Privacy Policy

Protecting your privacy and keeping your personal information confidential and secure is important to Migration Manager. This  Privacy Policy outlines the policy of Migration Manager Pty Ltd and its related companies for maintaining your privacy and handling your personal information. This notice applies across all websites that we own and operate and all services we provide, including Migration Manager, Migration Manager Cloud, our Assessment and Portal products, and any other apps or services we may offer (for example, events or training). For the purpose of this notice, we’ll call these our ‘Services’.

When we say ‘personal data’ we mean identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, support queries and so on. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply. 

This Privacy Policy relates to personal information we handle about our Clients, visitors to our websites and other members of the public. Note that Clients of our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals (also referred to as “Customers”) with whom our Clients interact. If you are an individual who interacts with a Migration Manager Client using our Services, then you will be directed to contact our Client for assistance with any requests or questions relating to your personal information.

1. Who we are

When we refer to ‘we’ (or ‘our’ or ‘us’), that means  Migration Manager Pty Ltd and all its wholly owned subsidiaries. Our headquarters are in Australia. Our contact details are at the bottom of this page.

2. What information we collect

  1. We collect personal information that has been directly provided to us by you or is otherwise available in the public domain where this information will assist us with the provision of services or which is necessary to do business with you.
  2. The personal information that we collect about you includes your name, postal and street address, email address, telephone number, gender, age, profession/role, place of work, business details, information relating to your support requests, technical issues or complaints you have made to us and various personal preferences. We also collect your payment information, such as your credit card or direct debit information and ABN, when you purchase a product or service from us.
  3. In certain circumstances we may collect sensitive information about you such as your membership of a professional association (e.g. Migration Institute of Australia status).  We collect that information if you voluntarily give it to us or if you otherwise consent (expressly or by implication) to us collecting it. If you: (a) provide us with sensitive information; or (b) authorise the organisation to which you are member to make this information available; this will constitute your consent.

3. Customer Data

  1. Clients/Users of Migration Manager may electronically submit data or information about their customers to our Services (“Customer Data”). Furthermore, on the instructions of a Migration Manager Client, we may provide services on behalf of these Migration Manager Clients to enable the collection, storage and usage of personal information of their customers.
  2. We are the Data Processor of Customer Data that has been provided to us by either the Migration Manager Client or the Customer.
  3. Migration Manager will not review, share, distribute, or reference any such Customer Data except as provided in our End User Agreement, or as may be required by law. In accordance with our End User Agreement, Migration Manager may access Customer Data only for the purposes of providing the services, preventing or addressing service or technical problems, at a Client’s request in connection with support matters, or as may be required by law.
  4. All Customer Data that we process is stored in an encrypted format in an Azure data center located in Australia.
  5. If you are Customer of a Migration Manager Client, and you would like your data edited, rectified or accessed, or for any other queries, please contact the Migration Manager Client directly.

4. How we collect information

  1. We collect personal information that you provide to us through:
    • making an order
    • registering a product;
    • registering for a product trial;
    • new client forms;
    • actions performed by you from within your product;
    • transactional services and payment services;
    • client/technical support;
    • software error and usage reports;
    • inbound and outbound sales calls/emails;
    • our website, including the client self-service portal;
    • competition entry forms;
    • bookings for training and events;
    • release forms and product testimonials;
    • customer surveys;
    • when you register for newsletters;
    • job applications;
    • when you contact us via email, telephone or fax; and
    • when you provide material to us to enable us to provide our services to you.
  2. We may also collect personal information about you:
    • from our third party joint initiative partners;
    • that is publicly available; and
    • from third parties that provide us with marketing leads.

5. Website Access & Cookies

  1. As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.
  2. We use "cookies" to store specific information about you and track your visits to our Site. It is not uncommon for websites to use cookies to enhance identification of their users. A "cookie" is a small amount of data that is sent to your browser and stored on your computer's hard drive. A cookie can be sent to your computer's hard drive only if you access our Site using the computer. If you do not de-activate or erase the cookie, each time you use the same computer to access our Site, our web servers will be notified of your visit to our Site and in turn we may have knowledge of your visit and the pattern of your usage. We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can learn more about cookies by visiting http://www.allaboutcookies.org.
  3. You can determine if and how a cookie will be accepted by configuring your browser, which is installed in the computer you are using to access the Site. If you desire, you can change those configurations in your browser to accept all cookies, to be notified when a cookie is sent, or to reject all cookies. If you reject all cookies you may be required to re-enter your information on our Site more often and certain features of our Site or Service may be unavailable.
  4. Examples of Cookies we may use:
    • Session Cookies. We may use Session Cookies to operate our Service.
    • Preference Cookies. We may use Preference Cookies to remember your preferences and various settings.
    • Security Cookies. We may use Security Cookies for security purposes.

6. How we use information we collect

  1. We collect, hold, use and disclose personal information to:
    • better understand our customers and users, and to provide better services. This includes understanding the operations of our service and user interactions with it, maintaining the quality of the service and analysis of site trends and statistics that help us improve our offer and design new services for the future;
    • fulfill orders and provide you with the products and services you have asked for;
    • assist you to provide services to your client(s);
    • perform product registration, identify you as the product owner and to provide client support and service to you, your business partners and your employees;
    • perform transactional services and payment services, including authorised financial transactions with you and your associated service providers;
    • provide you with software and related services;
    • provide you with technical support and/or training;
    • undertake software error analysis and debugging on your product;
    • keep you informed about our products and services and those of relevant business and joint initiative partners;
    • register and renew domain name(s) on your behalf;
    • record your marketing and communication preferences;
    • enable secure access to our websites;
    • participate in the process of any third party acquisition or potential acquisition of an interest in us or our assets;
    • fulfil any legal and regulatory obligations; and
    • process a job application.
  2. Direct Marketing: We may use your personal information to contact you about product upgrades and new product releases and to let you know about new services and special offers relevant to your business. If you do not want us to use your personal information for direct marketing, you can let us know at any time by emailing us at [email protected]
  3. Order fulfilment: When ordering products and services, you need to provide us with your contact information (such as name, email address, phone number and, if it’s applicable, a delivery address) and financial information (such as your credit-card information if you are using this payment method).We use this information to fulfil your order and bill you. If we have trouble processing an order, we use the contact information you give us to contact you so that we can resolve the problem.
  4. Client support: When you contact Migration Manager support, our technical consultants use your personal information and any other information you provide to able to give you quality advice that is relevant to your particular situation. 
  5. Error analysis and debugging: When you use Migration Manager, if the software encounters an error you can elect to send the results of this error via encrypted messaging services to the technical support team for analysis and debugging. Within the preferences of Migration Manager you can opt out of sending this information at any time.
  6. Using Product Features: When you use the Migration Manager software, you can elect to use our servers and services to collect, store and transmit your customer data. We will not review, share, distribute or reference any such customer data except as provided in the Migration Manager End User Agreement or as may be required by law. In accordance with the Migration Manager End User Agreement, we may access Customer Data for the purposes of providing the services, preventing or addressing service or technical problems, at your request in connection with support matters, or as may be required by law.
  7. Aggregated data: Aggregated data is data that does not contain any information specific to a particular individual or business, such as statistical trends in a particular industry sector. We sometimes share aggregated data with our business partners.
  8. Disclosure to third parties: We may provide your personal information to our related companies and to service providers that we outsource functions to. These service providers may assist us with client contact, archival, auditing, accounting, legal, business consulting, banking, delivery, data processing, automated communications, website or technology services. Some of the third parties described above may be located in the United States, Europe, New Zealand or other countries. We will also disclose your personal information if we are required by law to do so.
  9. Debt Collection and Credit Reporting Agencies: In circumstances where accounts rendered to you, for services provided to you, have not been paid in accordance with their terms and despite further requests payment has not been forthcoming we may provide your personal details to a Debt Collection and Credit Reporting Agency.  In that event only such information that is reasonably necessary and relevant to the collection of the outstanding debt will be disclosed. 
  10. To meet Legal Requirements, including complying with court orders, valid discovery requests, valid subpoenas and other appropriate legal mechanisms.
  11. To prosecute and defend a court, arbitration, or similar legal proceeding.
  12. To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  13. To provide suggestions to you. This includes adding features that you or your clients may be interested in, or using data to suggest products or services that you may be interested in or that may be relevant to you or your clients. 
  14. To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

7. How we share or transfer information we collect

  1. Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
  2. We do not disclose personal information to overseas recipients apart from:
    • any disclosures which may occur as a result of the use by us of IT service providers. We may do this where we have made a business decision to store our data with a trusted service provider who is in the business of providing data storage and processing services.  Examples are those who store and process our email and mobile application data. This including but is not limited to “cloud”-utilising providers such as Google, Dropbox, Raygun, Acuity, Salesforce, Slack, Atlassian and Microsoft etc.  These providers may be based overseas or use overseas infrastructure to perform services for us, including in the USA, UK or EU. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency.  Where these services are used by us, it is not practical for us to notify you of which country your personal information may be located in. Providers whom we may store and process data with who may located outside of Australia include Microsoft, Adobe, Dropbox, Google, Wordpress, Amazon, Raygun, Acquity, Salesforce, Slack, Jira etc.
    • occasions where we are required to do so in order to provide you with our products or services, or manage our relationship with you;
  3. Migration Manager will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data and other personal information.
  4. When you use our services, we may share certain information about you with other parties including:
    • Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
    • Law Enforcement: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect us, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
  5. We do not otherwise sell, rent, trade or exchange any Personal Data of our Clients, Users, Customers or Visitors. 
  6. By having dealings with us you acknowledge and consent to disclosure of your personal Information to the overseas recipients described above in the circumstances described above. 

8. Security of personal information

  1. Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens. We take appropriate measures to protect Personal Information from loss, misuse and unauthorised access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. Data that is provided to us is stored by us using services such as Salesforce, Migration Manager software, Azure, Raygun, Dropbox, Freshdesk and Jira. We ensure that all third party services that we use to store your personal data have in place the requisite security to protect your data.
  2. If a security breach causes an unauthorised intrusion into our system that materially affects you or your clients, then we will notify you as soon as possible and later report the action we took in response.

9. Information access and correction

  1. Subject to any exceptions in the Privacy Act, if you have provided us with personal information, you have a right to request to access or correct it. If you want to access or correct your personal information you should contact us using the contact details at the bottom of this web page.
  2. Once you have made your request for access or correction, we will respond within a reasonable period. In some cases we may ask you to pay an administrative fee to cover costs associated with your request for access. To assist us in responding to your request, please include as much detail as possible about the particular personal information that you are seeking to access or correct (in order to help us locate it) and, if applicable, how you would like to access the information.
  3. We will provide you with a copy of or details of your personal information wherever it is possible and practicable to do so. Otherwise, we will work with you to find a mutually agreed alternative.
  4. If after exploring all options, we refuse to correct or give you access to your personal information, we will provide you with a written notice that sets out the reasons for the refusal (except where it would be unreasonable to do so), the mechanisms available to you to complain about the refusal and any other matters that the Privacy Act requires us to address.

10. Data Retention

  1. We do our best to keep your personal data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes.
  2. We will retain your information for as long as your account is active or as long as needed to provide you with our Services (for details see our End User Agreement). We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.

11. Questions, Concerns and Complaints

  1. If you wish to complain about a breach of the privacy rules that bind us, you may contact our support team at one of the above contact points.  We may ask you to put your complaint in writing and to provide details about it. 
  2. We may discuss your complaint with our personnel and our service providers and others as appropriate.
  3. We will investigate the matter and attempt to resolve it in a timely way. We will inform you in writing about the outcome of the investigation.  If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the Privacy Commissioner for further investigation and will provide you with the Commissioner’s contact details.

12. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time at our discretion. We will make any changes available on our websites. You can also obtain a copy of the most current Privacy Policy by either emailing or writing to our support team using the contact details set out below.

13. Your Authorisation

When using any of our services you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information, and the information of your customers, as described in this Privacy Policy.

14. Contact Details of our Privacy Officer

To contact our Privacy Officer please send an email or letter marked to the attention of "The Migration Manager Privacy Officer" care of the contact details at the bottom of this page.

15. Contacting Migration Manager

Email: [email protected]

Post:

MIGRATION MANAGER 

PO Box 182

Nerang QLD 4211