Our policies &
guidelines
In this Privacy Policy, 'us' 'we' or 'our' means Layby Pty Ltd (ACN 653 280 909). We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information. We are bound by the Australian Privacy Principles contained in the Privacy Act.
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by Layby, must abide by this Privacy Policy and Collection Statement (Privacy Policy). Layby makes this Privacy Policy available free of charge and can be downloaded from our website healthlayby.com.au.
In this Privacy Policy:
disclosure of information means providing information to persons outside of Layby.
personal information means information or an opinion relating to an individual, which can be used to identify that individual.
Chief Risk Officer means the contact person within Layby or questions or complaints regarding Layby’s handling of personal information.
sensitive information is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information.
use of information means use of information within Layby.
What personal information do we collect?
We may collect the following types of personal information:
• Name;
• Mailing or street address;
• Email address;
• Telephone number and other contact details;
• Age or date of birth;
• Credit card information;
• Bank account details;
• Drivers licence details;
• Financial information;
• Your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
• Details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
• Any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
• Information you provide to us through customer surveys; or
• Any other personal information that may be required in order to facilitate your dealings with us.
How do we collect personalinformation?
We may collect these types of personal information either directly from you, or from thirdparties. We may collect this information when you:
- register on our app;
- communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
- interact with our sites,services, content and advertising; or
- invest in our business or enquire as to a potential purchase in our business.
In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exemptfrom the Privacy Act.
We will not collectsensitive information aboutyou without your consent, unlessan exemption in the APPsapplies. These exceptions include if the collection is required or authorised by law, or necessary to take appropriate action in relationto suspected unlawfulactivity or serious misconduct.
If the personal information we request is not provided by you, we may not be able toprovide you with the benefit of our services or meet your needs appropriately.
We do not give you the option of dealing with them anonymously, or under a pseudonym. This is because it is impractical and, in some circumstances, illegal for Layby to deal with individuals who are not identified.
Unsolicited PersonalInformation
We may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to our purposes for collecting personal information. We may retain additional information we receiveabout you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.
Who do we collect personalinformation about?
- Layby users
- potential Layby users
- recipients of funds remitted by Layby users
- service providers or suppliers
- prospective employees, employeesand contractors
- other third parties with whom we come into contact.
Why do we collect,use and disclose personalinformation?
We may collect, hold,use and disclose your personal information for the following purposes:
- to enable you to access and use our services through the Health Layby app;
- tooperate, protect, improveand optimise our services, businessand our users’ experience, suchas to perform analytics, conductresearch and for advertising and marketing;
- tosend you service,support and administrative messages, reminders, technical notices, updates, securityalerts, and information requested by you;
- tosend you marketing and promotional messagesand other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
- to administer rewards,surveys, contests, or other promotional activities or eventssponsored or managedby us or our business partners;
- tocomply with our legal obligations, resolve any disputes that wemay have with any of our users, and enforce our agreements with third parties; and
- to consider your employment application.
We may also discloseyour personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
Dowe use your personal information for direct marketing?
We and/orour carefully selectedbusiness partners may send you direct marketing communications and information about our service. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided(e.g. an unsubscribe link).
To whom do we discloseyour personal information?
We may disclose personalinformation for the purposes described in this privacy policy to:
- our employees and related bodies corporate;
- third party suppliers and service providers (including providers for the operation of our websites and/or our businessor in connection with providing our products and services to you);
- professional advisers, dealersand agents;
- payment systems operators(e.g. merchants receiving card payments);
- our existing or potential agents,business partners or partners;
- our sponsors or promoters of any competition that we conductvia our services;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third partiesauthorised by you to receiveinformation held by us;and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Disclosure of personal information outside Australia
We may disclose personal information outside of Australia to third party suppliers or cloud providers located in Asia and other countries in the APAC region.
When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not requiredto ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
Using our website and cookies
We may collectpersonal information about you whenyou use and access our website.
While we do not use browsinginformation to identifyyou personally, we may recordcertain information about your use of our website, such as which pages you visit, the time and date of your visit and the internetprotocol address assigned to your computer.
We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookiesthrough your internet browser but our websites may not work as intended for you if you do so.
We may also use cookies to enable us to collect data that may includepersonal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.
Management of personal information
We recognise the importance of securing the personal information of our customers. We will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access,modification or disclosure.
Your personal information is generally stored in our computer database. Any paper files are stored in secure areas.In relation to information that is held on our computer database, we apply the followingguidelines:
- passwords are requiredto access the systemand passwords are routinely checked
- data ownership is clearly defined
- we change employees’ access capabilities when they are assigned to a new position
- employees have restricted access to certain sections of the system – each employee has an access to data that is required to perform his/her duties only
- the system automatically logs and reviewsall unauthorised accessattempts
- unauthorised employees are barred from updating and editing personalinformation
- all computers which contain personalinformation are securedboth physically and electronically
- data is encryptedduring transmission over the network
- print reporting of data containing personal information is limited
- data is encryptedin the database
- data access passwordsare changed regularly.
Where our employees work remotely or from home, we implementthe following additional security measures:
- two-factor authentication is enabled for allremote working arrangements
- password complexity is enforced,and employees are requiredto change their password at regular intervals
- weensure that employees only have access to personal information which is directlyrelevant to theirduties
- we use audit trails and audit logs to track access to an individual’s personal information by an employee
- wemonitor access to personal information, and will investigate and take appropriate action if any instances of unauthorised accessby employees are detected
- employees must ensure that no othermember of their household uses their work device;
- employees must store devices in a safe location when not in use
- employees may not make hard copiesof documents containing personal information, nor may they email documents containing personal information to their personalemail accounts
- employees may not disclose an individual’s personalinformation to colleagues or third parties,via personal chat groups.
Links
Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for theprivacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differsubstantially from our Privacy Policy, so we encourage individuals to read them before using those websites.
Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.
If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
Updates to this Privacy Policy
This Privacy Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.
Responsibilities
It is the responsibility of management to inform employees and other relevant third parties about this Privacy Policy.Management must ensure that employees and other relevant third parties are advised of any changes to this Privacy Policy. All new employees are to be provided with timely and appropriate access to this Privacy Policy, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.
Non-compliance and disciplinary actions
Privacy breaches must be reported to management by employees and relevant third parties. Ignorance of this Privacy Policy will not be an acceptable excuse for non-compliance. Employees or other relevant thirdparties that do not comply with this Privacy Policy may be subject to disciplinary action.
Making a complaint
We have an effective complaints handling processin place to manage privacyrisks and issues. The complaints handlingprocess involves:
- identifying (and addressing) any systemic/ongoing compliance problems
- increasing consumer confidence in our privacy procedures
- helping to buildand preserve our reputation and business.
If you think we have breachedthe Privacy Act, or you wishto make a complaintabout the way we havehandled your personal information, you can contactus using the details set out below;
Chief Risk Officer- CRO@healthlayby.com.a
Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within 30 days of receiving.
If you are not satisfied with our response to your complaint, you can also refer your complaint to the Officeof the Australian Information Commissioner by:
- telephoning – 1300 363 992
- writing – Director of Complaints, Officeof the Australian Information Commissioner, GPO Box 5218,SYDNEY NSW 2001
- emailing – enquiries@oaic.gov.au
Contractual arrangements with third parties
We ensure that all contractual arrangements with third parties adequately address privacy issues and we make third parties aware of this Privacy Policy.
Third parties will be required to implement policies in relation to the management of your personal information in accordance with the PrivacyAct. These policies include:
- regulating the collection, use and disclosure of personal and sensitive information
- de-identifying personal and sensitive information wherever possible
- ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties
- ensuring that the personaland sensitive information is only disclosed to organisations which are approvedby us.
Contact Us
For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
Terms & Conditions
These Terms & Conditions (“T&Cs” or “Agreement”) govern your use of the Health Layby Wallet (“HLW”) platform, a service operated by Layby Pty Ltd (ACN 653 280 909, AFSL No. 560833), trading as Health Layby and Health Layby Wallet (“we,” “us,” “our,” or “HLW”). By creating an HLW account and using our services, you agree to comply with this Agreement. If you do not agree, you must not use the HLW platform.
- About HLW
1.1 Our Role
HLW is a payment, savings, and layby facilitation service. We enable you to deposit funds into a digital wallet and pay for healthcare services and products from participating Health Service Providers (“HSPs”). We do not provide healthcare services, clinical advice, or insurance coverage. HLW makes no representation of financial product advice beyond general information.
1.2 AFSL Licence
Layby Pty Ltd (trading as Health Layby Wallet) holds Australian Financial Services Licence number 560833. However, any financial information we provide is general in nature, does not consider your personal objectives, financial situation, or needs, and is not financial advice.
1.3 No Guarantee or Interest
Any funds you deposit do not earn you interest and are not guaranteed or insured by a government agency. Funds you deposit are held in an interest-bearing account controlled by HLW, and HLW is entitled to any interest accumulated from any funds held in that account.
- Eligibility & Account Creation
2.1 Minimum Requirements
You must be at least 18 years old, an Australian resident, and able to form binding contracts under Australian law.
2.2 Identification and Verification
We may ask for personal details and identification documents to comply with Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations. You agree to keep your contact information provided to HLW (e.g., name, email, phone number) current.
2.3 Acceptance
By opening an HLW account, you confirm you have read, understood, and agreed to these T&Cs, and you will only use HLW for lawful and legitimate purposes. HLW does not accept any liability or responsibility for any unlawful, negligent, wrongful, or other conduct during your use of the HLW Wallet and account.
- Using Your HLW Wallet
3.1 Adding Funds & Related Fees
3.1.1 Deposit Transaction Fee
Each time you save or add funds to your HLW Wallet (including Layby Plan deposits), HLW charges a 1.2% + $0.60 fee on the deposit transaction.
Example: If you deposit $10 weekly, your Wallet is credited with $10, and HLW deducts $0.72 (rounded as necessary).
3.2 Balance & No Interest
3.2.1 Any money you deposit is reflected as a balance in your HLW account.
3.2.2 You are not entitled to and will not be paid any interest which may accumulate on the balance of any funds deposited or held in your HLW account. HLW will retain any interest which may accumulate on any funds held in a HLW holding account.
3.3 Insufficient Balance
It is your responsibility to maintain a sufficient bank account balance when scheduling Layby Plan deposits or one-time top-ups. If a deposit attempt fails due to insufficient funds, HLW will:
- 3.3.1 On the first failed attempt: notify you of the unsuccessful deposit.
- 3.3.2 On a second attempt: re-try the deposit (typically within 24–48 hours).
Stopping Further Attempts: If the second attempt fails, HLW stops additional deposit attempts for that transaction. Your existing Wallet balance remains intact, and any future scheduled deposits for subsequent periods are paused until you manually re-initiate or update your payment method.
HLW is not liable for any bank fees or service interruptions arising from repeated deposit failures.
3.4 Withdrawal
You may withdraw up to your available Wallet balance, less any fees and interest which may have accumulated, to your linked bank account by requesting a withdrawal in the HLW app. HLW may take 48 hours, or longer in some cases, to process withdrawals.
- Healthcare Services & Products
4.1 HLW’s Role
HLW only facilitates payments. We do not provide, endorse, or guarantee any healthcare service or product offered by HSPs. Suitability, safety, and quality are solely the HSP’s responsibility.
4.2 HSP Discretion
By creating a Layby Plan for a specific healthcare service or product, you acknowledge that the HSP has full discretion to determine if that service or product is appropriate for you. If the HSP determines the service or product for your Layby Plan is unsuitable, inappropriate, or otherwise, the HSP may decline to provide the selected product or service and may suggest an alternative.
4.3 Refunds on Unsuitable Services/Products
If the HSP determines a Layby Plan you created is for a service or product that is unsuitable and you cancel the Layby Plan, any funds contributed to that cancelled Layby Plan will be refunded to your HLW Wallet, less any applicable fees. You may then withdraw or reallocate those funds.
- Layby Plans & ACCC Compliance
5.1 Lay-by Agreement Under ACL
When you create a Layby Plan through HLW, it may be considered a “lay-by agreement” under the Australian Consumer Law (ACL). In accordance with ACL:
- 5.1.1 You will receive a copy of these T&Cs at the time of creating a plan.
- 5.1.2 You have the right to cancel your Layby Plan at any time before the plan is completed.
- 5.1.3 If HLW modifies these Layby terms in a way that significantly affects your rights, HLW will provide reasonable advance notice.
- 5.1.4 Service and Product Details & Payment Release
For any healthcare service or product arranged through a Layby Plan:- What’s Included: Your Health Service Provider (HSP) will clearly explain what is included in the plan.
- What’s Not Included: Any extra items or fees (e.g., initial consultations, diagnostic imaging, or additional procedures) will be listed by your HSP before you proceed.
- Payment Release: Your funds remain under your control until they are released to the HSP. Once released, the funds cannot be reversed. Please see the Refunds section for more details.
5.2 Creating a Savings Wallet & Layby Plan
You can set aside and save funds in your HLW Wallet—or Layby for a specific healthcare service or product via the Layby feature. During registration, you will be prompted to set up your Wallet with regular deposits (weekly, fortnightly, monthly, or yearly). Once this is set, you will have access to your dashboard. Each deposit, whether it goes into your Wallet or is allocated toward a Layby Plan, is subject to the 1.2% + $0.60 transaction fee as described in Clause 3.1.
- 5.2.1 Wallet Feature & Scan
Funds saved in your HLW Wallet are under your control and can be used for general purposes. You may use these funds at participating Health Service Providers’ practices that display a QR code, allowing you to set an amount and scan to send funds directly from your Wallet balance. - 5.2.2 Layby Feature
Alternatively, you can earmark funds specifically for a future healthcare service or product by setting up a Layby Plan. Deposits directed toward a Layby Plan incur the same 1.2% + $0.60 transaction fee as general Wallet deposits, ensuring all contributions are processed consistently.
5.3 HSP Deposit Requests
When you release funds or pay a deposit from your HLW Wallet toward your Layby Plan—or at various procedural stages—the HSP may request that you release the completed Layby funds either prior to your appointment (to secure the booking) or after the service or product has been delivered. You must confirm via the HLW app before HLW releases any portion of your Layby balance to the HSP.
5.4 Cancelling or Pausing a Plan
- Your Right to Cancel or Pause: You may cancel or pause your Layby Plan at any time, with no penalty fees, by using the HLW app.
- Funds Return: Upon cancellation, all money you have paid into that Layby Plan is transferred back to your HLW Wallet balance (less any transaction fees already incurred under Clause 3.1).
- No Lock-In: You are not locked into continuing deposits or completing the Layby. You can stop contributing at any point.
5.5 Accidental Release of Funds
If you accidentally confirm the HSP’s request to release Layby funds, HLW cannot reclaim them on your behalf. You must arrange any refund or reversal directly with the HSP. HLW is not liable if you mistakenly release funds.
5.6 Business-Initiated Cancellation
If HLW or the HSP cancels your Layby Plan, you may receive a full refund of amounts paid into that plan, less any fees and interest which may have accumulated, or any amounts lawfully withheld under ACL (including fees for processing or any breach).
6. Buy Now Feature
6.1 Operation of Buy Now
The Buy Now Feature (BNF) enables you to initiate immediate payment for a healthcare service or product offered by a participating HSP. Payment may be made via:
- Direct debit from a connected bank account nominated and registered by you;
- The available balance within your HLW Wallet; or
- Apple Pay or Google Pay (processed via Stripe).
6.2 Holding and Release of Funds
All funds remitted via the BFF is held by HLW until such time as the HSP requests release. Upon receipt of a release request, you will be notified through the HLW application and required to either approve or decline the release. Funds will not be released without your express approval. Upon your approval of a release request, the transaction becomes final and irrevocable. Thereafter, any request for refund must be made directly to the HSP, and HLW accepts no liability in relation to such matters.
6.3 Fees Applicable to Buy Now
- Transactions funded via direct debit from a connected bank account or HLW Wallet balance are subject to the standard deposit transaction fees outlined in Clause 3.1.1.
- Transactions funded via Apple Pay or Google Pay are subject to a transaction fee of 2.7% plus $0.60 at the time of purchase.
6.4 Customer Confirmation
Prior to completing a BNF transaction, you will be prompted to confirm your intention to proceed. Upon confirmation, the payment will be deemed authorised and binding.
6.5 Scope of Availability
The BNF is made available only in respect of selected healthcare services or products and only through participating HSPs. Availability is at HLW’s discretion
and may vary from time to time.
6.6 Dispute Resolution and Refunds
In the event of any dispute regarding the provision, quality, or delivery of a service or product acquired via the BNF, you must resolve the matter directly with the HSP. HLW will not mediate or otherwise involve itself in such disputes. Buy Now transactions are otherwise governed by the refund, dispute, and limitation of liability provisions set out in these Terms & Conditions.
7. Paying HSPs
7.1 Immediate Payments (QR Code)
When using HLW to pay for a completed service or product via a QR code, HLW will settle the transaction from your Wallet.
7.2 Layby Plan Completion
Upon completion of a Layby Plan, you may choose to pay the HSP in full, subject to verifying the total cost and any applicable discount.
7.3 Not Responsible for Service/Price Changes
HLW is not responsible if an HSP changes their private fees, imposes additional charges, or fails to honour a discount. You must check the final price with the HSP before authorizing payment.
8. Free Access and Benefits
8.1 Free, Full-Feature Access
HLW is now available entirely free of charge, excluding any fees and interest which may have accumulated. All users enjoy full access to every feature on the platform without any premium or freemium subscription requirements. This includes:
- Discounts on participating HSP services or products
- The ability to add multiple users to your account
- Earning points
- Access to the Layby feature
HLW may introduce subscription modelling in the future and reserves the right to do so.
8.2 No Subscription Fees
There are no recurring or one-off subscription fees for any HLW services.
8.3 Changes to Features
While HLW currently offers all benefits and features for no fee, we reserve the right to modify or enhance these features at our discretion, which may result in a fee charge as set forth in Clause 10.
9. Customer-Facing Fees & Changes
9.1 Fee Adjustments and Future Premium Access
HLW reserves the right to increase transaction fees and/or introduce a subscription-based premium service in the future. Should we decide to make such changes, we will notify you at least 30 days before the new fees or subscription terms take effect. You will be provided sufficient notice and be presented with updated terms and conditions.
10. Refunds & Disputes
10.1 Service or Product Refunds
All refunds related to a healthcare service or product must be handled between you and the HSP. HLW does not facilitate or process refunds within the HLW platform or otherwise engage in any dispute relating to a refund with an HSP.
10.2 Unauthorised or Erroneous Transactions
If you suspect an unauthorised transaction or a technical error, notify us immediately at help@healthlayby.com.au. We will investigate and may adjust your account if we find evidence of an HLW error.
10.3 Accidental Release of Funds
If you accidentally confirm a release of Layby funds to an HSP, HLW cannot reverse it. You must contact the HSP for any resolution or refund.
11. Amendments & Updates
11.1 Changes to T&Cs
We may update these T&Cs from time to time. If changes significantly reduce your rights,we will provide at least 30 days’ notice.
11.2 Feature Changes
We may add, remove, or modify features of HLW at our discretion. If such changes materially affect your usage, we will notify you in advance.
12. Closing Your Account
12.1 User-Initiated Closure
You may close your HLW account at any time by emailing help@healthlayby.com.au or using the app’s “Close Account” feature. All outstanding obligations (e.g., negative balances, open disputes) must be settled first.
11.2 HLW Right to Delay or Decline
We may delay closure if there is an ongoing dispute or investigation, pending transaction, or if fraud or breach of these T&Cs is suspected.
11.3 Payout of Remaining Balance
Upon closure, any remaining Wallet balance, less any fees and interest which may have accumulated, will be transferred to your linked bank account. HLW may need additional documentation or identity checks before releasing funds.
13. Account Records & Statements
We maintain transaction logs and account records as required by law or internal policy. You can view your transaction history in the HLW app.
14. Privacy & Data Protection
14.1 Privacy Policy
By using HLW, you consent to our data practices as outlined in our Privacy Policy, in compliance with the Privacy Act 1988 (Cth) and Australian Privacy Principles.
14.2 Data Sharing
We share necessary transaction details (e.g., name, amount) with HSPs when you authorize payments. We do not share your personal health information unless required or authorized by you or by law.
14.3 Notifiable Data Breaches
If a data breach occurs affecting your personal information, HLW will notify you and relevant authorities in accordance with the Notifiable Data Breaches scheme.
15. Termination & Suspension by HLW
15.1 HLW’s Right to Terminate
We may suspend or terminate your account immediately if we suspect fraud, a material breach, insolvency, or a high risk to HLW or other users.
15.2 Force Majeure
HLW is not liable for service interruptions or failures caused by events beyond our control (e.g., natural disasters, regulatory actions).
16. Dispute Resolution
16.1 Initial Negotiation
If a dispute arises, we aim to resolve it via good-faith negotiations within 30 days of notice.
16.2 Mediation
If not resolved, either party may refer the dispute to mediation (e.g., the Australian Disputes Centre) in Western Australia. Each party bears its own costs, and mediator fees are shared unless otherwise agreed.
16.3 Litigation
If the dispute remains unresolved after mediation, either party may seek remedies in the courts of Western Australia.
17. Indemnification & Liability
17.1 Your Indemnity
You indemnify HLW, its affiliates, and their employees against any claim or loss resulting from your breach of these T&Cs, violation of any law, or misuse of HLW.
17.2 Limitation of Liability
To the extent permitted by law, HLW is not liable for indirect or consequential losses, including lost profits or data, or for any failure of an HSP to provide suitable or adequate services or products.
17.3 Australian Consumer Law
Nothing here excludes any non-excludable right you have under the Australian Consumer Law. Where liability can be limited, it is limited to re-supplying the service or paying the cost of re-supply.
18. No Waiver & No Partnership
18.1 No Waiver
A delay or failure to enforce any right under these T&Cs does not waive that right or any other rights.
18.2 No Partnership
This Agreement does not create a partnership, joint venture, or agency relationship between you and HLW.
19. Governing Law & Severability
19.1 Governing Law
This Agreement is governed by the laws of Western Australia and the courts in Western Australia.
19.2 Severability
If any clause in these T&Cs is found to be invalid or unenforceable, the remainder of these T&Cs retains full effect.
20. Definitions
- “AFSL”: Australian Financial Services Licence.
- “HSP”: A Health Service Provider or merchant offering healthcare services or products that accepts HLW payments.
- “Layby Plan”: A scheduled payment plan allowing you to deposit funds over time to pay for a future healthcare service or product, subject to Australian Consumer Law lay-by rules where applicable.
- “Wallet Balance”: The funds you have deposited (less fees) and available for payment or withdrawal.
21. Contact Us
For questions, concerns, or disputes, contact us at:
Layby Pty Ltd (ACN 653 280 909, AFSL No. 560833)
(trading as Health Layby and Health Layby Wallet)
Email: help@healthlayby.com.au
Perth, Western Australia.
- ISSUER
This financial services guide (FSG) is provided by Layby Pty Ltd (ACN 156 646 963) which holds Australian Financial Services Licence number 560833.
- PURPOSE OF THIS FSG
This FSG contains information about:
- The services we provide;
- Remuneration, commission or other benefitspaid to us and othersin connection with the services we provide;
- Details of any associations which might reasonably be expected to be able to influence the services we provide; and
- Our complaints resolution arrangements and how you can access it.
This FSG contains only general information about the serviceswe offer.
- How to contactus
Our detailsare as follows:
| Issuer: | Layby Pty Ltd |
| Australian Company Number | 156646 963 |
| Australian Financial Services Licencenumber | 560833 |
| Address | Unit 2, 628-630 Newcastle Street, Leederville, Western Australia, 6007 |
| support@healthlayby.com.au | |
| Website | www.healthlayby.com.au |
- Financial Services we are authorised to provide
We are authorised under our AFSL to:
- Provide general financial productadvice for non-cashpayment products;
- Issue, apply for, acquire,vary or disposeof non-cash paymentproducts;
- Acquire, vary or disposeof non-cash paymentproducts on behalfof another.
It is important to understand the distinction between‘general advice’ and ‘personal advice’. We are only authorised to provide general advice. This means we have not taken into account your individual objectives, financial circumstances, or specific needs.
If you have any questions aboutthe information in this FSG or about our products and services, please contact us.
You shouldconsider the appropriateness of our productsand services in regards to your objectives, financial situation and needs before you act on any advice we provide.
- Receiving your instructions
We will primarily acceptyour instructions throughthe HLW App. However, you can also instruct us in person, by phone, by email or by post.
- Other documents you may receive
Product Disclosure Statement
We will provide you with a PDS if we issue you with our financial products. The PDS contains information to help you make an informed decision about whether you wish to acquire one of our financial products. This documentincludes information aboutproduct benefits, product risks and our fees.
You can also obtaina copy of the PDS through our website.
Terms and Conditions
Before you can use our HLW App, you must agree to our termsand conditions of use. We willprovide you with a copy of this document throughthe HLW App. You can also obtain a copy of our terms and conditions of use through our website.
- Remuneration, commission and other benefits
Health Layby
We earn money from any fees you pay us for using our Product.The fees we charge are set out in the PDS.
Staff
Our staff receivesa salary plus superannuation whereapplicable. They may also be eligible for monetary and non-monetary awards or additional incentive payments including bonuses and shares.
The way we pay our staff and the amount we pay them varies depending on each individual staff member’s business area and position at Layby.
Third Parties
We may enter into contractual arrangements with third partieswhich may includethe payment of a commission for the referral of business to us.
Arrangements that may influence our advice to you
We are authorised to issue financial products which are facilities for making non-cash payments, and we do this on our own behalf.Therefore, the generaladvice that we provide to you will likely relate to our own non-cash payment facility products.
- Associations
We are not part of a group of companies.
We do not maintainany associations or relationships that might reasonably be expected to be capable of influencing us in providing the Product.
We allowHealth Services Providers to make available on our HLW App, goodsand services they wish to sell. Before a HSP can sell their goods and services on our HLW App, they must agree to our service provider terms and conditions.
- Complaints and Disputes
Internal dispute resolution
We have in place an internal disputeresolution process to resolve any complaints you may have.
If you have a complaint about our Products or Services, please contact us at support@healthlayby.com.au. You can also to raisea concern or complaint throughthe HLW App.
We will acknowledge your complaint and aim to resolve your complaint in accordance with our regulatory obligations.
External dispute resolution
If you are dissatisfied with the response to your complaint, you can contact the Australian Financial Complaints Authority (AFCA). AFCA is an independent and free disputeresolution body.
AFCA’s detailsare:
Website: www.afca.org.au Email: info@afca.org.au Phone: 1800 931 678 (freecall)
Mail: Australian FinancialComplaints Authority GPO Box 3 Melbourne, VIC 3001
- Compensation Arrangement
Our compensation arrangements comply with the legal requirements set out in Section 912B of the Corporations Act. As required, we maintain professional indemnity insurance coverage in relation to the financial products and services we provide. This insurance provides cover for claims made against us and our representatives including claims against representatives who no longer work with us.
- Privacy
Your privacy is important to us. The information you provide to us and any other information provided by you in connection with the HLW App will primarily be used for providing you with the services and for complying with certain laws and regulations.
Our privacypolicy is available on our websiteat www.healthlayby.com.au. It includes information such as:
- how we collect, hold,use and discloseyour personal information;
- your rights and choicesregarding the rightto correct, amendor delete your information; and
- how you can make a complaint regarding privacy concerns.
We will update our privacy policyfrom time to time.
- General
About this PDS
This product disclosure statement (PDS) has been created and issued by Layby Pty Ltd (ACN 156 646 963) (“Health Layby”, “we”,“us”, “our”) under the Corporations Act 2001 (Cth). It outlines information of the Products and Services we provide, including their benefits, potential risks, associated costs, and other important information to assist you in determining whether our Product and Services are suitable for you.
The information in this PDS is general in nature and does not consider your personal goals, financial situation, or needs. Before acting on the information provided in this PDS, you should carefully assesswhether our Productsand Services are right for yourcircumstances. It is recommended that you review this document thoroughly and seek guidance from a qualified advisor before deciding whether to purchase our Products or Services. For further details, please reach out to us or visit our website at www.healthlayby.com.au.
The purpose of this PDS is to give you clear, relevantinformation to help you decide whether to acquire the Products and Services we offer.
Requesting a copy of the PDS
If you would like a printed copy of this PDS (or any Supplementary PDS), please email us at support@healthlayby.com.au, and we will provide one free of charge.
Meaning of words in this PDS
Unless specifically stated, terms used in this document are defined in the ‘Key Terms’
section below.
Licensing and Authorisation
Our Products are issued by Layby Pty Ltd (ACN 156 646 963) pursuantto our Australian Financial Services Licence (AFSL) (AFSL No. 560833).
Layby Pty Ltd is authorised under its AFSL to issueproducts for non-cashpayment facilities.
- How to contact us
Our detailsare as follows:
| Issuer: | Layby Pty Ltd |
| Australian Company Number | 156 646 963 |
| Australian Financial Services Licence number | 560833 |
| Address | Unit 2, 628-630 Newcastle Street, Leederville, Western Australia, 6007 |
| support@healthlayby.com.au | |
| Website | www.healthlayby.com.au |
- General Product Description
Our Health Layby Wallet App (HLW App) is a mobile application designed for compatible mobile devices (such as Apple and Android). It is an online non-cash payment facility that allows you to transfer your own funds to yourHealth Layby Wallet (HLW) and then purchase goods and services with one of our HSPs who accepts payment using the HLW App. Users create a HLW User Account and link their Nominated Bank Account to the HLW to enable the transfer of funds to and from their HLW.
We are authorised under our licence to offer people products which are classified as ‘non- cash payment facilities’. This means that we provide people with a resource (such as a mobile app) whichallows them to make payments in a way that does not involve the physical delivery of cash.
Product Features
Some key features of the HLW App are:
- Deposits - you can use the HLW App to deposit funds into your HLW
- Set up layby plans - using the HLW App, you can setup an arrangement to debit funds, on a regular basis,from your NominatedBank Account and allocate those funds to a pre-purchased specific procedure or healthcare service
- Access the Buy Now features – using the HLW App, you can purchase goods and services from a HSP through the HLW App and pay for them directly using the HLW App
- Transact with HSPs – using the HLW App,you can purchasegoods and services in person at a HSP and pay for them directly using the HLW App
- Payment of deposits –where a HSP requires you pay a deposit for a healthcare service, you can pay them directly, using your HLW App
- Withdrawal – you can withdrawmoney from your HLWApp and transferit back into your Nominated Bank Account
The HLW App is not:
- a deposit taking institution (like a bank)
- a fund covered by the government’s Financial Claims Scheme
- a credit facility
- a BNPL (buy now pay later) product
- a prepaid card, gift card or loyalty card Acquiring our Product(How to use the HLW App)
- Downloading the HLW App
The HLW App is available for download through our website or on the Google Play and Apple App stores. Once downloaded, you must use the HLW App to create a HLW User Account.To create an account, you must completean application process and accept our Terms and Conditions. This constitutes an agreement between you (as the user) and us. You must read our Terms and Conditions before agreeing to acquire the Product.
- Creating a HLW User Account
To create a HLW User Account,you must:
- be at least 18 years of age;
- be an Australian resident;
- have a bank account,in your name,and which allows you to use thePayTo payment facility; and
- meet any other eligibility criteria we determine.
- Activating your HLW User Account
To activate your HLW User Account, you must connect your bank account to your HLW. To do this, you must enter into a PayTo Agreement with us. Entering into a PayTo Agreement with us allowsus to instantly transferfunds from your Nominated Bank Account into your HLW. To connect your Nominated Bank Account to your HLW you will need to follow the prompts on the HLW App.
- How we manage your money
The funds in your HLW willbe held by us for you. Funds deposited by you are held in a pooled account and are segregated from our money and the money of other HLW customers.
By using our Products, unless explicitly otherwise agreed that you relinquish any right to any interest on funds deposited in the HLW. The money is held for you until you withdraw the money or until you provide us with instructions to allocate funds to a third party such as a HSP or it is refunded to you.
We will not and cannot use the money deposited into the HLW for our own purposes.
- Important information about HLW AccountBalances
Sometimes there may be a discrepancy between the account balance displaying on your HLW App and the amount of client money we hold on yourbehalf. It is likelythat this has occurred because of uncleared funds, software malfunction, or if we otherwise take action pursuant to the Terms and Conditions.
You can ask us for information about the moneywe are holding on your behalfat any time, and we will provide you with a statement within 5 business days or such longer period as we may agree to in writing with you.
Because we rely on financial institutions and third-party providers to process transactions, and to hold funds, there is a counterparty risk that you may lose some or all of your money if there is a deficiency in the account used by the relevant banking partner to support our Products.
- Key Benefits
The HLW App provides you with a range of benefits. These include:
- HSP Offers: HLW customers will have access to rewards, discounts and promotions on purchases offeredby participating HSPs through the HLW App. To take advantage of a HSP offer, you must use the HLW App to make the purchase and you must comply with any terms and conditions of the offer made by the HSP. Terms and conditions may vary between HSPs.
- Multiple options to purchase HSP goods and services: The HLW App is a convenient way for you to save on healthcare related goods and service by using our Buy Now feature or our Layby feature. The Layby feature allows you to quickly and easily set up a payment plan to pay off the price of the goods or services you wish to purchase. The Buy Now featureallows you to purchase goods or servicesdirectly from the HSP.
- Convenience and control: The HLW App allowsyou to pay for goodsand services at the offices/rooms of the HSP. This gives you increased control over the timing of payments through our platform with fast and paperless transactions. Flexibility to deposit and withdraw funds when needed means deposits can be scheduled weekly, fortnightly, monthly or yearly and they can be paused or cancelled at any time.
- Easy to Budget: The Layby feature providesyou with an easy way to budgetfor the healthcare goods or services you know you need. By setting up a Layby plan and making regular payments into your HLW, you can budget for those upcoming healthcare expenses.
- Multiple Layby Plans: You can purchasemultiple goods and services on the HLW App by creating multiple Layby plans.
- Security: The HLW App is a secure location to set aside funds for your healthcare needs and help you manage your healthcare expenses over time.
- Keep track of balances: When healthcare expenses are payable, you know exactly that amount available for cover the expenses compared to health funds which may or may not require you to pay for any financial gap between the expense and the health care fund rebate.The HLW App helps you keep track of your progress when saving for your health care expenses
- Reduce financial stress: Knowing you have funds set aside for future expenses provides stability and reduces financial stress at the time healthcare expenses are required;
- It’s your money: The money in your HLW is always your money and can be returned to you at any time (compared with the way health insurance provides operateand the payment of premiums for extras cover).
- Key Risks
There are some risks you shouldconsider:
- The Product may not be appropriate for your needs;
- You may incur a fee from your financial institution to transfer funds from your Nominated Bank Account into your HLW App;
- Generally, once processed, payments cannot be reversed, This includes in circumstances where you have provided us with payment instructions that are inaccurate or fraudulent. In these circumstances, you might lose funds that cannot be recovered;
- You are relying upon the abilityof financial institutions to fulfil theirobligations to you. As a result, there is a counterparty risk associated with the Products and Services.
- Moneys transferred in the HLW are not protected under the Financial ClaimsScheme or any government guarantee which means you may lose all or part of your funds in the event of insolvency.
- The HLW App might have periods of downtime duringwhich the Product will not be available. We will provide you with advance notice of any scheduled downtime, but unscheduled downtime may be out of our control;
- We are unable to determine whetherpayment or withdrawal instructions are accurate, authorised or fraudulent and you may be liable for unauthorised transactions performed using the HLW app and for some resulting losses. You are responsible for ensuring the security of all your payment instructions.
- Data provided to us in connection with your HLW App could be accessed by unauthorised third parties. While we have implemented security systems and processes, the security of data stored and transmitted through the internet cannot be guaranteed. It is importantthat you protect any passwords and or softwareyou use to access the Product.
- You will not be able to use the HLW App if the app has been downloaded on to a device that is not working or not connected to the internet. The funds transaction features in the Product rely on the abilityto debit amountsfrom and creditamounts to accounts issued by Australian banks or other financial institutions.
- Where you consent to us collecting and passing your personal information to providers, you should carefully check the provider’s privacy policy so you know what the provider will do with your personal information.
- Our Fees
When you transfermoney to or from your HLW, and when you transfer money to a HSP,a fee will be applied.The fee will depend on the type of transaction. Our current fees are set out below.
All fees and charges are subject to change in accordance with ourTerms and Conditions. All payments will be made in Australian dollars unlessotherwise agreed. The times at which the fees and charges will or may be payable are set out in the table below and set out in the Terms & Conditions.
| Type of fee | Amount (exclusive of GST) | Frequency |
| Bank transfer | 1.75% of deposit + $0.60 | Per transaction |
| Layby Deposit | 1.75% of deposit + $0.60 | Per transaction |
BuyNow (Google Pay/ Apple Pay) | 2.7% of deposit + $0.60 | Per transaction |
| Withdrawals | $0.60 | Per transaction |
Example
To give you an exampleof how we will chargeyou, we have outlined an examplebelow. Layby Plan
Let’s say you want to buy a DentalCrown from ABC Dentistsfor $1500.00. You purchase the Dental Crown through the HLW App and setup a layby plan. You decide to pay $300 every Wednesday for 5 weeks.
On the next Wednesday, HLW App will automatically transfer $300 from your Nominated Bank Account and deposit it into your HLW and allocate that money to your “Dental Crown Layby Plan”. You willalso pay $300 x 1.75%+ $0.60 = $5.85 in additional to the transfer as a fee. Therefore, we will withdraw $305.85 from your Nominated Bank Account.
- Referrals
Third parties may have a contractual arrangement with uswhereby they may be remunerated with a payment or other benefit for referring business to us.
- Tax Implications
You should get your own independent tax advice in relation to the impact your use of our Products may have on your personal tax liability as we have not considered your individual circumstances or needs when issuing our Products.
- Privacy
Your privacy is important to us. The information you provide to us and any other information provided by you in connection with our Products will primarily be used for providing you with our Products and Services and for complying with certain laws and regulations.
Our privacy policy is available on our website at www.healthlayby.com.au. It includes information such as how we collect, hold, use and disclose your personal information; your rights and choices regardingthe right to correct, amendor delete your information; and how you can make a complaint regarding privacy concerns. We will update our privacy policy from time to time.
- Complaints and Disputes
Internal dispute resolution
We have in place an internal disputeresolution process to resolve any complaints you may have.
If you have a complaint about our Products or Services, please contact us at support@healthlayby.com.au. You can also to raise a concernor complaint through the HLW App.
We will acknowledge your complaint and aim to resolve your complaint in accordance with our regulatory obligations.
External dispute resolution
If you are dissatisfied with the outcome of your complaint, you can contact the Australian Financial Complaints Authority (AFCA). AFCA is an independent and free disputeresolution body.
AFCA’s detailsare:
Website: www.afca.org.au Email: info@afca.org.au Phone: 1800 931 678 (free call)
Mail: Australia FinancialComplaints Authority GPO Box 3 Melbourne, VIC 3001
- Disclaimer
The Products and Services offered by Health Layby are intended for use by residents of Australia only. This document is provided on an as is basis and, to the fullest extent permitted by law, comes without any warranties, either express or implied. While we make every effort to ensure its accuracy, Health Layby does not guarantee that this document is free from errorsor omissions. We accept no responsibility for any errors or omissions, or any loss or damage resulting from the use or reliance on the information. We make no
assurances regarding the accuracy, completeness, reliability, or suitability of the information provided in this document, nor the outcomes of using this information.
- Other related documents
Other documentswhich you shouldread are:
- Financial ServicesGuide (FSG): this document sets out the services which we will make available to you.
- Product Terms and Conditions: this document details the terms and conditions that all users may agree to beforedownloading the HealthLayby Wallet and accessing our services.
- Target MarketDetermination (TMD): this documentoutlines the customers our product is likely suitable.
Each of these documents are available on our website www.healthlayby.com.au.
- Updates
The information in thisPDS is current as of the date of publication. If there are any updates or changes, we will issue a supplementary PDS (Supplementary PDS), which will be made available on our website at www.healthlayby.com.au.
- Key Terms
AFSL means Australian Financial ServicesLicence.
Buy Now means the feature within the HLW App that allows you to immediately pay for a healthcare service from a HSP using saved funds in the HLW, the connected bank account or using Google Pay or Apple Pay.
HLW means the digitalaccount we have created for you in the HLW App.
HLW App means the HLW App describedin section 3.
HLW User Account means the account you create to access the services offeredby us through the HLW App (including the deposit of funds and the payments to HSPs).
HSP orHealth Service Providermeans a clinic,hospital or practitioner who has partnered with us and that accepts HLW payments.
Layby Plan means the featurewithin the HLW App that allows you payoff the price of goods and services of a HSP over time.
Nominated Bank Account means a bank account you have nominatedto transfer funds to or from your HLW, and which has been connected to your HLW using PayTo functionality; Products means the products issued by us under our AFSL and includes the HLW App; You or Your means an individual who has a HLW User Account.
We, Usor Our means Layby Pty Ltd A.C.N. 156 646 963.
Target Market Determination
1. About this document
When to use this target market determination
This target market determination (TMD) provides a description of the likely objectives, the
likely financial situation and the likely needs of customers in the target market seeking to use
the Health Layby Wallet App. It also provides a description of the key attributes of the Health
Layby Wallet App and an explanation as to why this product is likely to be consistent with the
likely objectives, financial situation and needs of a customer in the target market. This
document is not intended to provide financial advice.
Product to which this target market determination applies
This TMD applies to the “Health Layby Wallet App” product.
Date from which this target market determination is effective
8 July 2025
2. Target Market and Key Attributes
The information below summaries the class of customers within the target market for this
product based on the product’s key attributes and the likely objectives, financial situation and
needs that it has been signed to meet.
Customer objective and needs
The Health Layby Wallet App has been designed for use by Australian residents, over the
age of 18 years, and who:
• do not hold extras cover
• have a transactional bank account with allows then to setup a PayTo agreement with
Australian businesses
• may be looking for a facility which allows them to make purchases from healthcare
service providers either in full or by instalment
Financial situation
The Health Layby Wallet App is suitable for persons who have access to funds which can be
transferred to the Health Layby Wallet App and can be transferred on the dates and in the
amounts as set out in the terms of purchase (as determined by Healthcare Service
Providers). Customer must also be able to pay for any applicable fees charged by the Health
Layby.
Product description and key attributes
The Health Layby Wallet App is a non-cash payment facility with the following key attributes:
• the ability to transfer funds from an Australian Bank Account which allows PayTo
payment
• the ability to make purchases from HSPs
• pay any applicable fees
The product is only available to customers that meet our eligibility criteria.Appropriateness
Heath Layby considers the Health Layby Wallet App product (including its key attributes) as
suitable for the target market including the likely objectives, financial situation and needs of
consumers in the target market.
3. Eligibility criteria
To be eligible for the product, a customer must:
• be an Australian resident
• be at least 18 years of age
• hold an Australian transactional banking account solely in their name
Excluded class of customers
This product has not been designed for:
• Customers who are seeking to earn interest on stored value funds
• Customer seeking a bank account that is protected by the Financial Claims Scheme
• Customers seeking a credit facility (such as a loan) to purchase HSP goods and
services
4. How this product is to be distributed
Heath Layby applies the following conditions and restrictions to the distribution of the Health
Layby Wallet App product so that the product is distributed under the following conditions:
Condition 1
• Individuals meet the eligibility criteria;
• Individuals have the ability to pay for the product
• The product is available to customers within the target market
Conditions 2
A distributor must only market or promote the product if
• they operate within the healthcare industry
• they have been approved by Health Layby
Condition 3
A distributor must only engage in retail product distribution conduct through the HLW App or
any other issue approved communication channels. This may include distribution in offices
or rooms by way of sign, brochure and other marketing material available to the general
public at reception or in room.
All conditions are appropriate as the product has been designed for a specific customer.
5. Reviewing this target market determination
We have implemented the following monitoring program for the Health Layby Wallet App
product, which is designed to trigger a review of this TMD:
Where a review trigger has occurred, this TMD will be reviewed within 10 business days of
us becoming aware of the trigger.
Period Review At least every 2 years from the date which this Target Market
Determination is effective.
Review Triggers We will review this TMD if there is:
• A material changes to the design or distribution of the
product including related documentation;
• A significant dealing of the product to customers outside the
Target Market consistently occurs;
• A change to distribution conditions which means that
distribution is found to be inadequate;
• An external event occurs such as materially adverse media
coverage or regulatory engagement or change
• A significant increase in the number complaints made to the
Australian Financial Complaint Authority in relation to the use
of the product.
6. Reporting
Reporting Period
The reporting period for this determination is annually from the date which this Target Market
Determination is effective.
Reporting Information
A distributor that distributes our product must provide the following information in writing to
us within the time frames specified below:
• Complaint information – information about complaints received in relation to the
product during the reporting period. This must be provided as soon as practicable and
in any event within 10 business days after the end of each reporting period
• Distributor Feedback – information known to the distributor that suggest that this
determination may no longer be appropriate. This must be provided as soon as
practicable and in any event within 10 business days of becoming aware of the
significant dealing
• Significant Dealing – information about any significant dealing in the product that is
not consistent with the target market determination. This must be provided as soon as
practicable and in any event within 10 business days of becoming aware of the
significant dealing
• Information Request by the Issuer - This must be provided as soon as practicable.
