Target Market Determination
Hello Clever Account
Issuer: Hello Clever Pty Ltd ABN 69 637 950 497 | AFSL No. 564985
Date: 4 August 2026
A. About this TMD
Hello Clever Pty Ltd ABN 69 637 950 497, AFSL No. 564985 (Hello Clever, we, us or our) is the issuer of the product described in this Target Market Determination (TMD). This TMD relates to the Hello Clever Account (the Product).
We have prepared this TMD in accordance with our design and distribution obligations under Part 7.8A of the Corporations Act 2001 (Cth). It describes the class of consumers for whom the Product, including its key attributes, is likely to be consistent with their likely objectives, financial situation and needs (the target market). It also sets out our distribution conditions, review triggers, review periods and reporting requirements.
This TMD is not a Product Disclosure Statement. It is not a summary of the features, terms or conditions of the Product, and it does not take into account any person's individual objectives, financial situation or needs. It is not intended to provide financial advice. Before deciding whether to acquire or continue to hold the Product, you should read our Financial Services Guide (FSG) and Product Disclosure Statement (PDS), together with your Merchant Agreement (which includes our Terms and Conditions and your Fee Schedule).
Capitalised terms used in this TMD have the meaning given to them in the PDS, unless otherwise defined.
B. Product Description
The Hello Clever Account is issued to you as a merchant. Its primary purpose is to allow you to receive funds for payments made by your customers for goods and services sold. Once those funds are received into your Hello Clever Account, you can then use the transfer, holding, multi-currency and conversion services in respect of the funds received. The Product operates as follows:
- Hello Clever Solution. The Hello Clever Solution is an online payment gateway. It enables you, as a merchant, to accept card payments and other supported payment methods from your customers in Supported Currencies. It is the means by which you receive funds for payments made by your customers into your Hello Clever Account.
- Payments Sub-Account. Payments accepted through the Hello Clever Solution are settled into your Payments Sub-Account. This is where you first receive funds for payments made by your customers. Chargebacks and refunds, together with any associated fees, are deducted from your Payments Sub-Account. From your Payments Sub-Account, payments and withdrawals can be made to an account held in your name and to third-party accounts. Funds can also be transferred to your Treasury Sub-Account.
- Treasury Sub-Account. The Treasury Sub-Account is a multi-currency wallet. It operates on funds you have already received into your Hello Clever Account. Funds held in your Treasury Sub-Account can be held in multiple Supported Currencies, converted from one Supported Currency to another, withdrawn to an account held in your name, or disbursed to third-party accounts, including accounts held offshore.
- Multi-currency and FX functionality. You can convert funds held in your Treasury Sub-Account from one Supported Currency to another. Each conversion is undertaken pursuant to an over-the-counter foreign exchange contract entered into between you and us. Conversions are pre-funded, which means that a conversion can only occur where there are sufficient cleared funds in your Treasury Sub-Account in the currency you propose to convert. Each conversion is undertaken on the basis of a time-limited quote, which sets out the total conversion rate (which includes our Spread), the fees applicable to the conversion, and the amount you will receive. We are not a speculative trading platform, and the Product must not be used for currency trading or related speculative purposes.
The Hello Clever Account is not a bank deposit. Funds held in connection with the Hello Clever Account are not necessarily held with an Authorised Deposit-taking Institution (ADI), and the Financial Claims Scheme does not apply. The key benefits, risks, and fees and charges of the Product are described in the PDS.
C. Target Market
The Product is designed for businesses based in Australia that accept payments from their customers online. The target market comprises merchants that:
- carry on a business, whether as a sole trader, partnership, company, trustee of a trust or other business structure;
- hold and operate the Product as a merchant, in the course of carrying on a business, and as principal (not as agent on behalf of another party, except where we have agreed otherwise in writing);
- wish to accept card payments and other supported payment methods from their customers online in Supported Currencies for goods and services sold; and
- once funds are received, may wish to hold balances in multiple Supported Currencies, convert funds from one Supported Currency to another, and transfer, withdraw or disburse funds, including to third-party accounts held offshore.
The table below describes the likely objectives, financial situation and needs of merchants in the target market, and the key attributes of the Product that make it likely to be consistent with that target market.
| Likely objectives, financial situation and needs | Consistent key attributes of the Product |
|---|---|
| A merchant carrying on a business that needs to accept online payments from its customers for goods and services sold, including card payments and other supported payment methods. | The Hello Clever Solution is an online payment gateway that enables the merchant to accept card payments and other supported payment methods from its customers, with the proceeds settled into the Payments Sub-Account of the merchant's Hello Clever Account. |
| A merchant that receives, or wishes to receive, customer payments in one or more Supported Currencies, and needs a single facility to receive, hold and manage those funds. | The Hello Clever Account is a multi-currency electronic payment facility. Payments are received into the Payments Sub-Account in Supported Currencies, and funds can then be transferred to the Treasury Sub-Account and held in multiple Supported Currencies. The Hello Clever Account operates on a base currency of Australian dollars (AUD). |
| A merchant that needs to pay, withdraw or disburse funds it has received, including making payments to its own account and to third-party accounts, whether in Australia or offshore. | From the Payments Sub-Account, payments and withdrawals can be made to an account held in the merchant's name and to third-party accounts, and funds can be transferred to the Treasury Sub-Account. Funds held in the Treasury Sub-Account can be withdrawn to an account held in the merchant's name or disbursed to third-party accounts, including offshore accounts, in Supported Currencies. |
| A merchant with foreign currency needs, such as paying offshore suppliers or converting foreign currency receipts, that wishes to convert funds it has received from one currency to another. | The multi-currency and FX functionality allows funds held in the Treasury Sub-Account to be converted from one Supported Currency to another pursuant to a foreign exchange contract. Conversions are pre-funded and undertaken on the basis of a time-limited quote that discloses the total conversion rate, the fees applicable to the conversion, and the amount the merchant will receive, before the merchant confirms the quote. |
| A merchant that needs to monitor and manage its payments and balances on an ongoing basis, using digital channels. | The Hello Clever Account can be accessed via our website or merchant portal and through the Hello Clever Solution, 24 hours a day, 7 days a week, with the ability to review balances and view complete transaction history at all times. |
| A merchant with the financial capacity to meet the fees and charges associated with the Product, and to fund chargebacks, disputes, refunds, reserves and other amounts from its own resources. | Fees, chargebacks, disputes, refunds, reserves and other amounts owed are deducted from settlement or from the relevant sub-account, on a net settlement basis, as set out in the PDS and the merchant's Merchant Agreement and Fee Schedule. Payments and conversions are pre-funded, so the merchant does not obtain credit through the Product. |
Product not designed for certain consumers
The Product is not designed for, and is unlikely to be consistent with the likely objectives, financial situation and needs of, consumers who:
- are not carrying on a business, or who wish to acquire the Product for personal, domestic or household purposes;
- wish to use the Product for currency trading or related speculative purposes, including to speculate on movements in foreign exchange rates;
- require hedging products, such as forward foreign exchange contracts or options, or guaranteed or fixed future exchange rates (conversions are spot conversions of pre-funded amounts at the quoted total conversion rate);
- require access to credit, or the ability to transact without sufficient cleared funds in the relevant sub-account; or
- require funds to be held with an ADI, the protection of the Financial Claims Scheme, or interest on balances held.
D. Distribution Conditions
We apply the following distribution conditions so that the Product is likely to be provided to merchants in the target market:
| Condition | Reason |
|---|---|
| The Product is distributed only by Hello Clever, directly to merchants, through our website, the merchant portal and the Hello Clever Solution. There is no third-party distribution network. | Direct distribution gives Hello Clever full control over how the Product is distributed and to whom, and ensures distribution remains consistent with this TMD. |
| The Product will only be issued to an applicant that registers for a Hello Clever Account, reads and accepts the Terms and Conditions and the Merchant Agreement, and completes our onboarding and identity verification requirements. | Our onboarding and identity verification processes are designed to confirm that the applicant is a business operating in Australia and meets our eligibility criteria, and to comply with our obligations under the AML/CTF Laws. We decide whether to accept an applicant as a merchant at our discretion. |
| The Product is only issued to applicants that will hold and operate the Product as a merchant, in the course of carrying on a business, and as principal. | This condition excludes consumers seeking to use the Product for personal, domestic or household purposes, and persons seeking to transact on behalf of third parties, neither of whom are within the target market. |
| Foreign exchange conversions are only available in respect of funds held in the Treasury Sub-Account, are pre-funded, and are only entered into once the merchant confirms a time-limited quote disclosing the total conversion rate, applicable fees and the amount the merchant will receive. | This ensures that the multi-currency and FX functionality is only used by merchants converting funds they have already received, on an informed basis, and prevents the Product from being used for speculative currency trading or on a leveraged or credit basis. |
| Marketing and promotion of the Product is directed at businesses that accept, or wish to accept, payments from their customers. | Directing promotion at merchants makes it more likely that the consumers who acquire the Product are within the target market. |
E. Review
We will review this TMD within 12 months of its effective date, and at least annually thereafter, or earlier if a review trigger or other event or circumstance occurs that would reasonably suggest that this TMD is no longer appropriate.
Review triggers include:
- a material change to the Product, its key attributes or the PDS;
- the discovery of a significant dealing in the Product that is not consistent with this TMD;
- the distribution conditions being found to be inadequate to ensure that the Product is distributed to merchants in the target market;
- a significant number of complaints, or complaints of a significant nature, from merchants in relation to the Product or its distribution;
- the Product performing in a materially unexpected or unfavourable manner, including a material increase in chargebacks, disputes, unauthorised transactions or failed payments;
- a material change in the law, regulatory guidance or regulator expectations (including any feedback, action or order from ASIC or another regulator) relevant to the Product or its distribution; and
- any other event or circumstance that would materially change a factor taken into account in making this TMD.
If a review trigger occurs, we will complete a review of this TMD within 10 business days, and we will cease to distribute the Product to the extent required until the review is complete and any necessary changes are made.
F. Reporting
We will collect and analyse information about the Product on an ongoing basis to determine whether this TMD remains appropriate. The type of information we will collect includes:
- product performance data, which may include numbers of new Hello Clever Accounts opened, account closure, suspension and dormancy rates, transaction volumes, chargeback, dispute and refund rates, and the volume and nature of foreign exchange conversions undertaken;
- customer feedback and complaints on product experience, including the volume and category of complaints received;
- general feedback from other sources, such as regulators, third-party suppliers and other stakeholders; and
- information or data which may suggest that there are significant dealings in the distribution of the Product.
We distribute the Product directly and do not use third-party distributors. If we engage a third-party distributor in the future, that distributor will be required to report to us:
- complaints information (including the number and nature of complaints received) at least every 6 months;
- any significant dealing in the Product that is not consistent with this TMD as soon as practicable, and in any event within 10 business days of becoming aware of it;
- and such other information as we may reasonably request to enable us to identify whether a review trigger has occurred.
We will maintain records of our decisions in relation to this TMD (including the reasons for those decisions), the information we collect, and the reviews we undertake, and we will notify ASIC of any significant dealing in the Product that is not consistent with this TMD as soon as practicable, and in any event within 10 business days of becoming aware of it.