GlowPay Target Market Determination
Effective Date: 3 July 2023
Target Market Determination (TMD)
Issuer: Glow Payments Pty Ltd (ABN 48 666 911 084)
Effective Date: 3 July 2023
1. About this document
This Target Market Determination (TMD) is required by law that offers consumers, distributors, and staff an understanding of the class of consumers for which GlowPay is appropriate, having regard to the objectives, financial situation and needs of the target market. It describes the distribution conditions we apply that make it likely that consumers who acquire the product are in the target market, and information regarding how we review, report and monitor the target market and distribution conditions so they remain appropriate.
This TMD applies to the GlowPay platform referred to in the Consumer Terms and Conditions which are available at www.glowpay.co/account-terms-and-conditions
This document is not a full summary of the GlowPay terms and conditions and is not intended to provide any financial advice. Consumers must refer to the GlowPay Terms and Conditions, their application and any supplementary information which outline the relevant terms and conditions under the product when making a decision about this product.
2. Class of Consumers that fall within this Target Market
The below summarises the overall class of consumers that fall within the target market for the GlowPay Instalment Plan.
GlowPay is for employed consumers who purchase health and well-being products and services and prefer to defer payment using instalments. GlowPay’s instalment plan has been designed for consumers whose likely objectives, financial situation and needs are aligned with the product including the key attributes below.
The target market for GlowPay includes consumers who:
are 18 years of age or older;
are an Australian resident with an Australian residential address;
have a valid email address and Australian mobile number;
are employed by and currently earning a regular income from an employer who has partnered with GlowPay to provide the product (Employer Sponsor);
have an eligible Australian bank account to which the product will be linked;
are digitally savvy as the product is distributed and administered online; and
meet GlowPay’s credit assessment criteria.
No interest charged;
No setup, periodic or account keeping fees charged;
Available for sole applicants only;
Finance facility limit up to a total of $2,000;
Instalment plans available for amounts from $100 to a maximum of $2,000;
Multiple instalment plans can be in place simultaneously, within the total finance facility limit;
Ability to re-use up to the approved amount;
Range of instalment amounts (subject to a minimum monthly repayment amount) and instalment frequencies (weekly, fortnightly or monthly); and
Entirely digital including the application process, receiving documents, viewing account details are all completed online.
Needs and Objectives
GlowPay is designed for individual consumers looking to use interest free finance to spread the cost of products and services for their health and well-being, with the following objectives and needs:
to spread the cost of purchasing health and well-being related products and services into instalments without incurring interest costs;
to make a purchase, then receive the same amount of funds repayable as an instalment repayment plan;
ability to make additional repayments or repay early with no added fees;
ability to reuse the available finance up to the pre-approved limit; and
require a digital product.
GlowPay is designed for individuals who:
have the financial capacity to repay the finance amount in accordance with the repayment schedule; and
are able to meet the repayment schedule without missing repayments or experiencing hardship.
Excluded class of consumers
GlowPay is not designed for consumers who:
do not satisfy each Eligibility Requirement and our credit assessment criteria;
do not have an ability to make the repayments;
require finance for amounts above $2,000;
want to use the instalment plan for a purpose other than the purchase of health and well-being related products and/or services;
want access to cash for basic living expenses; or
have irregular or highly variable income.
Consumers in any of these groups are not included in the target market.
Why the product is consistent with the target market
The above description of the target market ensures that GlowPay is being directed towards consumers for whom it has been designed, taking into account their likely objectives, financial situation, and needs. This is based on an analysis of the key attributes, features and terms of the product.
GlowPay has been designed for consumers who want a payment solution to spread the cost of their health and well-being related purchases, with no annual or monthly fees, no interest, fixed repayments and an ability to self- serve their account online. The product design enables this form of repayment schedule and access making it a suitable choice for consumers seeking to defer payments over instalments.
Additionally, the product has been designed for employed individuals that meet our credit criteria and whose financial situation allows them to meet the repayments over the term of the repayment schedule.
The product's key attributes, such as the ability to finance payments for spreading the cost of goods and services related to health and well-being, are consistent with the objectives, financial situation and objectives of the target market. The product's distribution channels, primarily through Employers by Referral, align with the target market's characteristics, ensuring that the product reaches the intended consumers.
3. Distribution Conditions
GlowPay is distributed directly by us to the consumer through an online application via our website and mobile app. Consumers who meet the eligibility criteria can apply for GlowPay directly through these platforms. We provide access to information about the GlowPay product on our website and in our mobile app to assist consumers to consider if it meets their objectives and needs.
GlowPay can also be distributed indirectly through benefits programs offered by an Employer Sponsor through Referral to GlowPay from the Employer’s website or other electronic means in accordance with the applicable agreement between GlowPay and the Employer Sponsor.
All applications can only be approved by GlowPay. Our application systems seek information to establish whether the consumer meets the Eligibility Requirements, including identity verification, and to ask ‘knock out’ questions to determine if a consumer meets the eligibility requirements to determine if a consumer falls within the target market.
The distribution of GlowPay is directed towards consumers who are comfortable with digital services and have the financial capacity to service their ongoing financial obligations.
The marketing for GlowPay does not deliberately target consumers outside the eligibility criteria, which assists in ensuring the distribution is being directed towards the target market.
When Employer benefits programs are used to distribute GlowPay by Referral, monitoring occurs by GlowPay of the activities of this distribution. For example, it is a requirement that the Employer provides GlowPay with ongoing information such as any complaints received.
GlowPay must not be distributed to consumers who do not meet the Eligibility Requirements outlined in this TMD.
Assessment of distribution channels and conditions
Based on the above, we have concluded that the distribution conditions and restrictions will make it likely that a consumer who acquires the product will be in the class of consumers for which it has been designed.
4. Reviewing this Target Market Determination
GlowPay will review the Target Market Determination (TMD) as outlined below.
The initial review of this TMD will be conducted within 12 months of the effective date of this version of the TMD. Subsequent reviews will be conducted at least every 12 months from the last review, or earlier as required.
This TMD will also be reviewed within 10 business days of the identification of a review trigger (below) being met.
GlowPay has set internal thresholds for review triggers and will continually monitor performance against these thresholds in governance forums. A review of this TMD will be performed within 10 business days if GlowPay determines that one of the below review triggers has occurred:
Material Change: A material change to the design or distribution of the product or the key product attributes or terms and conditions that would reasonably suggest that this TMD is no longer appropriate.
Complaints: A significant number or significantly increased number of complaints are received from consumers (directly, or via Employer Sponsors) who have applied for, acquired, or used the product, with respect to the design, functionality, outcome and distribution of the product, which would reasonably suggest that this TMD is no longer appropriate.
Consumer Behaviour: An observation based on analysis of a material consumer behaviour or product usage that would reasonably suggest that this TMD is no longer appropriate. Metrics monitored for customer behaviour would include data on items such as sales volumes, missed payments, complaints and financial hardship.
External Environment: Significant changes to the external environment that would reasonably suggest that this TMD is no longer appropriate, including the regulatory/legislative environment for the product, material adverse media coverage or regulatory attention, as well as the economic and market conditions.
Notification from ASIC: The use of ASIC’s Product Intervention Powers (PIP), regulator orders or directions with regard to this product that would reasonably suggest that this TMD is no longer appropriate.
Significant Dealing: Occurrence of a significant dealing that would reasonably suggest that this TMD is no longer appropriate.
5. Reporting and Monitoring
GlowPay will implement a robust reporting and monitoring system to ensure that the product is being distributed and used in accordance with this TMD. This system will include the following elements:
Distributors will report specific complaints in relation to GlowPay as soon as practicable and within 5 business days of receipt of the complaint. This will include (if available) written details of the complaint, including the complainant’s name, contact details and information about the complaint.
Distributors will also report the number of complaints, the channel they received the complaint, and general feedback relating to GlowPay and/or performance of the product covered by this TMD on a 6 monthly basis.
Distributors will report if they become aware of a significant dealing in relation to this TMD within 10 business days. This will include information about the date or date range of the significant dealing(s) and a description of the significant dealing (e.g., why it has been determined to not be consistent with the TMD).
GlowPay will monitor the distribution of the product and the performance of the product in the market. This will include monitoring of sales volumes, late repayments, complaints, hardship, and arrears.
GlowPay will also monitor external events such as legislative changes, material adverse media coverage or regulatory attention that may impact the appropriateness of this TMD.
This reporting and monitoring process ensures that GlowPay is being distributed and used in a manner consistent with the TMD and allows for timely adjustments to the TMD if necessary. This ensures that the TMD remains relevant and effective, and that the product continues to suit the likely objectives, financial situation and needs of the target market.
For enquiries and information about this TMD, please contact us at firstname.lastname@example.org
Last updated: 3 July 2023