Target Market Determination
Issued by Kuber Financial Pty Ltd
ABN 90 652 317 907
Corporate Authorised Representative of AFSL no 480834
Issue Date: 29 April 2024
The Kuber Wallet is a non-cash payment facility and a financial product for the purpose of the design and distribution obligations set out in Part 7.8A of the Corporations Act 2001 (Cth).
The purpose of this Target Market Determination is to provide consumers information about the Kuber Wallet and its key attributes, the target market for the Kuber Wallet, and the distribution and monitoring arrangements between the issuer, its merchants and any other approved distributors from time to time. This document is not to be treated as a full summary of the product terms and conditions and is not intended to provide financial advice.
Customers should refer to the Combined Financial Services Guide & Product Disclosure Statement for the Kuber Wallet available at PDS&FSG when deciding about these products.
Date from which this Target Market Determination is effective 29 April 2024
The information below summaries the overall class of consumers that fall within the target market for the Kuber Wallet, based on the product’s key attributes and the objectives, financial situation and needs that they have been designed to meet.
- Class of consumers that fall within the target market
The Kuber Wallet is designed for Australian resident individuals (who have successfully completed the Kuber Know-Your-Customer onboarding process) with a wide range of income and spending habits who are looking for a digital solution available on their smartphones and which facilitates both real time payments for free and data analytics on their spending and budget behaviours. The Kuber Wallet is also designed for Australian resident merchants, who have successfully completed the Kuber Know-Your-Customer onboarding process and who want to enable their customers to make real time payments for goods and services acquired using their smartphones. The target market for this product are individuals over the age of 18, and all small to medium enterprises.
- Description of the Kuber Wallet and its key attributes
The Kuber Wallet allows users to set up their Kuber account with their smartphones and to load their Kuber wallets using PayID.
Key attributes of the Kuber Wallet for individuals are:
- Create the Kuber Wallet in the user(s) smartphone
- Top up or load the Kuber Wallet using PayID
- Send money from the wallet to other Kuber Wallet user(s)
- Make payments to merchants using QR code
- Withdraw funds from the Kuber Wallet to the user(s) bank account
- Use data visualisation on their income and expenditure profile
- Customise their budgets according to category
- Provide budget reminders
- Set up financial goals with progress tracking
- Manually record various assets and liabilities held
- Funds in the Kuber Wallet belong to the individual. There is no minimum balance requirement. However, if the user has not completed their KYC requirements, the total value of transactions allowed is limited to A$200. This means the total value of incoming and outgoing transfers cannot be more than A$200 before KYC is completed.
- Create group payment for users within the Kuber network and request that other users with their network pay a portion of a determined amount from a transaction (called “dutch-in”)
- All funds are held with Zai Australia Pty Ltd (ABN 96 637 632 645) in a segregated trust account with an Australian bank but controlled by Kuber via Zai’s dashboard
Key attributes of the Kuber Wallet for merchants are:
- Create the Kuber Wallet in the user(s) smartphone
- Top up or load the Kuber Wallet using PayID
- Send money from the wallet to other Kuber Wallet user(s)
- Make payments to other merchants or other users using QR code
- Withdraw funds from the Kuber Wallet to the merchant(s) bank account
- Use data visualisation on their income and expenditure profile
- Customise their budgets according to category
- Provide budget reminders
- Set up financial goals with progress tracking
- Manually record various assets and liabilities held
- Funds in the Kuber Wallet belong to the merchant.
- Option to disclose contact information of merchant on automatically generated transaction receipts.
- Create group payment (dutch-in), same as individuals.
All funds are held with Zai Australia Pty Ltd (ABN 96 637 632 645) but controlled by Kuber via Zai’s dashboard
The Kuber Wallet cannot be used for:
- Making cash withdrawals from an ATM or eftopos; Transactions where the total value is greater than $200 if the user has not completed their KYC requirements.
- Excluded class of consumers
The Kuber Wallet is not suitable for:
- Individuals below the age of 18;
- Individuals who do not have access to a smartphone in order to download the Kuber App;
- Individuals who need to make cash withdrawals from ATMS or eftpos;
- Individuals who need to make online or in-store purchases with merchants who are not part of the Kuber platform;
- Individuals or merchants who have failed to complete the Kuber Know-Your-Customer onboarding process, or who on review by the administrator, have provided unsatisfactory responses;
- Individuals or merchants who do not have PayID, or are unable to generate their unique KuberID to share with their banking institution;
- Any individual or merchant or other user who engages in unlawful transactions as set out in the Kuber General Terms of Business;
- Merchants who only accept recurring payments or cash (ie they do not have a bank account)
- Merchants who run a franchise business and are required to do payment processing through their licensor
Individuals or merchants who transacts above $10,000 per transaction
- Consistency (appropriateness) between target market and Likely objectives, financial situation and needs
The Kuber Wallet is likely to be consistent with, and appropriate to, the likely objectives, financial situation and needs of consumers in the target market as they enable users to load and manage their money through the Kuber Wallet, and to obtain insights into their spending and budget habits. They also enable merchants to have an alternative to card payments which come with unnecessary transaction fees, set up costs, monthly maintenance costs and surcharges which the merchant does not have control over and considers as a fixed costs of operating their business.
It also becomes a problem for merchant’s customers who may not wish to pay more than the value of the goods or services they are purchasing. With Kuber’s QR code technology, merchants can provide their customers with a viable alternative that is easily accessible by everyone.
- The Kuber Wallet is distributed in the following ways:
- Online through the Kuber website at www.kuberfinancial.com.au;
- Online through the Kuber mobile application; (from Google PlayStore and Apple AppStore)
- Online through other approved distributors.
- Online through social media platforms (Instagram, LinkedIn, Twitter, Facebook, Substack and TikTok)
- Targeted emails to existing Kuber users
- Push notifications to existing Kuber users
- Through our merchants, including distributing or promoting via posters, physical banners, brochures or flyers at their physical stores.
The issue of the product is subject to the distribution conditions and restrictions which will ensure that the product is only issued to persons for whom it will be appropriate.