Last updated May 15, 2023

Thank you for visiting our website. This website is owned and operated by Constantinople Operating Company Pty Ltd ABN 79 655 047 126. We are a software company and not a bank. By accessing and/or using this website and related services, you agree to these Terms and Conditions (Terms). You should review these Terms carefully and immediately cease using our website if you do not agree to these Terms.

In these Terms, "us", "we" and "our" means Constantinople Operating Company Pty Ltd and our related bodies corporate.

Collection of your personal information

We collect and retain personal information about you when you make an enquiry through our website, including name, email and phone number. We collect this personal information in order to respond to your enquiry We may disclose that information to third parties that help us deliver our services (including suppliers and our business partners) or as required by law. If you do not provide this information, we may not be able to respond to your enquiry or process your application for employment with us. We may also disclose your personal information to recipients that are located outside of Australia. By providing your personal information to us, you consent to the collection, use, storage and disclosure of that information as described in the these Terms.

Accuracy, completeness and timeliness of information

The information on our website is not comprehensive and is intended to provide a summary of the subject matter covered. While we use all reasonable attempts to ensure the accuracy and completeness of the information on our website, to the extent permitted by law, including the Australian Consumer Law, we make no warranty regarding the information on this website. You should monitor any changes to the information contained on this website.

We are not liable to you or anyone else if interference with or damage to your computer systems occurs in connection with the use of this website or a linked website. You must take your own precautions to ensure that whatever you use from our website is free of viruses or anything else (such as worms or Trojan horses) that may interfere with or damage the operations of your computer systems.

We may, from time to time and without notice, change or add to the website (including the Terms) or the information, products or services described in it. However, we do not undertake to keep the website updated. We are not liable to you or anyone else if errors occur in the information on the website or if that information is not up-to-date.

Linked sites

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise (for example, where we post a message or a job ad), we do not endorse and are not responsible for the content on those linked websites and have no control over or rights in those linked websites.

Intellectual property rights

Unless otherwise indicated, we own or license from third parties all rights, title and interest (including copyright, designs, patents, trademarks and other intellectual property rights) in this website and in all of the material (including all text, graphics, logos, audio and software) made available on this website (Content).

Your use of this website and use of and access to any Content does not grant or transfer any rights, title or interest to you in relation to this website or the Content. However we do grant you a licence to access the website and view the Content on the terms and conditions set out in this Agreement and, where applicable, as expressly authorised by us and/or our third party licensors.

Any reproduction or redistribution of this website or the Content is prohibited and may result in civil and criminal penalties. In addition, you must not copy the Content to any other server, location or support for publication, reproduction or distribution is expressly prohibited.

All other use, copying or reproduction of this website, the Content or any part of it is prohibited, except to the extent permitted by law.

No commercial use

This website is for your personal, non-commercial use only. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, commercially exploit, create derivative works from, transfer, or sell any Content, software, products or services contained within this website. You may not use this website, or any of its Content, to further any commercial purpose, including any advertising or advertising revenue generation activity on your own website.

Unacceptable activity

You must not do any act that we would deem to be inappropriate, is unlawful or is prohibited by any laws applicable to our website, including but not limited to:

• any act that would constitute a breach of either the privacy (including providing private or personal information without an individual's consent) or any other of the legal rights of individuals;

• using this website to defame or libel us, our employees or other individuals.

• uploading files that contain viruses that may cause damage to our property or the property of other individuals;

• posting or transmitting to this website any non-authorised material including, but not limited to, material that is, in our opinion, likely to cause annoyance, or which is defamatory, racist, obscene, or threatening, or otherwise or which is detrimental to or in violation of our systems or a third party's systems or network security.

If we allow you to post any information to our website, we have the right to take down this information at our sole discretion and without notice.

Warranties and disclaimers

To the maximum extent permitted by law, including the Australian Consumer Law, we make no warranties or representations about this website or the Content, including but not limited to warranties or representations that they will be complete, accurate or up-to-date, that access will be uninterrupted or error-free or free from viruses, or that this website will be secure.

We reserve the right to restrict, suspend or terminate without notice your access to this website, any Content, or any feature of this website at any time without notice and we will not be responsible for any loss, cost, damage or liability that may arise as a result.

Liability

To the maximum extent permitted by law, including the Australian Consumer Law, in no event shall we be liable for any direct and indirect loss, damage or expense – irrespective of the manner in which it occurs – which may be suffered due to your use of our website and/or the information or materials contained on it, or as a result of the inaccessibility of this website and/or the fact that certain information or materials contained on it are incorrect, incomplete or not up-to-date.

Jurisdiction and governing law

Your use of the website and these Terms are governed by the law of New South Wales and you submit to the non-exclusive jurisdiction of the courts exercising jurisdiction in New South Wales.

Privacy Policy

Constantinople commitment to privacy

Constantinople Holding Company Limited ABN 71 655 000 472, its subsidiaries and affiliates in Australia (collectively referred to as Constantinople) are committed to managing personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, "we" and "us" refers to Constantinople and "you" refers to any individual about whom we collect personal information.

About Constantinople

Constantinople is a global fintech company offering wholesale banking solutions.

Please contact us for a full list of the companies which comprise Constantinople and which are subject to this Privacy Policy.

What information does Constantinople collect about you?

Clients and prospective clients

When you enquire about our services or when you become a client of Constantinople, a record is made which may include your personal information.

The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

• your name, e-mail and other contact details;

• information about your employer or an organisation who you represent;

• your professional details; and

• any additional personal information you provide to us, or authorise us to collect, as part of your interaction with Constantinople.

Prospective employees/applicants

We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may

collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions which require you to hold a licence or certificate).

Other individuals

Constantinople may collect personal information about other individuals who are not clients of Constantinople. This includes customers and members of the public who participate in events we are involved with; individual service providers and contractors to Constantinople; and other individuals who interact with Constantinople on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Constantinople. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.

If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.

In limited circumstances, Constantinople may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by Constantinople we may collect health information about you in an emergency or otherwise with your consent.

You can always decline to give Constantinople any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.

Visitors to our websites

The way in which we handle the personal information of visitors to our websites is discussed below.

How and why does Constantinople collect and use your personal information?

Constantinople collects personal information reasonably necessary to carry out our business, to assess and manage our clients' needs, and provide services. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing client relationships.

The purposes for which Constantinople usually collects and uses personal information depends on the nature of your interaction with us, but may include:

• responding to requests for information and other general inquiries;

• managing, planning, advertising and administering programs, events and competitions;

• researching, developing and expanding our facilities and services;

• informing you of our activities, events, facilities and services;

• recruitment processes (including for volunteers, internships and work experience); and

• responding to enquires and complaints.

Constantinople generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:

• our affiliated and related companies; and

• third-party suppliers and contractors who assist us to operate our business.

Constantinople also collects and uses personal information for market research purposes and to innovate our delivery of products and services.

How does Constantinople interact with you via the internet?

You may visit our websites www.cxnpl.com without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to Constantinople will be managed in accordance with this Privacy Policy.

Constantinople's websites use cookies. A “cookie” is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.

Constantinople's websites may contain links to third-party websites. Constantinople is not responsible for the content or privacy practices of websites that are linked to our website.

Can you deal with Constantinople anonymously?

Constantinople will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for Constantinople to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

How does Constantinople hold information?

Constantinople stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

Constantinople maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.

We take steps to destroy or de-identify information that we no longer require.

Does Constantinople use or disclose your personal information for direct marketing?

Constantinople may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.

If you opt-out of receiving marketing material from us, Constantinople may still contact you in relation to its ongoing relationship with you.

How does Constantinople use and disclose personal information?

For clients

The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services.

For customers and participants

If you are a customer or participant in an event, we may disclose your personal information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.

Disclosure to contractors and other service providers

Constantinople may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.

Personal information may also be shared between related and affiliated companies of Constantinople, located in Australia and overseas.

Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

Use and disclosure for administration and management

Constantinople will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:

• administering billing and payments and debt recovery;

• planning, managing, monitoring and evaluating our services;

• quality improvement activities;

• statistical analysis and reporting;

• training staff, contractors and other workers;

• risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);

• responding to enquiries and complaints regarding our services;

• obtaining advice from consultants and other professional advisers; and

• responding to subpoenas and other legal orders and obligations.

Other uses and disclosures

We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

Does Constantinople disclose your personal information overseas?

Constantinople is a global organisation and works with clients, service providers, sponsors and commercial interests across the globe. It is likely that your personal information will be disclosed to overseas recipients.

Unless we have your consent, or an exception under the APPs applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.

Entities which are related entities of Constantinople, or are otherwise affiliated with Constantinople, have operations in Singapore and India. In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which Constantinople and its related entities and affiliates operate.

How can you access or seek correction of your personal information?

You are entitled to access your personal information held by Constantinople on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.

You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

What should you do if you have a complaint about the handling of your personal information?

You may contact Constantinople at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Constantinople may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.

How changes are made to this privacy policy?

Constantinople may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

How can you contact Constantinople?

The contact details for Constantinople are:

Constantinople Privacy Officer

Address: Level 4, 725-731 George Street, HAYMARKET NSW 2000

Email address: privacy@cxnpl.com

This Privacy Policy was last updated in 2025