Privacy Policy

1. Overview

Synapse Virtual Solutions Pty Ltd trading as AusDora (“AusDora”, “we”, “us”, “our”) recognises the importance of protecting your privacy.

This Privacy Policy explains how we collect, hold, use, disclose, and protect personal information about individuals who interact with us, access or use the AusDora website, mobile applications, and related services (collectively, the Services).

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (Privacy Laws).

By accessing or using our Services, creating an account, or providing personal information to us, you consent to the collection, use, and disclosure of your personal information in accordance with this Policy.

2. Scope of This Policy

2.1 Definitions

For the purposes of this Policy:

“AusDora” means Synapse Virtual Solutions Pty Ltd trading as AusDora.
“AUDD” means the Australian dollar-backed digital stablecoin supported through approved providers.
“Third-Party Providers” includes identity verification providers, custody providers, infrastructure providers, analytics providers, and regulated financial service providers such as AUDC Pty Ltd.
“Home Currency Accounts” means external payment accounts used by users outside the AusDora platform for home currency payment activity.

2.2 This Policy applies to:

users of the AusDora platform;
visitors to our website or applications;
individuals who communicate with us directly or indirectly.

2.3 This Policy does not apply to:

blockchain networks;
third-party wallet providers;
third-party fiat or digital asset service providers;
transactions or activities conducted outside the AusDora platform, except to the limited extent user-provided evidence is reviewed for compliance, fraud prevention, dispute handling, or risk management.

This Policy does not apply to transactions or settlement activities conducted outside the AusDora platform between users.

This Policy should be read together with the AusDora Terms of Service, which govern the nature and limitations of AusDora’s services.

3. User Confidentiality

Users may interact with each other through the platform.

You are solely responsible for any personal information you choose to disclose directly to other users. We recommend reviewing the privacy and security practices of any third party before sharing personal information.

AusDora is not responsible for the collection, use, or disclosure of personal information by users to each other or by third parties.

4. Personal Information We Collect

4.1 Definition of Personal Information

Personal information means information or an opinion about an identified individual or an individual who is reasonably identifiable.

4.2 Types of Personal Information

We may collect the following categories of personal information:

full name;
date of birth;
contact details (email address, phone number, residential or mailing address);
citizenship or residency information;
government-issued identification (e.g. passport, national ID, driver licence);
visa or migration status (where relevant);
tax residency information (where required);
account credentials (usernames, authentication data);
platform activity data (application-layer activity);
transactional information relating to platform activity, including references required by third-party fiat or digital asset service providers;
communications with us;
usage data and logs, which may include information such as your Internet Protocol (IP) address, browser type, browser version, device type, make and model clickstream/heatmap data, the pages of our Services that you visit, the features and functions of our Services you use, activities or actions you do while using our Services, the time and date of your visit to our Services, the time spent on any pages of our Services, and other log related information relating to your use of our Services;
any other information you voluntarily provide;
external payment account information, including Home Currency account details, account ownership evidence, and bank statements or equivalent documents provided for verification, fraud prevention, AML/CTF compliance, dispute handling, or risk management purposes.

AusDora does not collect, store, or have access to private cryptographic keys, seed phrases, or on-chain wallet credentials.

Where required for platform operation, account verification, fraud prevention, AML/CTF compliance, dispute handling, or risk management.

Except as outlined in this Policy, we endeavour to only collect personal information about you from you, where it is reasonable and practical to do so. Sensitive information will only be used and disclosed for the purpose for which it was collected by us or for a directly related secondary purpose.

5. How We Collect Personal Information

We collect personal information through:

account registration and onboarding;
identity verification processes conducted by third-party providers;
use of our Services;
communications (email, forms, support requests);
marketing, surveys, research, or feedback;
website and application usage (cookies and logs).

Where reasonable and practical, we collect personal information directly from you.

6. Sensitive Information

Sensitive information (as defined by Privacy Laws) is collected only where:

required by law or regulation;
necessary for identity verification or compliance purposes; or
you have provided explicit consent.

Sensitive information is used only for its primary purpose or directly related secondary purposes permitted by law.

7. Use of Personal Information

We use personal information to:

provide and operate the AusDora platform;
verify user identity and eligibility;
comply with legal, regulatory, and AML/CTF obligations;
conduct behaviour-based monitoring of application-layer platform activity for compliance, risk management, and AML/CTF purposes;
maintain platform security and integrity;
monitor usage and manage risk;
communicate with users;
improve and develop our Services;
conduct internal analytics and research;
respond to enquiries and complaints.

Monitoring primarily focuses on application-layer platform behaviour and behavioural indicators generated through platform usage. Limited third-party blockchain analytics may be used where reasonably required for compliance, sanctions screening, fraud prevention, or risk management purposes. AusDora does not collect private wallet credentials, seed phrases, or private cryptographic keys.

8. Disclosure of Personal Information

8.1 General Disclosure

We may disclose personal information to:

regulated third-party service providers, including AUDC Pty Ltd and associated infrastructure, compliance, wallet, and custody service providers (e.g. KYC, onboarding, custody, fiat rails);
technology and infrastructure providers;
professional advisers (legal, compliance, accounting);
affiliates and contractors;
regulators, law enforcement, or authorities where required by law;
parties involved in a corporate transaction (merger, acquisition, restructure);
other parties with your consent;
AUSTRAC, law enforcement agencies, courts, regulators, or other competent authorities where required or permitted by law.

We do not sell personal information.

8.2 Third party social media and Communication Channels

AusDora may maintain social media accounts or communication channels hosted by third-party platforms. Any information you disclose through those platforms is subject to the privacy practices, terms, and policies of the relevant third-party provider. AusDora is not responsible for how third-party platforms collect, use, or disclose your information.

Data Security and Protection

We take reasonable steps to protect all personal information which we hold from misuse, interference, loss, unauthorised access, modification or disclosure.

The precautionary steps we take to protect personal information may include:

technologies and processes such as access control procedures including multi-factor authentication, network firewalls, physical security and encryption of data transmission;
adopting measures to protect our computer systems and networks for storing, processing and transmitting personal information;
regularly reviewing our information collection, storage and processing practices; and
secured encrypted servers, password protection for electronic files, multifactor authentication procedures, securing paper files in locked cabinets and physical access restrictions.

We also take steps to ensure that the personal information we collect is accurate, up-to-date and complete. These steps may include maintaining and updating personal information when it is apparent that updating is required, or we are otherwise advised by you that your personal information has changed.

Notwithstanding that we use our best endeavours to protect all personal information, we cannot completely guarantee the security of your personal information.

9.1 Data Accuracy

We take reasonable steps to ensure personal information is accurate, complete, and up to date. Users are encouraged to notify us of changes to their information.

10 Third-Party Service Providers

AusDora relies on third-party providers for certain services, including identity verification, compliance support, custody, and digital asset infrastructure.

Third-party service providers operate independently from AusDora and are responsible for their own systems, security controls, and privacy practices. AusDora does not control how such providers collect or process personal information within their own platforms.

Third-party service providers may include identity verification providers, technology providers, custody providers, infrastructure providers, analytics providers, and regulated financial service providers such as AUDC Pty Ltd.

11. Data Retention

AusDora retains personal information only for as long as reasonably necessary to provide its Services and to satisfy legal, regulatory, compliance, AML/CTF, fraud prevention, dispute resolution, and recordkeeping obligations.

Where required under applicable laws, certain records may be retained for minimum statutory retention periods, including after account closure or termination.

12. Direct Marketing

We may use your personal information to provide updates, service announcements, product information, or marketing communications relating to AusDora and its services. You can opt out of receiving any marketing communications from us by following the opt out instructions in those communications.

13. Overseas Disclosure

13.1 Overseas IT service providers

We may disclose personal information to outsourced information technology service providers, including cloud computing providers and data storage providers, and other third party service providers who are not in Australia or may transfer or store your personal information outside Australia.

Where personal information is disclosed or stored overseas, AusDora will take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with applicable privacy protections and security safeguards.

13.2 Disclosure for analytics

We may use Google Analytics and other third party analytics software to track your usage of our Services. Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of our Services, to prepare reports on its activities and share them with other Google services.

Google may use the data collected to contextualise and support analytics, usage insights, and service optimisation in accordance with Google’s own privacy policies. Personal information collected by Google includes cookies and usage data, which is processed in the United States of America (subject to changes in Google’s data processing policies). You can find Google's privacy policy on their website.

13.3 Consent to overseas disclosure

Other than as contemplated in this Policy, we will only disclose your personal information to an overseas recipient if:

you consent to the transfer; or
the disclosure of the information is required, authorised or permitted by or under an Australian law, other applicable law or a court/tribunal order.

14. Cookies and Tracking Technologies

We use cookies and similar technologies to:

improve platform functionality;
analyse usage;
remember user preferences.

You may disable cookies via your browser settings, but some features may not function properly.

Web Beacons

Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users or to access cookies.

Unlike cookies which are stored on the user’s computer or mobile device storage drive, web beacons are embedded invisibly on web pages (or in e-mail). Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns.

Like many sites, we use web beacons to collect information which is done in accordance with this Policy.

16. No Fiduciary Relationship

Nothing in this Privacy Policy creates a fiduciary, trustee, custodial, or agency relationship between AusDora and any individual.

17. Access and Correction

You have the right to:

request access to personal information we hold about you;
request correction of inaccurate or outdated information.

Requests may require identity verification. We will respond within a reasonable timeframe as required by law.

Requests can be made by contacting: support@ausdora.au

18. Complaints

If you believe we have breached this Privacy Policy or Privacy Laws, you may contact us at:
support@ausdora.au

We aim to respond within 30 days.

You may also lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

19. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be published on our website. Continued use of the Services constitutes acceptance of the updated Policy.

20. Contact Us

For questions or concerns about this Privacy Policy or how we handle personal information, contact:
support@ausdora.au
Australia

Effective Date: 23 June 2026
Version: 1.0