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Legal

Who Pennie is for, how we handle your information, and the rules for using Pennie. Last updated 29 October 2026.

Target Market Determination

Pennie Pay Advance Contract. Issuer and distributor: Jingle Finance Pty Ltd (ACN 132 485 066) trading as Pennie ("we", "us"). Version 1 (draft). Date: 29 October 2026. Next review due: no later than 12 months after the date above.

1. About this document

This Target Market Determination (TMD) describes the customers for whom the Pennie Pay Advance Contract is likely to be appropriate, the conditions on how it is distributed, and when we will review this TMD. It does not describe every term of the product and is not advice. Customers should read the contract terms before accepting an advance.

2. Target market

The Pennie Pay Advance Contract is designed for people who:

It is not designed for people who:

3. Key product attributes and why they suit the target market

These features suit the target market because the amount is small, the term is short, and the cost and repayment date are shown upfront and tied to pay the customer has already earned.

4. Distribution conditions and channels

The product is distributed only through the Pennie website, directly by us. We do not use third-party distributors. Before an advance is offered we verify the customer's identity, connect to their bank account using a read-only connection and confirm their employment and income. Customers who do not meet the criteria in section 2 are not offered an advance, and our marketing must be consistent with this TMD.

These conditions make it likely that customers who take the product are in the target market, because eligibility is checked automatically, and only by us, before each advance.

5. Review of this TMD

We review this TMD no later than 12 months after it is first made, and no later than 12 months after each review. We also review it earlier if any of the following occurs, or if anything else suggests the TMD is no longer appropriate. A review starts within 10 business days of us becoming aware of the event.

6. Records and reporting

We record complaints about the product. If we become aware of a significant dealing in the product that is not consistent with this TMD, we notify ASIC in writing as soon as practicable, and within 10 business days. This TMD is available free of charge on our website.

Questions about this document: hello@pennie.com.au.

Privacy Policy

How Jingle Finance Pty Ltd (ACN 132 485 066) trading as Pennie collects, holds, uses and discloses your personal information, and how you can access or correct it.

Introduction

Jingle Finance Pty Ltd (ACN 132 485 066) trading as Pennie ("we", "us", "our") is committed to complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (together, "Australian Privacy Law"). This policy applies to everyone who uses our website or service, deals with us, or whose personal information we collect, including people who apply for or hold an advance from us. Last updated 29 October 2026.

Pseudonyms

You do not have to give us your name or any personal information. However, we cannot provide an advance without first verifying your identity, so we will not continue to deal with you unless we obtain your true name and other verifiable information.

The kinds of personal information we collect

When you visit our website we may record the domain name and IP address of your device, the date and time of your visit, the website you came from, the pages you viewed, and your email address (through cookies, anonymous identifiers and session variables). Your internet provider or browser supplier may also collect information of this kind for its own purposes. We are not responsible for that, and you should refer to their privacy policies.

When you deal with us as a prospective or existing customer, we may also collect:

If you apply for an advance, we also collect the credit-related information we need to assess and administer it. We do not collect sensitive information.

How we collect your personal information

We may use technologies such as cookies, anonymous identifiers and session variables on our website. Your browser may let you block or restrict cookies, but some features may then work less well or not at all.

We collect most information directly from you, online, in person, by phone, by post or email, or through forms. Where it would be impractical or unreasonable to collect it from you, we may collect it from other sources such as a person you authorise (for example an agent or financial counsellor), your employer, a government agency, a financial institution, or our identity verification and bank connection providers.

How we hold your personal information

We use reasonable measures to keep personal information secure, including a secure storage environment, access limited to authorised personnel, and encryption and password protection for electronic records. We are not responsible for the security of any device you use to access our website.

Why we collect, hold, use and disclose it

We collect, hold, use and disclose personal information only for purposes permitted by Australian Privacy Law, including to:

Overseas recipients

We do not currently disclose your personal information to recipients outside Australia. If that changes, we will update this policy.

How you may access your personal information

You may ask for access to the personal and credit information we hold about you by identifying yourself and contacting us at: Jingle Finance Pty Ltd (ACN 132 485 066) trading as Pennie, Suite 22, 4 Young Street, Neutral Bay NSW 2089, email hello@pennie.com.au.

If we cannot give you access, we will tell you why in writing within a reasonable period. Reasons can include that giving access would disclose another person's information, create a risk to someone's health or safety, not be permitted by law, or disclose commercially sensitive internal information that Australian Privacy Law does not require us to release.

How you may correct your personal information

If you think information we hold about you is inaccurate, contact us, identify yourself, and tell us what is inaccurate and how you would like it corrected. If we cannot agree to the correction, we will tell you why in writing.

How you may complain about how we handle your personal information

If you are not satisfied with our reasons, or you want to complain about how we collect, hold, use or disclose your personal information, contact our Privacy Officer at hello@pennie.com.au or by post at Suite 22, 4 Young Street, Neutral Bay NSW 2089. We will follow our privacy internal dispute resolution process.

If you remain dissatisfied, you can contact the Office of the Australian Information Commissioner: GPO Box 2999, Canberra ACT 2601. Tel 1300 363 992. Website www.oaic.gov.au.

Changes to this policy

We may change this policy because of changes in the law, technology or our systems. Changes will be published on our website. Where a change affects you in a particular way and the law requires us to notify you, we will do so.

Terms of Use

The rules for using the Pennie website and service. Please read them before you sign up.

Agreement

These Terms of Use ("Terms") are a legally binding agreement between Jingle Finance Pty Ltd (ACN 132 485 066) trading as Pennie ("we", "us" or "our") and you, for your use of the Pennie website, its subdomains, our mobile app and any associated tools, content and services (the "Service"). By registering, accessing or using the Service you agree to be bound by these Terms. If you do not accept them, you must not use the Service. Last updated 29 October 2026.

1. Disclaimer

Unless we say otherwise, content on the Service is general information only. It is not legal, financial or professional advice, and you should get independent advice suited to your circumstances. We publish it in good faith, on an "as is" and "as available" basis and, so far as the law allows, without warranty.

2. Eligibility, acceptable use and enforcement

The Service is for residents of Australia who are 18 or over. You must use it lawfully and responsibly. You must not:

We may suspend, restrict or end your access, with or without notice, if we reasonably consider that you have breached these Terms or acted unlawfully or harmfully.

3. Identification and authorisation

If you open an account we will ask for an identity document so we can verify who you are. If you take an advance we may also ask for or update your bank account details so we can assess your eligibility. You confirm that you are authorised to give us your ID and bank details and to access and share your bank account information, and you consent to us checking your ID against official records.

You authorise us and our third-party providers to collect, use and disclose your ID and bank account information to operate the Service, including to verify your identity, assess your eligibility, prevent fraud and meet our legal obligations (including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)). Your ID details are passed to our verification provider and stored securely to the extent reasonably needed to operate the Service and meet record-keeping obligations.

4. Third-party services and bank connection

We use third-party providers for identity verification, data analytics and bank connection. If you connect a bank account, our provider retrieves your bank information from time to time on your behalf to operate the Service. We do not receive or store your internet banking credentials. We take reasonable steps to make sure our providers comply with applicable laws, but we are not responsible for the content or practices of any website or service we do not operate.

5. Contract terms

These Terms apply to your access to and use of the Service. If we give you an advance, it is governed by separate contract terms covering repayments, fees, interest and disclosures. Fees, interest and repayments are set out in your contract and shown to you before you accept. If there is any inconsistency, the contract terms govern the advance and these Terms govern your use of the Service.

6. Privacy

Our Privacy Policy explains how we handle personal information. By accepting these Terms you acknowledge it. If there is an inconsistency about personal information, the Privacy Policy prevails. In all other cases these Terms prevail.

7. Marketing communications consent

When you open an account, and each time you take an advance, you will be asked to consent to receiving marketing from us by email and, if you give us a mobile number, by SMS. Every message will identify us and include a working unsubscribe option. We process unsubscribe requests within 5 business days.

8. Changes to the Terms

We may revise these Terms at any time. Unless we say otherwise, changes take effect when the updated Terms are posted on our website or in the app. For material changes we will try to give reasonable notice. If you do not accept the updated Terms you should stop using the Service. Continuing to use it on or after the effective date means you accept them.

9. International use

We comply with Australian law in relation to online activities. You are responsible for making sure your use of the Service complies with the laws that apply where you are. We make no promise that the Service is appropriate or available in every jurisdiction.

10. Limitation of liability

To the fullest extent permitted by law, we and our employees, directors, contractors, agents, licensors, suppliers, third-party providers, subsidiaries and affiliates exclude every warranty, representation and condition not expressly stated in these Terms (including that the Service will be accurate, reliable, uninterrupted or free of errors or viruses), and accept no liability for indirect or consequential loss, or loss of revenue, profit, goodwill or data, arising in connection with the Service.

11. Regulatory status and consumer rights

The Pennie Pay Advance Contract is not regulated by the National Credit Code or the National Consumer Credit Protection Act 2009 (Cth). Nothing in these Terms excludes, restricts or modifies any right or remedy you have under Australian law that cannot lawfully be excluded, including rights under the Australian Consumer Law and the Australian Securities and Investments Commission Act 2001 (Cth).

12. Indemnity

You agree to indemnify us and our employees, directors, contractors, agents, licensors, suppliers, third-party providers, subsidiaries and affiliates against claims, losses, liabilities, expenses, damages and costs (including reasonable legal costs) arising from your breach of these Terms, your misuse of the Service, or your negligent, unlawful or wrongful conduct. This does not apply to the extent the loss is caused by our negligence, fraud or wilful misconduct.

13. Service changes and suspension

We may alter, suspend or end access to all or part of the Service, including for particular users, where it is reasonably necessary, for example to comply with the law or a regulator, address security or operational risks, prevent fraud or misuse, or carry out maintenance. Where reasonable we will try to give advance notice. We may act immediately and without notice where the law requires it or urgent action is needed to protect the Service or its users.

14. Copyright and intellectual property

Unless we say otherwise, all content on the Service, including text, graphics, logos, icons, images, audio, video, downloads and software, belongs to us or our licensors and is protected by Australian and international copyright, trade mark and other intellectual property laws. You may use it for personal, non-commercial purposes only. Without our written consent you must not reproduce, modify, republish, upload, post, transmit or distribute it, except as permitted by the Copyright Act 1968 (Cth) or other applicable law. We reserve all rights not expressly granted.

15. Licence

We grant you a limited, non-exclusive licence to use the Service for personal, non-commercial purposes. You must not frame, or use framing techniques to enclose, any trade mark, logo or other proprietary information without our written consent.

16. Security and viruses

We do not promise that files available for download through the Service will be free of viruses, worms, Trojans or other harmful code. You are responsible for maintaining appropriate security measures.

17. Account security

You are responsible for keeping your username and password confidential. We are not liable for any loss from unauthorised access that results from your failure to protect them.

18. Electronic communication and signature

You consent to receiving communications and documents from us electronically (for example by email, SMS or in the app) rather than on paper, unless the law requires otherwise. You are responsible for keeping access to those channels and your contact details up to date. You also consent to electronic signatures, and agree that accepting electronically (for example selecting "I agree") is your legally binding signature.

19. General provisions

If we do not enforce part of these Terms, that is not a waiver of any right. These Terms are not modified by any course of conduct. If a term is invalid or unenforceable it is severed and the rest continue. We may assign our rights and obligations at any time without notice. All rights not expressly granted are reserved.

20. Complaints and financial difficulty

If you have a complaint or dispute about the Service, contact us so we can try to resolve it. If you are experiencing financial difficulty, contact us so we can help you with your options.

21. Applicable law

These Terms are governed by the laws of Australia and of the State of New South Wales. Any dispute that is not resolved is subject to the exclusive jurisdiction of the courts of New South Wales and the courts that hear appeals from them.

22. Contact

If you have questions about these Terms or the Service, contact us at hello@pennie.com.au.

Contact us

Questions, privacy requests, complaints or financial difficulty? Send us a message and the Pennie team will get back to you.

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