At Evolucian Pty Ltd (trading as Transfigr), we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Transfigr operates as a Corporate Authorised Representative (CAR #1307597) of Financial Mandate Pty Ltd (AFSL 700151). Our officers, representatives, and employees are required to obtain and hold information that personally identifies the persons with whom they transact.

This document describes our current policies and practices in relation to the handling and use of personal information.

Why we collect and use personal information

We collect, store, use, and disclose personal information to provide you with relevant financial products, tools, and services — including the Transfigr app and Free Financial Health Check. Additionally, we may use your information for purposes such as:

Complying with legal obligations (e.g. identity verification)
Addressing your enquiries and complaints
Coordinating third-party services
Internal operations, including record keeping, data analysis, auditing, or training
Promoting other products and services that may be of interest to you

If you prefer not to receive direct marketing communications, please contact us using the details below.

We also collect, use, store, and occasionally disclose personal information about business partners and employees to effectively manage and operate our business. We treat this information with the same level of care as that of our clients.

What personal information we collect

We request personal information that is essential for providing you with relevant products and services. The types of information we may collect include (but are not limited to) your name, date of birth, contact details, financial information, employment status, and residency or citizenship information.

In some cases, we may collect personal information about your family members when it is necessary for the service we are providing.

We do not generally use or adopt government-assigned identifiers (such as Tax File Numbers or Medicare numbers) to identify individuals, even if you provide them. We will only share this information with another entity where you give explicit consent or where required by law. We are also legally required to destroy or de-identify these identifiers once no longer needed.

By law, we must keep certain records for a specified period — including records for at least seven years after providing advice, and Customer Identification Procedure records for the duration of your relationship with us, plus seven years after you cease receiving services.

How we collect personal information

In most cases, we collect personal information directly from you when you:

Complete the Free Financial Health Check or use any Transfigr tool or calculator
Register for or use the Transfigr member app
Fill out an identification or data collection form
Provide us with any relevant documentation
File a complaint
Communicate with us in person, by phone, email, or through other electronic means

We may also collect personal information from other sources, such as publicly available social media or websites, or professionals acting on your behalf.

Your rights and withholding information

You have the choice to provide or withhold your personal information. However, if you choose not to share certain details, it may affect the quality of the services we can provide. In some cases, we may be unable to provide the requested service if the information provided is insufficient.

If you wish to remain anonymous or use a pseudonym when dealing with us, please note that we may only be able to offer limited services or information.

Accessing and correcting personal information

You, or someone you nominate, can request access to the personal information we hold about you. We aim to respond within 30 days. There may be a cost involved with locating, copying, or sending you the information — this will be discussed and agreed with you at the time.

There may be circumstances where we decline to provide information (for example, where it is commercially sensitive). We will inform you and explain why. We take reasonable steps to ensure your personal information is accurate, up to date, and complete. You can update your personal information by contacting us.

Disclosure of personal information

We may disclose your personal information to third parties where you have given consent, or where it is reasonable to expect such disclosure. Entities we may share information with include:

Individuals acting on your behalf (e.g. solicitors, accountants, trustees)
Financial product and service providers, including financial planning software providers
Other organisations within the Transfigr and Financial Mandate group
Organisations assisting with business functions (e.g. auditors, IT support, compliance consultants)
Our solicitors, insurers, courts, tribunals, and dispute resolution organisations
Any entity we or our service providers are required by law to disclose your information to, such as law enforcement agencies or regulatory authorities

Disclosure of personal information overseas

We may disclose your personal information to service providers who operate outside Australia — for example, when working with overseas providers who assist with document preparation or technology services. When we send personal information to overseas recipients, we ensure appropriate data handling and security arrangements are in place. All reasonable steps will be taken to ensure offshore service providers comply with the Privacy Act 1988.

How we protect your personal information

We are committed to ensuring that your personal information is stored securely. We have implemented security systems, practices, and procedures to safeguard your privacy. We may use cloud storage or third-party servers to store personal information. When personal information is no longer needed, we take appropriate steps to securely de-identify or destroy the data.

Using our website and app

The Transfigr website (transfigr.com) and member app may contain links to other websites whose operators may follow different privacy policies. While you are not required to register your personal details to browse our website, we offer registration services that allow you to access the Transfigr member app and receive relevant updates and communications.

Our website and app may use cookies, analytics tools (such as Google Analytics), and similar technologies to identify your browser or collect usage information. You can control cookie preferences through your browser settings; however, declining cookies may affect the functionality of some features.

Policy updates

We may amend or update this Privacy Policy as required by law or as our business processes or technology changes. The updated policy will be posted at transfigr.com/legals.

Your security is our priority.

We've built robust protection into every layer of our system, including multifactor authentication, firewalls, and advanced encryption. Regular security testing ensures our defenses stay strong and up to date. You can trust that your information is safe with us - always.

FINANCIAL MANAGEMENT

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Last updated: 2026 · Evolucian Pty Ltd (CAR #1307597) under Financial Mandate Pty Ltd (AFSL 700151)

Built using AWS security best practices

Our infrastructure follows the AWS Well-Architected Framework. This provides industry-recognised guidance for building secure, reliable and resilient cloud applications.

Secure sign-in

Your account is protected using AWS's managed identity service. During sign-in, it uses the Secure Remote Password (SRP) protocol, allowing you to authenticate without transmitting your actual password over the network. This reduces the risk of password interception.

Multi-layer protection against online attacks

Our application is protected by AWS Web Application Firewall (WAF), helping block malicious traffic, automated attacks and common web vulnerabilities before they reach our application.

Optional Multi-Factor Authentication (MFA)

You can add an extra layer of protection to your account using either an authenticator app or email verification. Even if your password is compromised, MFA helps prevent unauthorised access.

Encryption in transit and at rest

All communication between your device and our servers is protected using HTTPS/TLS encryption. Your data is also encrypted while stored – this safeguards it from unauthorised access.

Sensitive information is encrypted

Sensitive financial information is encrypted before it is stored in our database using field-level encryption. This means even if someone gained access to the database itself, protected data would remain unreadable without the appropriate encryption keys.

Role-based access control

Access to systems and customer data is restricted using role-based permissions and the principle of least privilege. Users are only granted the minimum level of access required to perform their roles.

Automatic backups and disaster recovery

Customer data is automatically backed up through our managed database platform. These backups help protect against data loss and enable recovery in the event of unexpected infrastructure failures.

Production data is isolated

Our live production environment is completely separated from development and testing environments. This reduces the risk of accidental access, changes or exposure of customer data during development.

Secure cloud infrastructure

Production systems are hosted in dedicated AWS accounts that are isolated from development and testing environments, following AWS recommended multi-account security practices.