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Target Market Disclosure (Australia)

Introduction

Fly Wallet Pty Ltd (referred to as Fly Wallet, us, our or we) are a product issuer and we issue non-cash payment facilities in the form of prepaid cards through payment schemes, such as Mastercard and Visa. We are authorised and regulated by the Australian Securities and Investments Commission (ASIC), with licence number 527319 and registered office located at Suite 62 3-7 Fetherstone Street Bankstown NSW 2200.

The design and distribution obligations set out in Part 7.8A of the Corporations Act 2001 (DD Obligations) apply to the issue and distribution of non-cash payment facilities to retail clients (Consumers). Non-cash payment products are products that allow Consumers to make payments, otherwise than through the physical delivery of Australian or foreign currency using prepaid cards.

The purpose of this target market determination (TMD) is to describe the target market of Consumers for our prepaid Cards to which the DD Obligations apply.

If you are a retail client, you should refer to the relevant Product Disclaimer Statement (PDS) before deciding whether to acquire or continue to hold the relevant product. You can get a copy of the relevant PDS from the website of the distributor of the product subject to this TMD.

You should not base any decision to transact on the contents of this TMD.

Product Information

Product	Bybit Card A non-cash payment facility in the form of a reloadable prepaid Mastercard issued to a customer of the distributor to use digital currencies within a digital currency exchange account to purchase eligible goods and services where Mastercard is accepted.
Product Options	Bybit Card
Issuer	Fly Wallet Pty Ltd
Start Date	1(st) February 2024

Target Market Class of Consumer

Likely needs and objectives

A Consumer:

with a verified digital currency exchange account with Bybit (Bybit Account); and

who may be seeking a reloadable prepaid Card to use digital currencies held within their Bybit Account to purchase eligible goods and services immediately upon presenting the Card for use, wherever Mastercard is accepted.

Likely financial situation

A Consumer who has digital currency within their account available to redeem into US Dollars which can then be used to make purchases with the Card and to pay any fees associated with the use of the Card.

Product Description

A reloadable prepaid Mastercard with the following key attributes:

ability to purchase eligible goods and services electronically where Mastercard is accepted;

ability to redeem digital currency held in an account with Bybit into US Dollars for the exact amount of the transaction, without first redeeming any digital currency prior to the point of transaction;

ability to load the Card to a digital wallet, allowing Consumers to make purchases with eligible mobile devices; and

a requirement to nominate a sequence of digital currencies to redeem and use for purchases with the Card and pay fees (including foreign exchange fees) for using the Card.

It is only available to Consumers who:

have a Bybit Account; and

who are subject to the terms and conditions of the distributor in respect of the buying, storing and selling of digital currencies through the distributor’s digital currency exchange services.

Appropriateness

The product, Bybit including its key attributes, is consistent with the objectives, financial situation and needs of Consumers, as it provides the means to redeem digital currency from a Bybit Account into US Dollars for the exact amount of the transaction, without needing to first redeem a predetermined amount of digital currency into US Dollars, prior to the transaction.

Distribution Conditions

Marketing and Promotion

A distributor must only market and promote the product through:

advertising through media (including social media), physical marketing materials (such as banners, brochures or flyers utilized) and any other marketing material available to the general public; and

any other Fly Wallet approved communication channels (including telephone, email and social media applications.

As the target market for consumers seeking to obtain a Bybit Account is broad in scope a comprehensive marketing and promotion strategy consistent with common industry marketing standards will be put in place for the Bybit Card.

Retail Product Distribution Conduct

A distributor must only engage in retail product distribution conduct (other than general advice):

only to Consumers who have a verified Bybit Account; and

only through:

any other Fly Wallet approved communication channels (including telephone, email and social media).

This condition is appropriate as the target market is further limited to those who already have an account with Bybit and are seeking to use the Bybit Card. The only payment card option available for Consumers on the platform, is the Bybit Card mitigating any risk of confusion to Consumers.

Review Triggers

Fly Wallet and the distributor of this product must cease retail product distribution conduct in respect of this product as soon as practicable, but no later than 10 business days after Fly Wallet determines a material event and/or circumstance has occurred in relation to the areas listed immediately below:

Material Complaints	material complaints (in number or significance) received by Fly Wallet or the distributor in relation to the terms of this product and/or the distribution conduct.
Product Performance	evidence, as determined by Fly Wallet, of the performance of the product, in practice, that may suggest that the product is not appropriate for the target market.
Distributor Feedback	reporting from the distributor, or consistent feedback from the distributor on the target market which suggests that the determination may no longer be appropriate.
Substantial Product Change	a substantial change to the product that is likely to result in the determination no longer being appropriate for the target market.
Significant Dealing	a material pattern of dealings in the product or of distributor conduct that is not consistent with the determination.
Notification from ASIC	a notification from ASIC requiring immediate cessation of product distribution or particular conduct in relation to the product.
Review Period	The first review, and each ongoing review, must be completed within each consecutive 12 month periods from the Start Date.

Reporting Information

A distributor that engages in retail product distribution conduct in respect of this product must provide the following information in writing to Fly Wallet within 10 business days after the end of each reporting period unless indicated otherwise below:

Complaint Information	Information about complaints received in relation to the product during the reporting period, and if complaints were received, a description of the number of complaints and the nature of the complaints received and other complaint information set out in paragraph RG 271.182 of Regulatory Guide 271 Internal dispute resolution.
Distributor Feedback	Information discovered or held by the distributor that suggests that the determination may no longer be appropriate.
Significant Dealing	Information about any significant dealing in the product that is not consistent with the target market determination the distributor becomes aware. The distributor must provide the information as soon as practicable, or in any event, within 10 business days after becoming aware of the significant dealing.
Information Requested by Fly Wallet	Information reasonably requested by the Fly Wallet. The distributor must provide the information as soon as practicable and no later than the date specified by Fly Wallet.
Reporting Period:	The reporting period for this determination is every 6 months commencing from the Start Date.

Other information

Fly Wallet reserves the right to amend the TMD, at any time, if such amendment is needed as a result of any changes to the law or regulations, regulatory guidance or for any reason Fly Wallet considers as a proper reason to amend the TMD.