MuchBetter Financial Services Guide and Product Disclosure Statement
INTRODUCTION
This Financial Services Guide (FSG), which is part one (1) of this document, is issued by MIR MUCHBETTER AUSTRALIA PTY LIMITED ACN 658 003 804 (referred to in this FSG as MIR AU, MuchBetter, we, us or our). The FSG is to help you decide whether to use the Service that we provide.
The Product Disclosure Statement (PDS), which is part two (2) of this document, is also prepared and issued by MIR AU. It contains information to assist you in making an informed decision on whether or not to register and use the Service. The PDS describes the key features of our products, their benefits, significant risks, where we detail the costs and fees of dealing in them, and other related information. You should read this PDS, the MuchBetter e-wallet (Wallet or Service) Terms and Conditions (Customer Terms), our Fees page on the MuchBetter website and our Target Market Determination (TMD) for the Wallet in their entirety before making any decision to enter into a contract with us.
Information relevant to both the FSG and PDS may be included expressly in one part and incorporated by reference in the other.
MIR AU’s legal relationship with our customers is governed by the Customer Terms, the Privacy Policy and this Combined FSG and PDS In the event of a conflict between these documents, the Customer Terms prevail.
. In the event of a conflict between these documents, the Customer Terms prevail.
MIR AU is authorised by the Australian Securities and Investments Commission (ASIC) and holds an Australian Financial Services Licence (AFSL) (AFSL no. 540851).
You are able to contact us at any time via:
· the MuchBetter website at https://muchbetter.com/; and
· email at support@muchbetter.com
Capitalised terms used in this document have the meanings given in brackets within this document or section 10 of the PDS titled “Dictionary”.
PART 1 – FINANCIAL SERVICES GUIDE
Introduction
This FSG contains only general information about the services we offer.
Any material provided to you by us, including in this document, will contain factual information or general advice only, and does not take into account your particular objectives, financial situation and needs, and a statement of advice will not be provided. Accordingly, you will need to consider the appropriateness of the information having regard to your particular circumstances and obtain professional advice. You should carefully read all of the information that we provide you before using our Service. If you have any questions after you have read the FSG and any additional information we provide to you, please contact us.
MIR AU Overview
MIR AU is authorised by ASIC and is the holder of AFSL 540851.
MIR AU is an Australian company which is part of a portfolio of investments and for the purposes of the section 9 definition of the Corporations Act 2001 (Cth) Manatee Holdings Limited is the entity that is the top “controller” for practical licensing purposes. Therefore, Manatee Holdings Limited is considered the “ultimate holding company” of MIR AU. Rtekk Holdings Limited (Rtekk) is an intermediate holding company of MIR AU and is the main operating company for the MuchBetter business which is already established in the UK and other countries. Rtekk owns the MuchBetter brand and technology and also employs most of the staff working in the MuchBetter business.
References in this document to MIR Group means Rtekk Holdings Limited (incorporated in the Isle of Man with company number 018684V), its subsidiaries, holding companies and associated companies (including MIR AU);
MIR Limited UK Ltd is registered in the United Kingdom (UK) and holds an Electronic Money Institution (EMI) licence issued by the UK Financial Conduct Authority.
MIR Canada Financial Limited is registered in Canada and holds a Registered Money Service Business (MSB) authorisation issued by the Financial Transactions and Reports Analysis Centre of Canada.
MIR-MuchBetter EDE S.L. is registered in Spain and as at the effective date has an application on foot for registration as a Registered EDE S.L. Electronic Money Institution with the Bank of Spain.
How to contact us
You are able to contact us at any time via:
the MuchBetter website at https://muchbetter.com/; and
email at support@muchbetter.com.
MIR AU’s Service
MIR AU is authorised to deal in and provide general financial product advice on digital payment products for both retail and wholesale clients.
The financial products we can provide to you include the MuchBetter digital wallet (the Wallet or the Service). The Wallet allows you to:
hold electronic money in a digital wallet in a denominated currency of your choice (subject to our list of currencies which are available from time to time);
deposit and spend funds safely and rapidly, specifically with a variety of licensed online gambling / gambling brands and various online merchants;
send to, and/or receive funds from, via P2P transfers with other MuchBetter Group digital wallet users (including Wallet users) domestically or overseas; and
facilitates currency exchange by allowing you to make a transaction (i.e. top up, withdrawal or payment) in a currency other than the one denominated in your account.
Accessing your Account
You can access your Account through the MuchBetter App only, being the Gateway and Cash App (each respectively and jointly an Authorised User Site).
In order to access the Service, you must sign into your Account and submit your instructions, and where applicable, any additional information required to use any of the Service.
Before you sign into the Authorised User Site to use the Service, it is important that you understand the risks, fees, costs and benefits of using the Service. For information on the risks, fees, costs and benefits related to the Service, you should carefully read and ensure you understand the PDS and Fees as well as the Customer Terms.
How income is generated
MIR AU earns income by:
charging fees when you engage in particular transactions in using the Wallet. An outline of our fees are detailed in section 5 of the PDS; and
earning interest on the monies from an Australian ADI in which we hold your Account funds.
providing digital payment services to merchants
MIR AU and associates remuneration
MIR AU does not receive any commissions, remuneration or other benefits from third parties for the Services we provide to you.
Our staff receive a salary plus superannuation where applicable. Our staff may also be eligible for monetary and non-monetary awards or additional incentive payments, including bonuses and shares.
You can request more information about certain relevant remuneration payments referred to above before we provide our services to you.
Conflicts of Interest and Third Parties
MIR AU does not have any relationships or associations with third parties which might influence us in providing you with the Service.
Insurance
We hold professional indemnity insurance (PII), which covers the financial services we are authorised to provide to you. Our PII:
is held in accordance with the requirements of section 912B of the Corporations Act 2001 (Cth); and
provides cover for claims made against us and our representatives or employees.
Complaints
If you need to make a complaint, you should contact our customer support team. You can raise your complaint by emailing us at support@muchbetter.com.
We have 30 days from the date of receipt of your complaint to resolve the issue. However, we will seek to resolve your complaint as soon as is practicable in the circumstances. If we take longer than two weeks to provide you with a final response, we will contact you and provide an indicative timeframe on when we can resolve your complaint.
MIR AU is a member of an independent dispute resolution scheme, the Australian Financial Complaints Authority (AFCA). Our AFCA membership number is: 103239
If the complaint cannot be resolved by our internal complaints procedure; or if you are dissatisfied with the outcome; or if we fail to resolve the complaint within the 30 day period, you can direct the complaint to AFCA. You can contact AFCA at:
Australian Financial Complaints Authority
GPO Box 3 Melbourne VIC 3001
Phone: 1800 931 678
Website: www.afca.org.au
Please also refer to our Complaints Policy:
Your Privacy
We will maintain complete records of the Service we provide to you in accordance with applicable laws. As a financial services provider, we have an obligation under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) to verify your identity, amongst other things.
If we are unable to collect all information requested in the account opening process or requested during the subsequent Service, we may be unable to provide or continue to provide the Services. We will also retain copies of this information.
We also keep a record of personal information you provide to us. Your privacy is important to us and we are committed to comply with the Privacy Act 1988 (Cth) and Australian Privacy Principles contained therein.
If you wish to access information we hold about you or have any concerns, please contact us. A copy of our Privacy Policy is available from our website .
PART 2 – PRODUCT DISCLOSURE STATEMENT
This Product Disclosure Statement (PDS) is dated 01 January 2025 and was prepared by MIR MUCHBETTER AUSTRALIA PTY LIMITED ACN 658 003 804 (referred to in this PDS as MIR AU, MuchBetter, we, us or our). MIR AU is authorised by the Australian Securities and Investments Commission (ASIC) and holds an Australian Financial Services Licence (AFSL) (no. 540851).
The financial products we can provide to you include the MuchBetter e-wallet (the Wallet or the Service) (a digital payment facility).
Capitalised terms have the meanings given in brackets within this PDS or as ascribed to them in section 10 of the PDS titled “Dictionary”.
Information about this PDS
This PDS is intended to assist you in deciding whether the Service described in this PDS is appropriate for you. The PDS also provides information on the Service that we provide. You may also use this PDS to compare these financial products against similar financial products offered by our competitors.
You should read this PDS in full before deciding to use our Service and keep this PDS and other documentation relating to your transactions for future reference.
MIR AU’s legal relationship with our customers is governed by the terms and conditions for the Wallet (Customer Terms), the Privacy Policy and this Combined FSG and PDS.
This PDS contains information to assist you in making an informed decision on whether or not to register and use our Services. The PDS describes the key features of our product(s), its benefits, significant risks, the costs and fees of dealing in them and other related information. Note that the information contained in this PDS is general in nature and does not take into account your personal objectives, financial situation or needs. You should obtain independent financial advice to ascertain whether our Services are appropriate for your financial situation. You should read this PDS, the Customer Terms and our TMD(s) in their entirety before making any decision to enter into a contract with us.
This PDS does not constitute a recommendation or opinion that the Service is appropriate for you. The information contained in this PDS is general in nature and does not take into account your personal objectives, financial situation or needs. You should obtain independent financial advice to ascertain whether our Services are appropriate for your financial situation. You should not undertake foreign exchange or enter foreign exchange contracts unless you properly understand the nature of foreign currency exchange products and are comfortable with the risks.
Information relevant to both the FSG and PDS may be included expressly in one part and incorporated by reference in the other.
If you do not understand any part of this PDS, have any questions regarding the PDS, or require any further information, you are able to contact us at any time via:
the MuchBetter website at https://muchbetter.com/; and
email at support@muchbetter.com.
About the Wallet
The Wallet is accessible through the Account.
The Wallet is an account which records the electronic money issued to you in exchange for money MIR AU received from you (otherwise known as stored value) when you open the account or top it up later.
Wallet – Sign-Up
You can apply for a Wallet through the Website, as well as the Apple and Google Play App Store (the App). You must meet the eligibility requirements set out in the Customer Terms.
Once you have stored value in your Wallet, you will be able to use the services and features described in paragraph 2.5.
Wallet – Key Features
Key features of the Wallet are set out in the table below.
Key Wallet Features | Description |
Currency Denomination | You can hold electronic money in a digital wallet in a denominated currency of your choice (subject to our list of currencies which are available from time to time). |
Deposit and Spending | Deposit and spend funds safely and rapidly, specifically with a variety of online gambling / gambling brands and various online merchants. |
P2P Transfers with MuchBetter | Send to, and/or receive funds from, P2P transfers instantly via other MuchBetter Group e-wallet users (including Wallet users) domestically or overseas |
Currency Exchange | Facilitates currency exchange by allowing you to make a transaction (i.e. top up, withdrawal or payment) in a currency other than the one denominated in your account. For example, you can pay with a gaming merchant in USD even though the denominated currency of your Wallet is AUD. |
View and Manage | View information about and manage your Wallet. |
We may add new features and services to the Wallet from time to time. We will inform you about these changes through the Website, App, by email and/or (where relevant) by updating this PDS.
All transaction information is available anytime and free of charge through your MuchBetter e-Wallet.
You can top up funds to your Wallet by multiple payment methods. The process for topping up your Wallet is explained in more detail in the Customer Terms.
You can withdraw funds from your Wallet using various methods, which are fully explained in the Customer Terrms.
You may choose one of several currencies as the denominated currency of your Wallet. From time to time, acting reasonably, we may remove and/or add currencies which are available for denomination in your Wallet. However, note that we provide no representation that any currency (other than AUD) will be available as the denominated currency during your use of the Wallet.
Some of the features (including the transactions) specified in the table at paragraph 2.5 above may incur charges as referenced in the Fees and Charges section of the PDS (see section 5 of the PDS). The charges will also be displayed in the MIR AU Application when you perform a transaction. You may need to accept the charges in order to make the transaction.
Please also refer to the Customer Terms for further information regarding the specific terms and conditions applicable to the Wallet.
Wallet – Client Money Provisions
MIR AU is not a bank and the Wallet is not a bank account. The key differences between the Wallet and a bank account are:
electronic money (also known as stored value) held in your Wallet represents a claim against MIR AU only;
we cannot and will not use the funds we hold in relation to a Wallet to lend to others;
the Wallet does not accrue interest; and
the Wallet is not covered by the Financial Claims Scheme that operates in Australia.
The client funds we hold in relation to Wallets are segregated from our operating funds and are held in a pooled trust account with an Australian ADI pursuant to the Client Money Provisions. Specifically, in this regard, the funds representing your balance and the balance of other clients are protected and held together in the same pooled account. With respect to the funds held in the pooled account:
we are entitled to earn and retain interest on those funds; and
are not required to pay you or any other clients any interest earned on those funds.
Wallet – Key Terms
In the table below, we outline key terms relating to the Wallet. Please also refer to the Customer Terms for further information regarding the specific terms and conditions applicable to the Wallet.
Key Terms | Description |
Incorrect Payment by You | Where you have authorised payment to the incorrect person or account we are not required to reimburse you. There may be very limited circumstances where we can recover your funds. |
Unauthorised Transactions to Others
| We will try our best to help you recover payment when an unauthorised transaction occurs on your Account. You will be entitled to a refund in the amount of the unauthorised transaction where you notify us without undue delay and in any case no later than thirteen (13) months after the transaction date, subject to the following: – your Account identification information has been stolen and you have not notified us of this (you are liable to a maximum of AUD $100 in this circumstance); – if you have failed to keep your Account identification information safe (you are liable to a maximum of AUD $100 in this circumstance); – you have acted fraudulently with respect to the unauthorised transaction (you are liable for the loss in this circumstance); and – you have compromised the security of your Account with intent or with negligence (you are liable for the loss in this circumstance). |
Unintended Transaction to You | We are entitled to remove funds from your Account which were not intended for you and return those funds to the payor. |
Our Error / Breach | You will be entitled to a refund in the amount of a transaction where that transaction was incorrectly executed by us or involved our breach of the Customer Terms. |
Disputes with Merchants | You must notify us a dispute with a merchant within 180 days and we will attempt to chargeback the transaction. There is no guarantee that you will receive a chargeback in this circumstance – specifically, payment of any amount to you in relation to this dispute will require us successfully securing the chargeback from the merchant. We may recover any reasonably incurred expenses in securing a chargeback for you from a merchant. |
Transaction Refusal | We may refuse to execute a transaction on your Account where: we reasonably believe that you did not give us the instruction; – we reasonably suspect fraudulent activity; – your instructions are unclear, incomplete or not in the required form; – we suspect that that the Customer Terms have been violated; or – we are otherwise required to do so by law or any other appropriate regulatory body. |
Negative Balance | If your Account has insufficient to cover your payments and any applicable fees, this will result in a negative balance. You must within two (2) business days top up your top up your Account to eliminate the negative balance. If you do not do this, we may restrict your access to the Account or otherwise limit your rights as a customer. |
Currency Exchange | Our currency exchange rate service is provided by XE.com, and these are updated throughout each day. It is your responsibility to check the applicable rates on XE.com before proceeding with transactions involving an exchange of currency. In most currencies, we will add a margin to the mid-market exchange rate provided by XE. We are not a currency exchange. We are not responsible for any loss due to changes in exchange rate. If the transfer method is not an instant method, the exchange rate as described above will be applied when we are provided a confirmation of the transfer by our payment processor. You can also see the exchange rate of your transaction from the transaction history in the App, by tapping on the specific one. You will see the transaction amount, exchange rate, and any fees as applicable. |
Key benefits and risks
The below is a schedule that summarises the key benefits and key risks of the Wallet.
Key benefits | Key risks |
(Payments) You can choose to make and receive instant payments to the accounts of other MIR AU / MIR Group customers and merchants including a variety of online gambling / gaming brands. | (Unauthorised Transactions) You may suffer loss if there are unauthorised transactions on your Wallet. The more you load into your Wallet, the more you could lose due to an unauthorised transaction. The Customer Terms explain when we or you will be responsible for unauthorised transactions. |
(Currency Exchange) Your Wallet enables you to make transactions (i.e. top up, withdrawal or payment) in currencies other than the denominated currency in your Wallet. For example, this allows you to make transactions with particular merchants, including gaming merchants, in their chosen currency. MIR AU offers competitive foreign currency exchange rates. | (Currency Exchange Rate Risk) Foreign currency exchange rates are variable. This means they are constantly changing and may depend on a combination of factors, including but limited to the currency, market liquidity and market volatility. Accordingly, depending on the type of transaction, such fluctuations may mean that: – you spend more of your denominated currency than anticipated; and – receive less money than anticipated (e.g. by way of withdrawal from your Wallet to your personal bank accounts). Similarly, currency exchange rate fluctuations may improve after we have made your currency exchange. |
(Payments) You can choose to make and receive instant payments to the accounts of other MIR AU / MIR Group customers and merchants including a variety of online gambling / gaming brands. | (Recovery of Insufficient Funds) If your Wallet goes into a negative balance, we reserve the right to recover these funds from you. |
(Payments) You can choose to make and receive instant payments to the accounts of other MIR AU / MIR Group customers and merchants including a variety of online gambling / gaming brands. | (Correspondent Banks) When making an international payment, it is not always possible for MIR AU to know how much a customer will be charged by the banks involved in the transaction. For example, if a user makes a payment to a country outside of Australia, the receiving bank could charge for accepting that payment. |
Wallet limits
The below is a schedule that outlines the account limits that apply to the Wallet:
ALL MONEY IN (PERIOD) | Limit amount (AUD or equivalent) |
One time | 100,000.00 |
Daily | 100,000.00 |
Monthly | 100,000.00 |
Annual | 100,000.00 |
WALLET LOAD MONEY IN (PERIOD) |
|
One time | 1500.00 |
Daily | 38,500.00 |
Monthly | 38,500.00 |
Annual | 38,500.00 |
WALLET TRNSFER MONEY IN (PERIOD) |
|
One time | 2000.00 |
Daily | 5000.00 |
Monthly | 10,000.00 |
Annual | 38,500.00 |
The maximum annual deposit available is reduced by the amount of each deposit transaction and reinstated by the same amount 12 months after each deposit transaction (subject to any decrease or increase we may make to this limit). You will not be able to make further deposit into your Wallet once the maximum annual deposit limit is reached, however, you can still spend your available balance as usual.
The below table is a simple example of how the maximum annual deposit limit on your Wallet works. Assume that you make your first deposit into your Wallet on Year 1:
Deposit date | Deposit amount (AUD or equivalent) | Accumulated deposit amount (AUD or equivalent) | Annual deposit balance remaining (AUD or equivalent) |
Year 1 | |||
5 May | 40,000 | 40,000 | 60,000 |
1 September | 50,000 | 90,000 | 10,000 |
7 November | 10,000 | 100,000 | 0 |
Year 2 | |||
5 May | 60,000 | 60,000 | 40,000 |
1 September | 10,000 | 70,000 | 30,000 |
7 November | 10,000 | 80,000 | 20,000 |
Fees and Charges
The primary Fees and Charges are set out on the website at https://muchbetter.com/muchbetter-fees
The Fees and Charges may change from time to time and any such changes will be communicated to you. You can also find information about new fees and charges on the Website.
Dispute Resolution
If you have a complaint or are otherwise unhappy with the Services, please contact us through the Website.
Alternatively, you can submit a complaint by contacting the support team at complaints@muchbetter.com.
You may also send us a letter addressed to:
MIR MUCHBETTER AUSTRALIA Pty Limited
Level 19/180, Lonsdale Street
Melbourne VIC 3000
You will need to provide us with:
your full name;
the phone number and email address associated with your account;
when the problem arose; and
your preferred outcome.
We will look into your complaint and respond to you as soon as possible or otherwise within 30 days following receipt of the complaint.
Australian Financial Complaints Authority
If you are unhappy with how we have dealt with your complaint, you can refer it to AFCA. AFCA provides fair and independent financial services dispute resolution that is free to customers. Their address is:
Australian Financial Complaints Authority Limited
GPO Box 3
Melbourne VIC 3001
Phone: 1800 931 678 Email: info@afca.org.au
You can find more information on their website.
Tax
You are responsible for any taxes that you may incur from using the Service provided by MIR AU.
Privacy
For information on how your personal information is collected, held and used by MIR AU, please see our Privacy Policy available at [INSERT].
Dictionary
In this PDS, the following terms have the corresponding meaning except where expressly stated to the contrary or where context otherwise requires:
Account means the account you open with MIR AU through the Website or App to access the Service.
FSG means Financial Services Guide.
MIR AU means MIR MUCHBETTER AUSTRALIA PTY LIMITED ACN 658 003 804.
MIR Group means Rtekk and its subsidiaries, including MIR AU.
PDS means Product Disclosure Statement.
Rtekk means Rtekk Holdings Limited.
Service means the Wallet.
Customer Terms mean the Terms and Conditions applicable to the Wallet https://www.muchbetter.com/legal/muchbetter-terms-and-conditions.
TMD means Target Market Determination.
Wallet means the MuchBetter e-wallet.
Website means MuchBetter.com through which we offer the Service or information related thereto.