1. This privacy policy sets out the commitment of The Partner Visa Academy Pty Ltd (ABN 39 642 011 541) trading as The Partner Visa Academy (‘The Partner Visa Academy’, ‘we’, ‘us’) to protecting the privacy of personal information we collect about you, including through our website located at https://thepartnervisaacademy.com.au.
2. Please read this privacy policy carefully and contact us at members@thepartnervisaacademy.com.au if you have any questions, or if you would like to request a copy.
3. By providing us with personal information, you’re telling us that:
a. You’ve had enough time to access this privacy policy; and
b. You’ve read and accepted this policy; and
c. You consent to the collection, use, storage and disclosure of your personal and sensitive information as set out in this policy.
4. If you don’t want to provide personal information to us, or if you don’t agree to this policy, then you don’t have to disclose your personal information.
5. Please be aware if you don’t provide us with your personal information, this may impact how you use our website and or how you access our goods and services.
6. While it is possible for you to remain anonymous or use a pseudonym in reaching out to make an enquiry with us, for example, about pricing or content, due to the nature of our services, it is impractical for us to work together if you elect to use a pseudonym. If are not comfortable sharing your full legal name, then please consider another provider.
7. We can change this policy at any time by posting an updated version on our website or by notifying you directly.
Links
8. To help you find more information, we sometimes include links to other helpful websites from our Website. Please note that this privacy policy only applies to information that we collect on our Website (not any other site).
9. As we aren’t responsible for data collection on those other sites, our privacy policy won’t apply. We can’t guarantee any of the privacy practices of other websites, so please be safe and make sure you read their privacy policy before giving them your personal information.
Opting out
10. From time to time, we’ll send you newsletters, invitations and updates. If you don’t want to receive these communications, you can always opt out by clicking the ‘unsubscribe’ button at any time. You can also opt out by emailing us at members@thepartnervisaacademy.com.au.
11. Please note that if you live in the European Union (EU) the following applies: where we have collected data from you where you have ‘opted in’ for direct marketing purposes pursuant to an offer, the provision of your personal data is a contractual requirement for the delivery of an opt in material.
Making a complaint
12. We can provide you with a copy of the Australian Privacy Principles, which describe your rights and how your personal information should be handled, on request.
c. By post to Office of the Australia Information Commissioner, GPO BOX 5288, Sydney NSW 2001.
15. If you live in the European Union (EU), you have the right to lodge a complaint with a supervisory authority. We hope that you will not have complaints but if you do, please raise them with us. You also have a right to lodge a complaint with the supervisory authority in the EU Member state where you live or work.
17. We collect certain types of personal information from you as set out in the table below:
Type of information
This may include:
Identity data
Your name, username or similar identifier
Profile data
Your username, interests, preferences, feedback and survey responses
Contact data
Your address, billing address, email address and telephone number
Transaction data
Payment details to and from you, your bank account details, details of product purchase and transaction history
Technical data
Internet protocol (IP) address, login data, browser type and version, operating system and platform and other technology on the device you use to access our website
Usage data
How you use our website, and goods and services
Marketing and communication data
Your marketing preferences (including about third-parties) and your communication preferences
Government related identifiers
Your passport number, birth certificate, marriage certificate, visa documentation and drivers’ licence number.
Sensitive information
18. We collect certain types of sensitive information from you as set out in the table below:
Type of information
This may include:
Health data
Your medical history and diagnosis.
Criminal record data
Your criminal record and criminal history both internationally and domestically.
How do we collect your personal information?
19. We’re committed to using lawful and fair means to collect your personal information and in collecting it from others only when it’s unreasonable or impracticable to obtain that information directly from you. For example, where a sponsor completes information on behalf of an applicant and vice versa.
Personal information
20. We collect personal information from you when you:
a. Visit our website; and/ or
b. Make an enquiry with us via our website, by email, web enquiry form, social media or telephone; and/ or
c. Complete an intake form or questionnaire; and/ or
d. Purchase a product or service from us; and/ or
e. Book in for a ‘Free Introductory Zoom Call’ or similar with us; and/ or
f. Sign-up to our membership; and/ or
g. Sign-up to our marketing subscription (such as an email list, newsletter, etc).
Sensitive information
21. We collect your sensitive information in limited circumstances, such as, when:
a. You participate in one of our programs or services and the sensitive information is disclosed to us to us to ascertain suitability for and/or to facilitate the delivery of the program or service;
b. You make an enquiry with us and the sensitive information is disclosed to us to facilitate a referral to an appropriate service provider, such as to our affiliate business, Freedom Migration.
c. You are referred to us by another service provider through a referral, such as from our affiliate business, Freedom Migration.
22. Please be aware that if you are unwilling to provide us with certain sensitive information, such as details about your criminal history or health information, we may be unable to determine your suitability for our services and this may impact our ability to deliver the services to you. For example, certain eligibility criteria apply to our ‘Peace of Mind Application’ services, such as that you do not have a criminal record and that you do not have any significant health concerns. If you don’t provide us with this information, you may not be able to access this service.
23. We limit the circumstances in which we collect personal and sensitive information indirectly to collection by the relevant sponsor or applicant. For example, where a sponsor completes information on behalf of an applicant and vice versa.
Cookies and other trackers
24. From time to time, third-parties may use technology such as cookies, web beacons, or similar, to collect or receive information from you, from our website, or elsewhere on the internet in order to provide measurement services and targeted advertising such as Facebook Pixel, Google Analytics and AdWords.
25. If we receive your personal information from a third-party, we’ll protect it as set out in this policy.
26. We’ll destroy or de-identify your information where we form the opinion that it’s been provided to us unlawfully or unfairly.
Why do we collect, hold, use and disclose your personal information?
27. We collect, hold, use and disclose your personal information as is reasonably necessary for us to perform our core functions and activities, including for the following purposes set out in the below table.
Legal basis to process data
Reason
To prepare to enter into a contract
Contact and communicate with potential clients
To ensure that we are the right fit for our clients and determine your suitability for our services
Verify your identity
To comply with a legal obligation (such as to meet our obligations under contract)
Provide you with our services
Contact and communicate with clients
Process refunds
We may be required to disclose your personal information, (including government related identifiers) under the Migration Act 1958 (Cth) to the Migration Agents Registration Authority (MARA) as required by law, including in circumstances where we receive a written request from MARA to do so.
We have your unambiguous consent (such as where you opt in)
Market to you and others (including remarketing – such as using a Facebook Pixel or similar to display our advertising to you elsewhere on the internet, for example on Facebook or Google).
We have a legitimate interest in processing your data
Maintain a database of customers, subscribers, loyalty program members, or similar
Keep internal records
Improve your customer service experience
Help us improve our website and business and for other statistical purposes
Verify transactions to limit our exposure to risk of or actual fraudulent activity
28. We never sell or rent personal or sensitive information we collect.
Third-parties
29. Where we disclose your personal information to a third-party for the above purposes, we’ll do our best to ensure that their privacy policy adheres to similar standards of privacy or request that they follow our privacy policy when handling your personal information.
30. We’ll also be diligent in ensuring that the personal information we disclose is accurate, up-to-date, complete and relevant.
31. We won’t use or disclose your personal information for the purpose of direct marketing unless you’ve consented to it.
32. We won’t disclose your information for any purposes other than the purpose for which it was collected without your consent unless we’re required to do so by law.
Disclosure to MARA
33. We may be required to disclose your personal information, (including government related identifiers) under the Migration Act 1958 (Cth) to the Migration Agents Registration Authority (MARA) as required by law, including in circumstances where we receive a written request from MARA to do so.
International disclosure
34. We won’t disclose your personal information to international recipients.
How do we hold and protect your information?
How we store personal information
35. We store all personal information we collect electronically, including on or within:
a. Dedicated information storage software, such as client relationship management (CRM) software; and
b. The backend of our website; and
c. The backend of our social media accounts, such as Facebook and Instagram.
Security
36. We’re committed to ensuring that your personal information is secure and protected from misuse, interference, loss and unauthorised access, modification or disclosure.
37. We undertake the following precautions to protect personal and sensitive information we hold:
a. our website contains pages encrypted with SSL (Secure Sockets Layer) to ensure the safety of any data that is submitted through use of this Website; and
b. we limit access to personal and sensitive information to a “need-to-know” basis; and;
c. we password protect client documents; and
d. the backend of our website is password protected; and
e. We use 2-factor authentication to secure our online systems; and
f. we protect devices we use to collect, hold, use and disclose personal information with industry-standard anti-virus software; and
g. our devices are protected by passwords and are stored in secure premises; and
h. all sensitive information is held in secure storage systems protected by passwords; and
i. data is securely stored on cloud servers; and
j. all conversations involving the discussion of personal information take place in private, where conversations are unable to be overheard by unauthorised personnel; and
k. unless required by law (for example if you purchase our services, we’ll need to retain those files for 7 years from the date of our last interaction with your file), if we no longer need personal information, we take reasonable steps to delete or de-identify the information.
Data breaches
38. If a data breach occurs involving personal information and the breach is likely to cause harm, we will notify the individual as soon as possible after the occurrence in accordance with our obligations under the Privacy Act and related legislation. If you are subject to the GDPR, we will report the data breach within 72 hours.
39. While we take commercially reasonable measures to maintain a secure website, electronic communications and databases are subject to errors, tampering and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to you for any such occurrences.
Your Consent
40. We request your consent to the processing of your personal data for the purposes set out in this policy.
41. You give us consent to process your personal data. You can withdraw that consent at any time by sending an email to members@thepartnervisaacademy.com.au. If you ask us to, we will stop using your personal data as soon as possible.
Our use of cookies
42. As you probably know, a cookie is a small text file that’s placed on your computer to help us remember your preferences, like your login information or location.
43. Cookies are used for a variety of reasons. We use cookies to make it easier and faster for you to use our Website.
44. We also use cookies for security purposes to protect you online. We and our third-party vendors may also use cookies to display advertisements to you elsewhere on the internet.
45. You can block the use of cookies by selecting the appropriate settings on your browser. You can opt out of third-party vendor cookies by visiting your Google Ad settings or http://www.networkadvertising.org/managing/opt_out.asp.
46. Please note that the Website may not work as well for you if you disable cookies.
Do you live in the European Union?
47. We’re committed to looking after our customers in the EU and we make every effort to comply with the European General Data Protection Regulation (GDPR), including by processing your personal data in accordance with the principles of data processing set out in the GDPR.
Your rights
48. You have the following rights under the GDPR:
a. the right of access (the right to access personal information we process)
b. the right of rectification (the right to require us to rectify inaccurate personal information or complete our records)
c. the right to be forgotten (the right to require us to erase all your personal information in certain circumstances)
d. the right to restriction of processing (the right to restrict how or why we process your personal information)
e. the right to data portability (the right to receive a copy of your personal information)
f. the right to object (the right to object to us processing your personal information)
g. the right of review (the right to request a human review of automated decision making or profiling)
50. For the purposes of this policy, the following definitions apply:
Concept
Definition
Personal data
Any information relating to you
Processing
Any operation on personal data such as recording, structuring, storing, etc.
Controller
The person or body who determines how and why personal data is processed. In this case, that’s us – The Partner Visa Academy.
Data protection officer
Oversees the data protection strategy
Collecting data
51. The personal data we collect is:
a. processed lawfully, fairly and transparently;
b. collected for the specified, explicit and legitimate purposes including creating our mailing list, direct marketing, taking payments and delivering goods or services to you;
c. adequate, relevant and limited to what is necessary for our purposes;
d. accurate, and where necessary, kept up to date (we will take every reasonable step to ensure that inaccurate personal data is erased or rectified without delay);
e. not stored than for longer than is necessary; and
f. processed in a manner that ensures appropriate security of the personal data.
How we will work with your personal data
52. To help you to understand how we’ll will work with your personal data we set out some key information below. As always if you have any questions just ask – we are here to help!
Who is the controller of the data?
53The controller of the data is The Partner Visa Academy Pty Ltd. Our privacy contact is Rofia Mavadda. Please direct privacy enquiries to members@thepartnervisaacademy.com.au.
What are the purposes for processing the personal data?
55. The purposes for processing personal data are set out above in the clause, ‘Why We Collect, Hold, Use and Disclose Personal Information’.
What is the legal basis for processing the personal data?
56. Where we have collected data from you for direct marketing purposes, the legal basis is your freely given, informed and explicit consent, which you have given by a positive act (i.e. accepting this Privacy Policy) knowing that you can withdraw it at any time.
57. If you are arranging a delivery it is a contractual requirement to take the payment/billing details and delivery information. Where we have collected data from you other than pursuant to an engagement or your consent, we have collected data to facilitate our pursuing our legitimate business interests.
Who receives your personal data?
58. Your data is received by us, The Partner Visa Academy Pty Ltd trading as The Partner Visa Academy, and by our marketing platforms like Facebook and Instagram.
Will we transfer data to a third country?
59. No.
How long will your personal data be stored?
60. We store all personal data indefinitely. This is necessary for our legitimate business purposes and to fulfil the purpose for which we collected the data, for example, to deliver our services to you, to contact you for marketing purposes and to facilitate your easy and convenient use of our website.
Is there automated decision making (including profiling)?
61. We use Facebook, Instagram and Google advertising services, which may use automated decision making. Please refer to their privacy statements, available at https://www.facebook.com/policy.php for more information.
62. You may request access to, rectification or erasure of your personal data, restriction of processing or object to processing for automated decision-making.
Data portability
63. You also have the right to data portability. We may request a reasonable fee to process a data portability request that is manifestly unfounded or excessive, based on the administrative costs of complying with the request. We will contact you promptly and inform you if we require payment of a fee.
64. We will not be obliged to comply with the request until we have received the fee. Please email us at members@thepartnervisaacademy.com.au. if you have a request like this.
Collection and affiliation
65. Please note that we are not affiliated with nor sponsored by Facebook, Instagram or Google.
66. We collect other personal data about you from other sources, as set out in this Privacy Policy.
Access, Correction and Deletion
Access
67. You can request details of personal information that we hold about you in certain circumstances set out in the Privacy Act 1988 (Cth) (the Act). We may refuse to provide you with information that we hold in certain circumstances set out in the Act.
68. Otherwise (including individuals subject to the GDPR), we will provide access to the information if it is reasonable and practicable to do so. In most cases we will do this free of charge, but if your request requires significant effort or expense on our part, we might ask for compensation for that.
Correction
69. If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us at members@thepartnervisaacademy.com.au.
70. We will endeavour to promptly correct any information found to be inaccurate, incomplete, or out of date and to notify of the correction, unless it is impracticable or unlawful to do so.
Deletion
71. If you want us to delete personal information we hold about you or to not collect information from you for a specific purpose, please contact us at members@thepartnervisaacademy.com.au.
72. Please be aware that if you have purchased services from us, we are required by law to hold your client file for a period of 7 years from the date of our last interaction with your file. We are prevented by law from deleting these records during that period.
73. For information that does not relate to a purchaser, such as in circumstances where you have signed up for our mailing list or booked an introductory session, we may process your request in accordance with this policy.
74. Please note that if we agree to delete information, because of backups and records of deletions, it may be impossible to completely delete the information without retaining some residual information.
75. We will respond to any request to access, correct or delete information within a reasonable time.
