Sniip App – Disclosure Documents

Issue date: 10 January 2025

WEX Australia Pty Ltd

This Financial Services Guide (FSG) is provided by WEX Australia Pty Ltd ABN 68 005 970 570 (Authorised Representative number: 1311978) (WEX, we, our or us) to you in relation to our activities which involve the provision of financial services as defined in the Corporations Act 2001(Cth) (Corporations Act).

Purpose and Contents of this FSG

This FSG describes our services to assist you to decide whether to use them. It describes how we are remunerated, compensation arrangements, and how we handle any complaints you may have.

The content of this FSG is general information only and does not take into account any person’s particular needs or objectives. WEX provides no warranty as to the suitability, for any person, of the services outlined in this FSG.

1. Our Services

We do not hold an Australian Financial Services License (AFSL). Rather, we are authorised to provide general financial product advice and deal in financial products by issuing, applying for, acquiring, varying or disposing of financial products pursuant to an authorised representative and intermediary authorisation agreement between WEX and Flexewallet Pty Ltd ACN 164 657 032 (Flexewallet, AFSL 448066). Our dealing services are limited to non-cash payment products to retail and wholesale clients.

We are not authorised to provide personal financial product advice. As such, any such financial product advice we provide will be general in nature and will not take into account your objectives, financial situation or needs. Because of this, before acting on any advice, you should consider its appropriateness having regard to your own circumstances.

We may provide general advice and deal in financial products by arranging for the acquisition of non-cash payment products issued by Sniip Ltd (ABN 86 161 862 068)(Sniip). Sniip provides eligible users with the ability to pay a bill by scanning the BPAY Biller Code and Reference number (BPAY Details) on a bill, negating the need to manually enter these BPAY Details and enter a bill amount in order to create a digital copy of the bill for payment. For more detail about this product, refer to the PDS at https://sniip.com/product-disclosure-statement/.

2. How can you give us instructions

You can give instructions to us about our services by contacting us as described in section 6 below.

To become an eligible user of the product, you need to complete registration with Sniip. Additional information about the product, including about its features, costs, benefits and risks, is contained in the Product Disclosure Statement (PDS) available at https://sniip.com/product-disclosure-statement/. You should consider the PDS before deciding whether to obtain the product.

3. How we are paid

A processing fee will be payable by customers to Sniip for each payment transaction made through the Sniip App (in accordance with the Sniip PDS).  The processing fee will be calculated and displayed for each such transaction prior to the customer making a payment. WEX does not receive any fee or remuneration from Sniip for such transactions.

WEX pays Flexewallet a fixed licence fee per month in respect of services provided by Flexewallet pursuant to the intermediary authorisation agreement between WEX and Flexewallet.

4. Professional Indemnity Insurance

We have professional indemnity insurance in connection with the services we provide.

5. What to do if you have a complaint

If you wish to lodge a complaint about the provision of our services, please contact us as described in section 6. We will acknowledge receipt of your complaint and attempt to resolve it as soon as practicable.

We are a member of the Australian Financial Complaints Authority, which is an external dispute resolution scheme. If you are not satisfied with the way we respond to your complaint, you may refer your complaint to:
Australian Financial Complaints Authority

GPO Box 3
Melbourne VIC 3001
Phone: 1800 931 678
Email: info@afca.org.au

6. How you can contact us or Flexewallet

Our contact details are as follows:
WEX Australia Pty Ltd ABN 68 005 970 570
Address: Level 23, 367 Collins Street, Melbourne Victoria Australia 3000
Email: privacy@wexaustralia.com

Flexewallet has authorised the distribution of this FSG by WEX.
Flexewallet can be contacted via:
Address: Level 3, 461 Bourke Street, Melbourne, VIC, 3000
Email: admin@flexewallet.com

Last updated: October 15, 2022.

Introduction

This Product Disclosure Statement (“PDS”) has been prepared by Sniip.  This PDS does not constitute an offer in any jurisdiction other than Australia or to anyone whom it would not be lawful to make such an offer. Sniip does not hold an Australian Financial Services Licence (“AFSL”). Non-cash payment facilities are issued by Sniip pursuant to an intermediary authorisation agreement between Sniip and Flexewallet Pty Ltd ACN 164 657 032 (AFSL 448066) (“Flexewallet”). Under that agreement, Flexewallet offers to arrange for the Product to be issued by Sniip pursuant to an intermediary authorisation for the purposes of section 911A(2)(b) of the Corporations Act 2001 (Cth).

The information in this Product Disclosure Statement (“PDS”) is up-to-date as of 15 November 2022. If this information changes and the changes are not materially adverse, we will make this updated information available on this website, or you can email us at customercare@sniip.com to request a copy to be emailed to you.

The purpose of this Product Disclosure Statement

The law requires that we prepare and provide you with a PDS. The purpose of this PDS is to give you the information you require to make an informed decision about whether or not to utilise the Product. To assist you in understanding the Product, this PDS details the significant features of the service, including how to use it, and its costs, benefits and risks.

This PDS and the Sniip Terms and Conditions form your agreement with us. You should read this PDS, the Sniip Terms and Conditions and the Privacy Policy carefully before deciding whether to use the Product.

About this Product Disclosure Statement

This PDS is an important document which provides you with information about the Product, including any fees and costs, to help you decide whether to obtain this product. You should read this PDS carefully and seek independent expert advice before making any decisions relating to the suitability of this product for you.

This PDS is not intended to constitute advice, nor is it a recommendation or opinion that the Product is suitable for your needs. Any advice contained in this PDS is general advice only and does not take into account your specific objectives, financial situation or particular needs.

Product Features

Scanning or importing a Bill

The Sniip App allows users to scan or import a Biller’s payment details on a paper or digital bill in order to create a digital copy of the bill for payment in the Sniip app.

This process is completed by scanning a BPAY Biller Code or Sniip QR code on the bill. This negates the need for Users to manually enter a Billers Details and bill amount.

Prior to using the Product, Users must register an account and provide their Card details in the Sniip App. Sniip will verify and validate the Details and allow Users to use one of their stored Cards or Apple Pay/Google Pay (or other digital wallets) to facilitate the payment of the bill via the Sniip App.

The two legs of a transaction on the Product:

1. A User will direct Sniip to make payment of a bill amount to the Biller on the User’s behalf. Sniip will initiate a transaction through the card scheme for the bill amount plus any relevant surcharges (detailed in section 7). This transaction will appear on the User’s statement as a payment to Sniip (‘Sniip Bill Payments’). For Payments involving BPAY, this component of the transaction falls outside of the BPAY Scheme and, accordingly, the BPAY Terms will not apply.
2. Sniip will make payment of the bill amount to the Biller on the same business day that cleared funds are received from the User. For Payments involving BPAY, this component of the transaction utilises the BPAY Scheme and is subject to the BPAY Terms.

It may take up to three (3) business days (or more in exceptional circumstances) from the time a payment is made by the User to Sniip through the Product until Sniip pays the Biller. During this period, Sniip will hold funds in an account with an Australian Authorised Deposit Taking Institution (“ADI”) in its own name on the User’s behalf.

Terms and Conditions

Use of the Product is governed by the Sniip Terms and Conditions, which are incorporated into, and form part of this PDS.

Privacy and Confidentiality

Sniip may collect personal information about you in the course of providing the Product to you. Sniip has adopted a Privacy Policy which provides information about how we collect, hold and use any information you provide to us. A copy of our Privacy Policy is available at https://sniip.com/privacy-policy.

In particular, if you agree to provide Sniip with access to your email in order for Sniip to notify you of any upcoming Bills, Sniip may use might use the data from the Bill to:

• analyse its services and customer needs with a view to developing new or improved products or services; or
• subject to any applicable laws, notify you of promotions, special offers or deals from other service providers, which might interest you.

Other Information Available

Additional information in respect of the Sniip service is available on the Sniip website.

Commissions, fees and charges

Processing fees for the use of the Product to make payments

• A processing fee will be payable for each Sniip transaction relating to a Payment as follows:

Personal payments

Type of card	Processing fee
Bank Accounts	0.00%
Debit cards	0.65%
Amex	1.29%
Diners	1.50%
Visa/Mastercard	1.50%
Visa/Mastercard International*	3.00%
Prepaid cards	0.85%
Crypto.com cards	0.85%

All processing fees are inclusive of GST.
*All international cards are recognised as credit cards and incur a 3% processing fee.

American Express Business payments

Transaction amount	Processing fee
$0 – $99,999	2.19% (1.99% + GST)
$100,000 – $299,999	2.15% (1.95% + GST)
$300,000 – $499,999	2.09% (1.90% + GST)
$500,000 – $999,999	2.04% (1.85% + GST)
+$1,000,000	1.93% (1.75% + GST)

• Processing fees will be calculated and displayed to the customer, prior to making a payment.
• A $25 fee will be payable for processing a payment reversal at the request of a User (where possible) and Sniip will retain any fees paid by you in respect of that payment.
• Sniip may also receive any interest paid in respect of User’s funds held in its account with the ADI before a Payment is made by the ADI.

Sniip may also receive fees from the ADI and/or its processing partners for processing a Payment.

Sniip may increase the amount of fees and charges or introduce new fees and charges. If they are changed, Sniip will provide you with two months’ prior written notice of the change through the Sniip website, or other means. Sniip may waive, in whole or in part, any fees or charges at its discretion.

Taxation Implications

Making Payments through the Product will usually have the same taxation implications as if you had made the payment through traditional BPAY, or banking channels.

What are the benefits?

Faster way to make payments

Users do not have to re-enter card, Apple Pay/ Google Pay (or other digital wallet) details or reference numbers to make a Payment.

Secure

Sniip is more secure than conventional online payment methods, permitting a User to safely, conveniently and cost-effectively make a Payment via a mobile device, utilising a 4-digit pin, or the biometric authentication located on their mobile device.

Multiple payment methods

Users can store their payment details from multiple sources and can simply select the preferred card or Apple Pay/ Google Pay (or other digital wallet) payment method at the time of paying the bill.

What are the risks?

Some of the risks associated with the Product are outlined below. This is a summary of the major risks only, and is not intended to be exhaustive. There may be other risks associated with your use of the product.

Ability to make payments

By using the Product, you are relying on Sniip’s ability (and the ability of its banking partners and/or the BPAY Scheme) to meet various obligations, including making payments you have requested and holding funds in its account on your behalf. There is a risk that Sniip or the ADI may be restricted from processing payments, which could result in the Product no longer being able to be offered.

Loss of funds

Before making a Payment, Sniip will debit a User’s Card or Apple Pay (or other digital wallets) for the bill amount plus any relevant surcharges and fees.  You will be responsible for any loss of funds until they are received in Sniip’s account held with the ADI.

Unavailability

While Sniip will make reasonable efforts to ensure continued availability of the Product, it is possible it may be rendered temporarily unavailable from time to time. This may be caused by factors external to Sniip such as general internet connection issues, as well as system issues and outages associated with various mobile network operators. Sniip is not liable for any late payment fees.

Unauthorised transactions

There is a risk your Sniip account may be compromised and subject to an unauthorised transaction or other types of fraudulent activity. While Sniip takes reasonable measures to ensure the security of its services, you are ultimately responsible for any unauthorised transactions and to keep your login credentials and mobile devices secure.

Regulatory Risk

There is a risk that Flexewallet’s Australian Financial Services licence (“AFSL”) may be cancelled or that Flexewallet ceases to authorise Sniip as an intermediary. In such circumstances, Sniip’s ability to operate the Product may cease.

Cash Advance

There is a risk that payments made by Users through the Product could be treated by the issuer of the nominated Card or Apple Pay as a cash advance. This may attract higher interest rates which may accrue from the time of payment.

Flexewallet

Target Market Determination

For Sniip Ltd ACN 161 862 068

1. About this document

This target market determination (TMD) seeks to offer consumers, distributors and staff with an understanding of the class of consumers for which this product has been designed, having regard to the objectives, financial situation and needs of the target market.

This document is not to be treated as a full summary of the product’s terms and conditions and is not intended to provide financial advice. Consumers must refer to the Product Disclosure Statement (PDS) and any supplementary documents which outline the relevant terms and conditions under the product when making a decision about this product.

Terms and Conditions & Product Disclosure Statement to which this target market determination applies

This TMD applies to Sniip Ltd referred to in the following Terms and Conditions & Product Disclosure Statement:

• Product Disclosure Statement (PDS) 
• Terms and Conditions

Date from which this target market determination is effective: 5 November 2022

2. Class of consumers that fall within this target market

The information below summarises the overall class of consumers that fall within the target market for Sniip Ltd, based on the product key attributes and the objectives, financial situation and needs that it has been designed to meet.

This non-cash payment product offered by Sniip Ltd has been designed for consumers whose likely objectives, financial situation and needs (as listed below) are aligned with the product (including the key attributes). Sniip Ltd is for those who:

• You must be an Australian resident and/or reside in Australia and be at least 18-years-old to open a Sniip account and use the Sniip services.
• Use of the App is at your own risk and the terms under which you access the App are set out in this document (Terms of Use or Terms). Your access to, and use of, the App is conditional upon compliance with, and acceptance of, the Terms, so please read these carefully. By downloading or using the App you acknowledge that you have read and fully understood, agree with, and accept all of the terms and conditions in these Terms.
• In order to use the App, you will need an eligible Device and Sniip recommends that you keep your Device updated with the latest operating system and security software as released by the Device or system operator. Sniip will not be liable if the App cannot function, or cannot function properly, due to an out-of-date operating system or security features.

Product description and key attributes  

The key eligibility requirements and product attributes of Sniip Ltd are:

• Sniip provides eligible users with the ability to pay a bill by scanning the BPAY Biller Code and Reference number (BPAY Details) on a bill, negating the need to manually enter these BPAY Details and enter a bill amount in order to create a digital copy of the bill for payment.
• Faster way to make payments. Users do not have to re-enter card, Apple Pay/ Google Pay (or other digital wallet) details or reference numbers to make a Payment.
• Sniip is more secure than conventional online payment methods, permitting a User to safely, conveniently and cost-effectively make a Payment via a mobile device, utilising a 4-digit pin, or the biometric authentication located on their mobile device.
• Users can store their payment details from multiple sources and can simply select the preferred card or Apple Pay/ Google Pay (or other digital wallet) payment method at the time of paying the bill.

Objectives, financial situation, and needs  

This product has been designed for individuals who:

• Sniip has determined that this product is suitable for any persons/entities who pay bills, or regularly make bill payments, and need security, certainty, convenience and efficiency in respect of those payments.

Excluded class of consumers  

This product has not been designed for individuals who:

• Persons who do not have a legitimate reason or need to utilise the services; and/or
• Persons who have insufficient funds to meet automated payments.

Consistency between target market and the product   

This is based on an analysis of the key terms, features and attributes of the product and a finding that these are consistent with the identified class of consumers.

3. How this product is to be distributed

Distribution channels

This product is designed to be distributed through the following means:

• This product can on be obtained through the Apple App or Google Play stores, through a link to download via our main website www.sniip.com.

Distribution conditions

This product should only be distributed under the following circumstances:

• Sniip does not have any Authorised Representatives, nor any third-party distribution agreements in place at the current time. Accordingly, there are no distribution conditions or reporting to disclose in the TMD.

Adequacy of distribution conditions and restrictions  

This is based on an assessment of the distribution conditions and restrictions and that they are appropriate and will assist distribution in being directed towards the target market for whom the product has been designed.

4. Reviewing this target market determination

We will review this target market determination in accordance with the below:

Initial review	Within 1 year of the effective date.
Periodic reviews	At least every year from the initial review.
Review triggers or events	Any event or circumstances arise that would suggest the TMD is no longer appropriate. This may include (but not limited): a material change to the design or distribution of the product, including related documentation; occurrence of a significant dealing; distribution conditions found to be inadequate; external events such as adverse media coverage or regulatory attention; and significant changes in metrics, including, but not limited to, complaints, [example metric], [example metric] and [example metric]

Where a review trigger has occurred, this target market determination will be reviewed within 10 business days.

5. Reporting and monitoring this target market determination

WEX may collect the following information from our distributors in relation to this TMD.

Complaints	Distributors will report all complaints in relation to the product(s) covered by this TMD on a daily basis. This will include written details of the complaints.
Significant dealings	Distributors will report if they become aware of a significant dealing in relation to this TMD within 10 business days.

Complaints and Dispute Resolution

Sniip is committed to dealing with customer complaints fairly and resolving issues in a timely manner in accordance with our procedures for the handling of complaints. If you have any questions, problems or complaints, please contact us in one of the following ways:

Sniip contact details

The Product is provided to you by Sniip. The contact details are as follows:

Email: You can lodge complaints by submitting an email directly from the website. This form can be accessed by clicking the Contact section on the Sniip Website. You can also file your complaint directly to us at customercare@sniip.com.
Mail: By mail to Sniip Ltd, Level 1/79 Hope St, South Brisbane QLD 4101.
Phone: (07) 3268 7710
ABN: 86 161 862 068

We endeavour to acknowledge a complaint within one business day, and provide a full response within a maximum time frame of 30 days. In instances where we cannot resolve your complaint within five business days, we will send you an email notifying you of the delay and the reason for the delay as well as an indication of when we expect to be able to respond.

If we require further time to conduct our investigation (for example, where information is being sought from a credit card issuer), we may not be able to resolve your complaint within 30 days. If we are unable to resolve your complaint within 30 days, or you are dissatisfied with how your complaint was handled or its outcome, you can refer your complaint to the Australian Financial Complaints Authority (AFCA), an independent external dispute resolution scheme covering applicable Australian customers.

AFCA contact details

Online: www.afca.org.au
Email: info@afca.org.au
Phone: 1800 931 678
Mail: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001
For further details on dispute resolution, please read the appropriate section in the Sniip Terms and Conditions.

Definitions

In this PDS, these words have the following meanings:

“Apple Pay”: The mobile payment and digital wallet service provided by Apple Inc. that allows users to make payments via the iOS App.

“App”: The “Sniip – The easy way to pay” application developed by Sniip and available for download on the Apple App and Google Play stores.

“BPAY”: BPAY Pty Ltd ABN 69 079 137 518.

“BPAY Terms”: The Product Terms in the Sniip Terms and Conditions.

“BPAY Scheme”: The scheme operated by BPAY from time to time to provide payment services to end customers.

“Card”: Any bank card, credit card or stored value card capable of being used in the Sniip App.

“Details”: means a Biller’s BPAY details or a Biller’s financial account details (including Account Name, BSB and Account Number)

“Product”: The product described in section 5 of this PDS.

“Sniip Terms and Conditions”: The Sniip Terms and Conditions document outlining all the terms and conditions a User must abide by when using the Sniip service.  The document is regularly updated and is available online at https://sniip.com/terms-and-conditions.

“Sniip Website”: The website found at https://sniip.com.

“Flexewallet”: Flexewallet Pty Ltd ACN 164 657 032 (AFSL 448066).

“Payment”: A payment made by you using the App by scanning a Biller’s Details.

“Privacy Policy”: The Sniip Privacy Policy document sets out the manner in which we will collect, store and use your personal information. The document is regularly updated and is available online at https://sniip.com/privacy-policy/.

“User”: A user of the Product.

“You” or “your”: Each person who uses the Product in accordance with the Sniip Terms and Conditions.