Effective from 21/11/2025
1.1 This Privacy Policy (“Privacy Policy” or “Policy”) has been prepared by Gate Information Pty Ltd (ABN: 60 659 401 617) (“Gate”, “we”, “us”, “our” or “ours”). The Privacy Policy, together with our User Agreement (“Terms”) and all other terms, conditions and policies published on the Platform (as defined below), govern your access to and use of the Platform. Prior to using this Platform, you (“user”, “you”, “your” or “yours”) personal confirm acceptance of these policies, which supplement and are incorporated into our Terms. This Policy does not intend to override the Terms. Any terms, words, phrases which are not defined in this Policy shall have the same meanings as ascribed to them in the Terms.
1.2 When you visit our website, pages, features, mobile applications, API and or other products and services (“Platform”), and more generally use or participate in any of our Services through our Platform, we appreciate you trusting us with your personal information. Personal information includes any information which may, by itself, or in collaboration with other information be able to identify you. Gate takes your privacy very seriously; and this Policy, as amended from time to time, sets out how Gate collects, processes, uses, maintains, stores, retains, transfers, discloses, erases or destroys your confidential and personally identifiable user data, as well as aggregated and anonymized data obtained from and through the Platform and related services offerings, via the Platform. The specific data points which we collect from you are explained below in this Policy. We are committed to protecting your information and right to privacy.
1.3 By opening an account with Gate (“Account”) and/or using our services and Platform, you acknowledge that you accept terms of this Privacy Policy. We encourage you to read this Policy carefully before proceeding further as it forms part of our Terms.
2.1 Gate is enrolled and registered with the Australian Transaction Reports and Analysis Centre (“AUSTRAC”) as a provider of digital currency exchange services, and this Policy has been prepared in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and other applicable Australian law guidance and international best practices. We may make amendments to this Policy.
2.2 From time to time, we may revise, amend or supplement this Policy to reflect necessary changes in law, our personal information collection and handling practices, the features of our Platform, advances in technology, or as required by regulator. If we make material changes to this Policy, we will publish the updated version on our website and, where practicable, notify you by email or via the Platform. We encourage you to review this Policy periodically to ensure you are aware of the current terms whenever you use our services.
2.3 Changes to this Policy are effective from the date on which they are published on our website or otherwise made available to you.
3.1 Users’ personal information is collected and processed in accordance with relevant principles, including: lawfulness, fairness and transparency; for specific and clear purpose, purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality (security) and accountability; with all relevant laws and regulations considered; and however applicable.
4.1 You provide consent to your personal data (whether provided directly by you, whether collected by us, or received by us from third parties or otherwise) being processed to satisfy all legal obligations arising from any contracts entered into/ with/ involving you or to deliver any services to you; or to take steps at your request prior to entering into a contract with you; or for our legitimate interests to protect our property, rights or safety of either Gate, its users, customers, clients, other persons or other entities.
4.2 The specific data points which we collect, the method by which we collect such data, the purposes for which we collect such data, how we share such data, and how long we retain such data is explained individually and specifically for your precise, informed and unambiguous consent below in this Policy.
5.1 The information you provide, or which we obtain from other sources will be used by us, in accordance with this Policy, read in conjunction with our Terms, other policies and the applicable laws. The table below specifies which data points we may collect (depending on the circumstances and needs), by what method and for what purposes.
| Type of Data Collected | How We Collect It | Purpose / Use |
|---|---|---|
| Personal information (e.g., full name, email, phone number, date of birth, address, government-issued ID, passport, billing info) | Directly from you when registering, updating your account, or interacting with customer support | Account creation and management, identity verification (KYC), compliance with AUSTRAC and AML/CTF obligations, fraud prevention, and providing services |
| Financial information (e.g., virtual asset holdings, wallet addresses, trading activity, deposits and withdrawals, and, where required, supporting documents such as bank statements, payslips, contracts, or other financial records to verify Source of Funds/Source of Wealth ) | Directly from you during deposits, withdrawals, and transactions | Processing payments, managing orders, administering fees, preventing fraud, compliance with financial and regulatory obligations |
| Account credentials (e.g., username, password, security PINs, API keys) | Directly from you during registration and account updates | Secure access to your account, account management, and fraud prevention |
| Device & technical information (e.g., IP address, device ID, operating , browser type, geolocation, server logs) | Automatically via Platform, app, cookies, or tracking scripts | Platform operation, service improvement, security monitoring, analytics, fraud prevention, personalization, and regulatory compliance |
| Usage data (e.g., transaction behavior, interaction with Platform features, activity history) | Collected from your activity on the Platform | Service personalization, monitoring trends, improving user experience, detecting misuse or fraud |
| Biometric / identity verification data (e.g., selfie photo, video, government IDs) | Directly from you or via authorized third-party verification providers | Identity verification, KYC/AML compliance, fraud prevention, regulatory reporting |
| Information from third parties (e.g., credit bureaus, identity verification services, government authorities, marketing partners) | Collected with your consent or as required by law | Fraud detection, identity verification, compliance with regulatory obligations, marketing or promotional purposes |
| Marketing & preferences data (e.g., feedback, survey responses, communication preferences) | Directly from you when submitting feedback, surveys, or preferences | Tailoring communications, improving services, administering rewards or contests |
| Aggregated, anonymized, or deidentified data | Generated internally from your activity or third-party data | Analytics, service improvement, reporting, compliance, and statistical purposes |
5.2 You acknowledge and agree that Gate may collect your personal information in the following ways:
i. Directly from you when you register for an account, update your account information, communicate with our customer support or administrative staff, provide feedback, participate in surveys or contests, or conduct transactions through the Platform.
ii. Directly from you during transactions, including payment processing, linking bank accounts, debit/credit cards, wallets, or other payment instruments.
iii. Automatically through the Platform or app, including via cookies, tracking scripts, server logs, device identifiers, IP addresses, operating information, network information, geo-location data, browsing activity, and other usage metrics.
iv. From third-party service providers and government-authorized or mandated entities, including identity verification services, credit bureaus, payment service providers, and other third parties, provided that such collection is permitted by law or authorized by you.
v. Internally generated data, including statistical, aggregated, anonymised, or de-identified data derived from your personal information for analytics, reporting, service improvement, or regulatory compliance purposes.
vi. From your interactions with the Platform, app, or customer support, including one-time passwords (OTPs), security codes, communications, preferences, or surveys.
vii. From regulatory, legal, or compliance sources, including internal compliance checks, fraud investigations, and reporting obligations to regulatory authorities, as required under applicable law.
Gate collects personal information for purposes including, but not limited to, account creation and management, KYC/AML/CTF compliance, fraud prevention, transaction processing, regulatory compliance, and improvement of our services.
5.3 You undertake that all personal information provided to us by you is true, complete and accurate and you must notify us of any changes to such personal information.
5.4 We do not collect data about actual or alleged criminal offences from you, yet we may obtain the relevant information from other sources and retain such information for the purpose of complying with the applicable laws and regulations.
5.5 To the extent that any sensitive personal information (including biometric, health-related, or government-issued identifiers) is collected, you acknowledge and agree that Gate may collect, use, and disclose such information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and other applicable laws. You expressly consent to Gate collecting, using, and disclosing your sensitive personal information for purposes including, but not limited to, identity verification, KYC/AML/CTF compliance, fraud prevention, regulatory reporting, and the provision of services. You may withdraw your consent at any time by contacting Gate; however, withdrawal may affect Gate’s ability to provide certain services or to comply with its legal and regulatory obligations. Gate will take reasonable steps to ensure that your sensitive personal information is protected from misuse, interference, loss, unauthorized access, modification, or disclosure in accordance with Australian law.
6.1 We may also create, process, collect, use and share aggregated, anonymised or deidentified data such as statistical or demographic data for any purpose which may be derived from your personal data. We may use this data to comply with legal or regulatory obligations.
6.2 We may share your data with members of our group (including our affiliates, subsidiaries, parent companies, joint venture partners, entities we control and entities under common control) (“Group”), service providers and our key partners. Some of these third parties may be in a jurisdiction outside the laws as stated in this Policy, in which case we will take all necessary steps to ensure that your personal information is treated securely and that such transfers are permitted under the applicable data protection laws.
6.3 We may also use any or all of the personal information above to administer and manage our business in general, to detect and prevent misuse of our services (including fraud and unauthorised payments), and to enforce our Terms or any other contract to which we may be a party to.
7.1 We may use cookies and similar technologies that automatically collect certain information from your browser or device when you visit our Platform, read our emails, use our Service or otherwise engage with us.
7.2 What are cookies? : A cookie is a piece of data contained in a very small text file that is stored in your browser or elsewhere in your hard drive. We use cookies, web beacons, log files, and a variety of similar technologies (collectively, “cookies”) to collect information from your browser or device. These technologies collect information about how you use the Service (e.g., the pages you view, the links you click, and other actions you take on the Service), information about your browser and online usage patterns (e.g., Internet Protocol (IP) address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email, links clicked), and information about the device(s) you use to access the Service (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating brand and model, and whether you access the Service from multiple devices).
7.3 How we use the information collected through cookies: We may use the information collected through these technologies to better display our Platform, to save you time, to provide better technical support, for promotional purposes, measure and analyze Platform usage, and other internal purposes.
7.4 Types of Cookies: The types of Cookies we may use are set out below.
| TYPES OF COOKIES | ||
|---|---|---|
| S No. | Type of Cookie | Description |
| 1. | Strictly Necessary (also known as Essential or Required Cookies) | Necessary for the operation of the Site. We may use essential cookies to authenticate users, prevent fraudulent use of user accounts, or offer Platform features. |
| 2. | Functional | Allow us to recognize and count the number of visitors and see how visitors move around the Site when using it. This helps us improve the way the Platform works. |
| 3. | Analytic | Used to recognise you when you return to the Platform. This enables us to personalise our content for you and remember your preferences. |
| 4. | Tracking | Record your visit to the Platform, the pages you have visited, and the links you have followed. We will use this information to make the Platform and the content more relevant to your interests. We may also share this information with third parties for this purpose. |
7.5 Your choice of cookies: You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Platform, services and/or features may no longer be available to you or function properly
8.1 If you fail, neglect and/ or refuse to, or are unable to provide us any personal information which we necessarily need to provide you with the services or the Platform, which we need to collect by law, we may not be able to provide you services through the Platform. In this case, we have the right to discontinue the provision of the Platform to you and/or close your Account. In such a situation, we will notify you at the earliest.
9.1 The Platform may be accessible to users below the age of 18 years, but only under parental or legal guardian supervision. For such users, we may collect personal information about the minor only to the extent reasonably necessary to provide the Platform services and comply with legal and regulatory obligations. We endeavour to minimise the collection of personal information from minors. For users below the age of 18 years, we will, on a best-effort basis, seek the information of their legal guardian for documentation, financial, security, and operational purposes. By using the Platform, you represent and warrant that you are at least 18 years old, or that you are a minor using the Platform under the supervision and legal responsibility of your legal guardian, or that you are the legal guardian of such a minor and consent to the minor’s use of the Platform and the collection of their personal information as described in this Policy. If we become aware that these requirements are not met, we may, at our discretion, deactivate the account and take reasonable steps to promptly delete the personal information collected.
10.1 We may collect and process some of your personal information without your knowledge or consent as permitted by law. We may be compelled to surrender your personal information to legal authorities without your express consent, if presented with a court order or similar legal or administrative order, or as required or permitted by the laws, rules and regulations of any nation, state or other applicable jurisdiction.
11.1 We provide you with choices regarding the personal data we use, particularly concerning any market research and/or subsequent marketing, advertising and promotion. Towards this, we have established these personal information control mechanisms:
A. Promotional offers from us: We may use your personal information to determine what may be of interest to you. This is how we decide which products, services, and offers may be relevant and of interest to you. By using our Platforms, registering an Account, contacting us, requesting information from us, you consent to receiving marketing communications from us. We may communicate with you by e-mail, fax, telephone, or other agreed channel of communications.
B. Opting out: You can ask us or third parties to stop sending you marketing related material and/ or communications at any time by following the opt-out links on any marketing message sent to you or, if the marketing related materials and/or communications are sent by us, then by contacting us at suppot_au@gate.com.
12.1 We may have to share your personal information with a selected and trusted group of third party/parties to fulfil our obligations under our contract with you, to meet government, regulatory and law enforcement requests, and to continue providing you with the services. We will only disclose your personal information to third party service providers under strict terms of confidentiality. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
12.2 We may have to share or transfer your personal information in the specific circumstances listed below:
A. Consent based: We will share your personal information with companies, outside organisations or individuals, if we have your consent to do so.
B. To comply with applicable law, judicial requirements, government requests, etc.: Where we are legally required to do so, we may disclose your personal information to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements), or where we find it is necessary to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved disclose your personal information. Additionally, we may disclose your personal information to enforce our Terms, or to protect the rights, safety, and security of Gate, our users, other persons or the public.
C. Merger, acquisition etc.: In connection with, or during negotiations of, any merger, sale of our assets, financing, acquisition of all or a portion of our business to another company, any dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your personal information may also be transferred as a business asset forming part of our good will. If another company acquires us, our business or assets, that company will possess the personal information collected by us and will assume the rights and obligations held by us regarding your personal information, as described in this Policy.
D. Advertisements: Where we use third party advertising companies to serve ads when you visit or use the Platforms. These companies may use information about your visits to our Platforms and other Platforms that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you, provided you have consented to the same.
E. Affiliates: We may share your personal information with our Group in order to provide you with certain services and/or functions, in which case we will require those Group members to honour this Policy.
F. With selected third party vendors: In connection with the performance of our services, we may share your personal information with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples of such third parties include payment processing, customer relationship management, data analysis, email delivery, hosting services, customer service, quality assurance testing, technical support, operational support and maintenance services and marketing efforts.
13.1 Our Platforms or communications may contain links to other third-party websites which are not owned or operated by us and are regulated by their own privacy policies. If you click on a third-party link, you will be directed to that third party’s platform. We strongly advise you to review the privacy policy of every platform you visit. We are not responsible for the privacy policies of these third-party websites, regardless of whether they were accessed using the links from our Platform. We have no control over and assume no liability for the content, privacy policies or practices of any third-party platforms or services.
14.1 Depending on the country in which you are resident you may have certain rights. These rights may include:
A. Right to be Informed: This means you have a right to know:
i. The identity and the contact details of Gate;
ii. The purposes for which your personal information is collected, used, and disclosed;
iii. The legal basis for processing your personal information, where applicable;
iv. The recipients or categories of recipients of your personal information;
v. Where your information is transferred overseas, the protections or safeguards applied;
vi. The period for which your personal information will be stored, or if that is not possible, the criteria used to determine that period;
vii. Whether providing personal information is voluntary or required, and the consequences of not providing it;
viii. Any automated decision-making that significantly affects you, including profiling, and meaningful information about the logic involved and consequences;
ix. Any additional purposes for processing different from the original purpose;
x. Actions to be taken in case of personal data breach;
xi. How to make a complaint to Gate or the Office of the Australian Information Commissioner (OAIC).
B. Right of Access: You have a right to see what personal information is held about you by us. Particularly you have the right to:
i. Receive confirmation as to whether or not your personal information is being processed;
ii. Access your personal information which we are processing along with the purposes of processing; the categories of personal information being processed; the recipients or categories of recipient to whom the personal information has been or will be disclosed; the envisaged period for which the personal information will be stored, or, if not possible, the criteria used to determine that period; where the personal information are not collected from you, any available information as to their source.
iii. Where your personal information is transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards relating to the transfer;
iv. A copy of your personal information being processed; and
v. Any further copies requested by you, upon paying a reasonable fee.
C. Right to Correction: This is your right to have your personal information corrected, rectified or amended, if what is held by us or a third party onboarded by us is incorrect/ inaccurate in some way.
D. Right to Erasure: This is your right, under certain circumstances to ask for your personal information to be deleted. This would apply if your personal information is no longer required for the purposes it was collected for, or your consent for the processing of that data has been expressly withdrawn, or where your personal information has been unlawfully processed. Once deleted all your personal data will be removed from our s and will not be recoverable.
E. Right to Withdraw Consent: If you wish for Gate to stop processing your personal information, it is your right to withdraw consent at any time, preventing Gate from further processing the same personal information.
F. Right to Restrict Processing: This is your right to ask for a temporary halt or pause in processing your personal data, such as in the case where a dispute or legal case must be concluded, or the data is being corrected.
G. Right to Data Portability: This is your right to ask for your personal information supplied directly to us, which we have processed pursuant to your consent, under a contract, or by automated means, to be provided to you in a structured, commonly used, and machine-readable or electronic format.
H. Right to Object: This is your right to object to the further processing of your personal information which is inconsistent with the primary purpose for which it was collected, which includes profiling, automation and direct marketing.
I. Rights in Relation to Automated Decision Making and Profiling: This is your right not to be subject to a decision based solely on automated processing.
14.2 You agree that the rights provided in section 14.1 above may be subject to limitations. In certain circumstances, your requests may be rejected or declined due to any of the following reasons:
14.3 We aim to respond to all legitimate requests promptly and within 30 days. In complex cases or multiple requests, we will notify you of delays and keep you updated. To exercise any of your rights under this Privacy Policy, please contact us at suppot_au@gate.com. Gate may require additional information to verify your identity before processing your request, to ensure that your personal information is not disclosed to unauthorized persons
15.1 Whenever possible, you can update your personal information, subject to verification by us. If you wish for us to update your personal information, please contact us at suppot_au@gate.com, or proceed to amend the same in your Account on the Platform. We will retain your personal information for as long as your Account has not been closed or as may be needed to provide you access to your Account and/ or services, and in compliance with the law.
16.1 We retain information on your behalf, including customer data, transactional data and other session data, linked to your Account. Should any further information be required, please contact us at suppot_au@gate.com.
16.2 Your personal information will be stored, retained, and processed for no period longer than as required by us for the purposes it was collected for, for the purposes of using the Platform, and for meeting any legal, accounting, reporting, government, regulatory or law enforcement requirements. Unless required for any of the purposes specified above, we will delete personal information related to closed Accounts every 12 calendar months, except for records relating to customer identification, verification, transactions, and AML/CTF reporting, which will be retained for a minimum of 7 years as required under the AML/CTF Act.
16.3 To determine the appropriate retention period for your personal information, the criteria we consider includes the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorised use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there are legal or contractual obligations that mandate us to retain data for a particular period of time; whether there is any legal or financial claim in relation to your business relationship with us and the applicable legal requirements.
16.4 When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
17.1 Your personal information is stored and transferred in compliance with the applicable legislations and regulations of Australia. Our data processing and storage may occur on servers located outside Australia. Where we disclose personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient protects the information in a manner consistent with the Privacy Act 1988 (Cth) and the APPs.
17.2 Some of the international organisations and countries to which your personal information may be transferred do not benefit from an appropriate data protection regulatory framework. For such international organisations and countries, we shall transfer your personal information, only upon ensuring that a suitable degree of protection is afforded to it through the implementation of the necessary safeguards, such as an adequacy decision by the relevant authority, adequate binding corporate rules or through the inclusion of standard contractual clauses in our agreements with such organisations and countries.
18.1 If you wish to close your Account, please use the relevant option within your Account on the Platform. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms.
19.1 We are committed to ensuring that your information is secure. To protect your personal data and information from loss, theft, misuse, alteration, destruction, unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. We use industry-standard technical mechanisms, password protected directories and databases and ensure that our affiliates or vendor entities use data encryption technology while implementing restrictions related to the storage of and the ability to access your personal information.
19.2 Our facilities are scanned on a regular basis for security holes and known vulnerabilities, to best ensure its security.
19.3 Your personal information is contained behind secured networks and is only accessible by a limited number of individuals who have special access rights to such s and are required to keep the information confidential.
A. No guarantee
I. Please note that no transmission over the Internet or any method of electronic storage can be guaranteed to be absolutely 100% secure, however, our best endeavours will be made to secure data and the ability to access your personal information.
II. Without prejudice to our efforts on protection of your data, nothing contained in this Policy constitutes a warranty of security of the facilities, and you agree to transmit data at your own risk.
III. Please note, that we do not guarantee that your data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
IV. Please, always check that any website on which you are asked for financial or payment information in relation to our Platform is in fact legitimately owned or operated by us. The risk of impersonating hackers exists and should be taken into account when using our Platform.
V. If you do receive any suspicious communication of any kind or request, do not provide your information and report it us by contacting our offices immediately at suppot_au@gate.com. Please also immediately notify us at suppot_au@gate.com if you become aware of any unauthorised access to or use of your Account.
VI. Since we cannot guarantee against any loss, misuse, unauthorised acquisition, or alteration of your data, please take the necessary steps to protect your own personal information, including the adoption of sufficient safety measures such as your choosing of an appropriate password of sufficient length and complexity and to not reveal this password to any third parties.
VII. We will use reasonable measures to protect data in transit, but cannot guarantee absolute security for transmissions via third-party networks or channels. Furthermore, we cannot ensure and do not warrant the security or confidentiality of data transmitted to us, or sent and received from us by Internet or wireless connection, including: email, phone, over-the-top (OTT) messaging services or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at suppot_au@gate.com.
VIII. Should your personal information be breached, and the security of your rights be at high risk, we shall promptly and immediately communicate to you the nature of the breach which has taken place, the likely consequences of such a breach and shall describe thoroughly the measures we have implemented to address the breach and to mitigate any and all adverse effects to you and your rights. In the unlikely event of a breach occurring, please reach out to us a tsuppot_au@gate.com or further information and for further advise on how to mitigate the potential adverse effects of such a breach.
IX. We also aim to conduct all applicable security risk assessments to ensure the availability of risk mitigation controls, to better safeguard the integrity of your data.
20.1. In the case of abuse or breach of security, we are not responsible for any breach of security or for any actions of any third parties which receive the information illegally.
20.2. We will not distribute customer information to be used in mailing lists, surveys, or any other purpose other than what is required to perform our services.
20.3 If you choose to restrict the collection or use of your confidential and personal information, please stop using the Platform immediately.
20.4 In the event that there is any incident affecting, or potentially affecting personal data, we In the event of a data breach, we will comply with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth) and notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required. We will provide affected individuals and the OAIC with all relevant information about the breach, including the nature of the breach, potential consequences, and remedial actions taken.
21.1 If you have any questions about our Policy as outlined above, or if you have any complaints, queries of issues pertaining to your personal information, then please contact our DPO at support_australia@gate.com.