Legal & Compliance Position
At Brumby Pay, we believe trust comes from transparency.
Our platform is built to meet strict compliance standards while staying simple, structured, and free from unnecessary regulatory burdens.
Below is a plain-language summary of our legal structure, obligations, and platform safeguards, so you can feel confident using Brumby Pay.
Brumby Pay Is a SaaS Platform, Not a Financial Service:
Brumby Pay is operated by Brumby Finance Pty Ltd, an Australian-owned company.
We provide a Software-as-a-Service (SaaS) platform that helps businesses:
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Log and monitor voluntary invoice payment activity
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Automate structured, compliant engagement with customers
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Recognise good payment behaviour through milestone-based, non-cash rewards
We do not:
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Offer credit, loans, or buy-now-pay-later services
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Act as a debt collector or enforce payments
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Receive, hold, or transfer customer funds
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Provide financial advice, credit decisions, or payment guarantees
Not a Designated Service Under AUSTRAC:
Brumby Pay has conducted a detailed legal review of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
We confirm:
Brumby Pay is not a reporting entity under AUSTRAC
We do not provide any designated services
You can read our AML/CTF position [here].
GST & Tax Compliance:
Brumby Finance Pty Ltd is registered for GST.
Platform commissions are treated as taxable supplies
We issue valid GST tax invoices to registered businesses
Non-registered sole traders and consumers receive GST-free documentation
Rewards are funded by Brumby and may carry tax implications for recipients, we recommend consulting a registered tax or BAS agent.
See our full Tax Disclaimer [here].
Privacy & Data Protection:
Brumby Pay complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
All data is securely encrypted, access-controlled, and used only for defined platform functions
We do not sell, rent, or misuse any personal or business data
We use verified third-party providers for reward fulfilment, messaging, and analytics
Users can access, update, or request deletion of their data at any time
You can read our full Privacy Policy [here].
Reward Controls & Consumer Law Safeguards:
Brumby Pay Rewards are:
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Funded and issued by Brumby Pay, not the creditor
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Triggered automatically when a predefined platform-wide milestone is reached
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Not discretionary, not tied to invoice value, and never used as a condition of payment
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Prohibited in certain high-risk or regulated sectors
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Milestone rewards are never based on luck or chance, there are no lotteries, draws, or subjective decisions.
We maintain:
A live Restricted Sector Register
Internal workflows to prevent misuse or manipulation
Legal alignment with the Australian Consumer Law (ACL) and ACCC/ASIC guidelines
How We Operate:
Brumby Pay operates with a strict compliance-first approach that recognises and rewards timely payments through milestone-based rewards without ever chasing debtors or applying pressure. Our platform delivers secure, compliant invoice workflows that support structured, automated engagement between businesses and consumers, without issuing collection notices, demands, or engaging in any form of financial coercion.
Contact Us:
For legal, compliance, or data protection enquiries:
Support@brumbypay.com.au
Brumby Finance Pty Ltd
© 2025 Brumby Finance Pty Ltd. All rights reserved.
This document is provided for general information purposes. It may not be reproduced, distributed, or used for commercial purposes without the prior written consent of Brumby Finance Pty Ltd.