within 30 days.

External Dispute Resolution

If you are not satisfied with our response to your complaint, you can contact the Australian Financial Complaints Authority (“AFCA”) (an independent and free dispute resolution body). Before AFC can investigate the matter, you must have first given us the opportunity to review it. AFCA’s details are listed below:

Online : https://www.afca.org.au

Email : info@afca.org.au

Phone : 1800 931 678 (free call)

Mail : Australia Financial Complaints Authority

GPO Box 3

Melbourne, VIC 3001

The AFCA Website also permits you to register or lodge a dispute online.

Combined Financial Services Guide and Product Disclosure Statement