1. Purpose and scope

This Privacy Policy sets out how (we, us, our, NSW Mont De Piete and Brisbane Mont De Piete T/A Montys) manage personal information consistent with Australian privacy laws. This policy supports implementing consistent, compliant privacy practices.

This policy applies to pawnbroking operations conducted across Australian states and territories, including interactions with customers, clients, suppliers, employees, contractors, website users and individuals who buy, sell and whose goods are pledged as security.

This policy is principles‑based. It explains what commit to doing rather than listing every procedural detail. Supporting procedures, notices and staff training give effect to these principles in practice.

1.1 Privacy governance and accountability

We take an open and transparent approach to managing personal information. Our business maintains this Privacy Policy with supporting guidance and procedures, to ensure compliance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and applicable state and territory legislation.

Privacy responsibilities are clearly assigned within our business. We take reasonable steps to embed privacy considerations into day-to-day operations, including staff awareness, secure handling practices, oversight of third-party service providers and compliance with pawnbroking regulatory requirements.

This policy and associated practices are reviewed periodically and updated to reflect changes in operations, legal obligations, regulatory requirements or privacy risk profile.

1.2 The nature of pawnbroking activities

Pawnbroking involves unique information handling requirements arising from:

identity verification obligations under pawnbroking regulations and anti-money laundering laws
recording details of pledged/buying of goods to establish ownership, value and security
mandatory recordkeeping and reporting to regulatory authorities and law enforcement
customer assessments for buy/pawn loans and retail transactions
retention of transaction records for extended periods to meet legislative requirements

This policy recognises these requirements and ensures personal information is collected and used lawfully, fairly and only to the extent reasonably necessary.

2. Our privacy principles

We commit to the core principles when handling personal information. Each principle is supported by a ‘Principle in practice’ section explaining what this means in the day-to-day context of pawnbroking operations.

2.1 Lawfulness and fairness

We only collect and use personal information where there is a lawful and fair reason.

Principle in practice

We collect personal information where it supports a genuine pawnbroking activity, such as completing a pawn transaction, or complying with regulatory requirements.
We consider whether a customer would reasonably expect us to collect and use their information in the way proposed, given the nature of pawnbroking services.
We are transparent about mandatory collections (such as identity verification) versus optional information.

2.2 Purpose limitation

We collect personal information only for clearly defined business purposes related to pawnbroking operations.

Principle in practice

We explain why information is being collected at the time we collect it, including whether it is a legal requirement.
We do not reuse information for unrelated purposes without consent or legal authority.
Common purposes include: processing pawn loans, purchasing goods, verifying identity, preventing fraud, meeting recordkeeping obligations and responding to lawful requests from police or regulators.
If our purpose changes, we reassess whether continued use is appropriate and lawful.

2.3 Data minimisation

We collect and retain only the personal information that is reasonably necessary for pawnbroking functions and compliance with the law.

Principle in practice

We avoid asking for unnecessary details, while ensuring we meet identity verification and regulatory obligations.
We clearly identify optional information on forms and in customer interactions.
We regularly review records and remove information that is no longer required, subject to mandatory retention periods under pawnbroking and other legislation.
We apply heightened care to sensitive information and collect it only where genuinely required or permitted by law.

2.4 Transparency

We are open about how and why we handle personal information in business operations.

Principle in practice

Our privacy policy is easy to find, displayed in-store and available on our website.
We provide clear privacy statements on transaction forms, loan agreements and online services.
We explain to customers when we are required by law to collect, retain or disclose information to authorities.
We update our privacy information when practices change.

2.5 Accuracy

We take reasonable steps to ensure personal information is accurate, up to date and complete.

Principle in practice

We encourage customers to keep their contact information and personal details current.
We correct information when errors are identified or when a customer advises us their details have changed.
We verify identity documents at the point of collection to support accurate recordkeeping.

2.6 Security

We protect personal information against misuse, interference, loss and unauthorised access or disclosure.

Principle in practice

Access to personal information is limited to staff who need it to perform their role.
Passwords, user accounts and devices are not shared.
Paper records, pawn tickets, identification documents and transaction files are stored securely and not left in public view.
Electronic records are protected by access controls, encryption where appropriate and secure backup systems.
We are careful when sending information by email, post or using portable devices.
Suspected or actual data breaches are reported internally immediately and escalated according to legal requirements.

2.7 Access and correction

Individuals can access and correct their personal information, subject to lawful exceptions.

Principle in practice

Customer requests for access or correction are taken seriously and responded to promptly.
We verify identity before releasing personal information to prevent unauthorised disclosure.
If access is refused, we explain why where permitted by law.
Requests are directed to the privacy officer whose contact details are set out in this policy.

2.8 Accountability

We take responsibility for privacy compliance and continuous improvement.

Principle in practice

Privacy responsibilities are clearly assigned within the to the privacy officer
Staff receive training and guidance on privacy expectations including obligations specific to pawnbroking.
Privacy practices are reviewed periodically, and incidents are used to improve systems and processes.
We maintain records to demonstrate compliance when required by regulators or in response to complaints.

3. What is personal information?

Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether it is recorded in a material form or not.

In the context of pawnbroking, this commonly includes names, contact details, dates of birth, residential addresses, photographic identification, signatures, details of pledged/buy or sold goods, transaction history and online identifiers.

Some information is considered sensitive information (such as biometric data or information revealing racial or ethnic origin). We apply additional care and controls when handling sensitive information and collect it only where permitted by law or with consent.

4. Collection of personal information

We collect personal information only where it is reasonably necessary for our pawnbroking functions and activities or where required by law. We generally collect information directly from the individual, unless it is unreasonable or impracticable to do so.

We may collect personal information when you:

enter into a pawn agreement with pledge goods as security
purchase goods from us
sell goods to us
contact us or use our services, whether in-store, by phone, email or online
visit our website or interact with our online services
apply for employment or engage with us as a contractor or supplier
are involved in a transaction or enquiry that requires us to verify identity under pawnbroking regulations or anti-money laundering law.

Identity verification: Pawnbroking legislation in all Australian states and territories requires us to verify and record customer identity. This typically involves collecting government-issued photographic identification (such as a driver’s licence or passport), recording identifying details and in some cases retaining copies of identification documents. These requirements are mandatory and non-discretionary.

Third-party sources: We may collect personal information from third parties where it is unreasonable or impracticable to collect directly from the individual or where authorised by law. This may include fraud prevention databases, law enforcement agencies, regulatory authorities, or publicly available sources.

Where required by law, we will obtain consent before collecting personal or sensitive information. Where consent is not required by law, we will collect information fairly and lawfully and provide clear notice about the collection.

5. Use and disclosure of personal information

We use and disclose personal information only for:

the primary purpose for which it was collected (such as completing a pawn transaction, processing a purchase, a sale or verifying identity)
related purposes that an individual would reasonably expect, given the nature of pawnbroking services (such as managing ongoing pawn tickets or preventing fraud)
purposes required or authorised by law, including disclosure to police, regulatory authorities or courts
purposes to which the individual has consented

We do not sell personal information.

Common disclosures include:

Law enforcement and regulators: We are required by pawnbroking legislation and other laws to disclose transaction records, CCTV footage, identification details and details of pledged goods to police and regulatory authorities on request or in prescribed circumstances.
Service providers: We engage third-party service providers for functions such as IT support, payment processing, debt collection, legal advice and record storage. We take reasonable steps to ensure these providers handle personal information securely and consistently with this policy.
Business transactions: In the event of a sale, merger or restructure of the business, personal information may be disclosed to prospective purchasers or advisers, subject to confidentiality obligations.
Legal obligations: We may disclose information where lawful including in response to subpoenas, court orders or requests from government agencies.

6. Data quality and retention

We take reasonable steps to ensure personal information is accurate, current and complete. We encourage customers to notify us of any changes to their personal details.

We retain personal information only for as long as it is required for business, legal or regulatory purposes. Pawnbroking legislation in all jurisdictions requires transaction records, identification records and details of pledged goods to be retained for specified periods (commonly between one and seven years, depending on the jurisdiction and the type of record). We comply with these mandatory retention periods.

When information is no longer required and mandatory retention periods have expired, it is securely destroyed or de‑identified. Destruction methods include secure shredding of paper records and permanent deletion of electronic records.

7. Information security

We use a combination of administrative, technical and physical safeguards to protect personal information, including:

user authentication to limit access to authorised staff
secure storage of paper records in locked filing systems and restricted areas
secure storage and transmission of electronic records, including encryption where appropriate
staff training and awareness on privacy and security obligations
regular review and testing of security measures
incident response and data breach notification procedures
contractual obligations requiring third-party service providers to implement appropriate security measures

Despite these measures, no system is completely secure. If a data breach occurs that is likely to result in serious harm to affected individuals, we will respond in accordance with the Notifiable Data Breaches scheme under the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner where required.

8. Access and correction

Individuals may request access to personal information we hold about them and request correction if the information is inaccurate, out of date, incomplete or misleading.

Requests should be made to the privacy officer using the contact details set out in Section 13 of this policy. We may need to verify identity before responding to an access request to prevent unauthorised disclosure.

We will respond to requests within a reasonable timeframe (generally 30 days). We do not charge a fee for making a request, although we may charge a reasonable fee to cover the cost of providing access in complex cases (such as retrieving archived records). We will advise of any fee before proceeding.

In limited circumstances permitted by law, access may be refused or restricted. These include where:

providing access would pose a serious threat to the life, health or safety of any individual
providing access would have an unreasonable impact on the privacy of others
the request is frivolous or vexatious
providing access would interfere with law enforcement activities or an investigation
denying access is required or authorised by law

If we refuse access or correction, we will provide written reasons where permitted by law, and inform the individual of available complaint mechanisms.

9. Complaints and concerns

If you have a concern or complaint about how we handle personal information, please contact the Privacy Officer using the details in Section 13. We will investigate and respond within a reasonable timeframe (generally 30 days).

Our complaint handling process includes acknowledging receipt of the complaint, conducting an investigation, providing a written response and implementing corrective action where appropriate.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by phone on 1300 363 992.

10. State and territory privacy and pawnbroking requirements

In addition to the national requirements under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, pawnbroking is regulated by state and territory legislation. Each jurisdiction has specific requirements relating to recordkeeping, identity verification, retention periods and disclosure obligations.

We monitor and comply with applicable state and territory requirements where we operate. Specific requirements for each jurisdiction are set out in Appendix A: State and Territory Requirements, which forms part of this policy.

Where state or territory laws impose obligations that go beyond this policy, we comply with the higher standard. Where there is any conflict between this policy and applicable legislation, the legislation prevails.

11. Overseas disclosure

Personal information is generally stored and processed within Australia. Where personal information is disclosed or stored overseas (for example, through cloud-based service providers with offshore data centres), we take reasonable steps to ensure the overseas recipient handles the information in a manner consistent with the Australian Privacy Principles, unless an exception under the Privacy Act applies.

We will provide information about overseas disclosure locations and safeguards on request.

12. Policy governance and review

This policy reviewed periodically to ensure it remains accurate, effective and compliant with current laws

13. Contact details

Privacy enquiries, access requests and complaints may be directed to:

Privacy officer

Name Sebastien Shael Dawson

Email Address: sales@montys.com.au

Phone Number: 0732524988

Postal Address: POBox 1688 Fortitude Valley QLD 4006

This policy is intended to provide general guidance and does not replace legal advice.

Appendix A

Queensland

Applicable legislation:

Second-hand Dealers and Pawnbrokers Act 2003 (Qld)
Second-hand Dealers and Pawnbrokers Regulation 2004 (Qld)

Key requirements:

Identity verification: Pawnbrokers must sight and record details from government-issued photographic identification.
Record retention: Transaction records, including copies of identification documents, must be retained for at least 5 years.
Disclosure to police: Pawnbrokers must provide records to Queensland Police Service on request.