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Privacy Policy

Last updated: March 2026 (Draft) 

Emigration Guru Pty Ltd (ABN [PENDING]) (“Emigration Guru”, “we”, “us”, “our”) operates the website www.emigrationguru.com and related services (the “Platform”).
We are committed to protecting the privacy of the personal information we collect from you. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
By using the Platform, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with this policy, please do not use the Platform.

1. Who We Are
Emigration Guru is an Australian-based online marketplace that connects migrants seeking visa and immigration services with verified, licensed immigration agents and lawyers. We operate as a platform and directory — we do not provide immigration advice, legal advice, or immigration services ourselves. All professional services are provided by independent, licensed immigration agents and lawyers who list their practices on the Platform.
Our principal place of business is in Australia, and we are subject to the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) administered by the Office of the Australian Information Commissioner (OAIC).

2. What Personal Information We Collect
2.1 Information you provide directly
If you are a Migrant (Seeker): - Full name - Email address - Password (stored in encrypted/hashed form) - Country of current residence - Nationality or citizenship - Destination country interest (e.g., Australia, Canada) - Visa category interest (e.g., skilled, family, student, business) - Current immigration status - Preferred language - Profile photo (optional) - Booking details (consultation type, date, time, description of needs) - Reviews and ratings you submit - Messages sent through the Platform - Payment information (processed by Stripe — we do not store your credit card details) - Any other information you voluntarily provide through forms, surveys, or communications with us
If you are an Immigration Agent or Lawyer (“Agent”): - Full name and professional name - Email address - Password (stored in encrypted/hashed form) - Firm or company name - MARA registration number (Australia) or CICC licence number (Canada) - Professional credentials and registration certificates - Photo identification - Professional indemnity insurance details - Profile photo - Office location(s) and timezone - Bio and professional description - Visa specialisations and languages spoken - Consultation fees and service package pricing - Availability and booking preferences - Bank account or payment details for receiving payouts (processed by Stripe) - Any other information you provide in your profile or communications
If you contact us: - Name, email address, and any information you include in your inquiry
2.2 Information collected automatically
When you use the Platform, we automatically collect:
• Device information: Device type, operating system, browser type and version, screen resolution
• Log data: IP address, access times, pages viewed, referring URL, time spent on pages, clickstream data
• Location data: General geographic location derived from your IP address (we do not collect precise GPS location)
• Cookies and similar technologies: See Section 8 (Cookies) below
2.3 Information from third parties
• Social login providers: If you register or log in using Google or Facebook, we receive your name, email address, and profile photo from that provider, subject to your privacy settings with them.
• Payment processor (Stripe): We receive transaction confirmation, payment status, and limited payment information (e.g., last four digits of card, card type) — but not your full credit card number.
• Government registries: We verify Agent credentials against publicly available regulatory registers (MARA, CICC). This information is already publicly available.

3. How We Use Your Personal Information
We use your personal information for the following purposes:
3.1 Providing the Platform and services
• Creating and managing your account
• Displaying Agent profiles in the directory for Migrants to search and browse
• Facilitating consultation bookings between Migrants and Agents
• Processing payments and payouts
• Sending booking confirmations, reminders, and notifications
• Enabling reviews and ratings
• Facilitating messaging between Migrants and Agents (when available)
• Verifying Agent credentials against government registries
• Providing customer support
3.2 Improving the Platform
• Analysing usage patterns to improve functionality and user experience
• Conducting research and analytics (using aggregated, de-identified data where possible)
• Testing new features and services
• Monitoring and preventing technical issues
• Powering Platform features such as agent matching and search relevance (see Section 3.5 below)
3.3 Communication
• Sending transactional emails (booking confirmations, receipts, status updates)
• Sending service-related announcements (policy changes, feature updates, maintenance notices)
• Sending marketing communications, including our newsletter and blog updates (only with your consent — you can opt out at any time). All marketing communications comply with the Spam Act 2003 (Cth) and include a functional unsubscribe mechanism
3.5 Artificial intelligence and automated features
The Platform may use automated tools, algorithms, or artificial intelligence (AI) features to:
• Match Migrants with relevant Agents based on profile information, preferences, and search behaviour
• Rank and order search results in the agent directory
• Detect spam, fraudulent activity, or policy-violating content (including reviews)
• Personalise content recommendations (e.g., blog posts relevant to your visa interests)
Where automated features are used, they rely on information you have provided (such as destination country, visa category, language, and budget) and aggregated, de-identified usage data. We do not input your personal information into publicly available AI models, and your data is not used to train third-party AI systems.
If we introduce automated decision-making that has significant legal effects on you, we will notify you and provide an opportunity to request human review.
3.6 Safety and compliance
• Detecting and preventing fraud, abuse, and security incidents
• Enforcing our Terms and Conditions and Agent Agreement
• Complying with legal obligations, including responding to lawful requests from regulatory bodies and law enforcement
• Resolving disputes

4. Legal Basis for Processing
Under the Australian Privacy Principles, we collect and use your personal information where:
• You have consented to the collection and use (e.g., by creating an account and agreeing to this policy)
• The collection and use is reasonably necessary for our functions and activities (APP 3)
• The information is directly related to the purpose for which it was collected (APP 6)
• We are required or authorised by law to collect or disclose the information
If we receive unsolicited personal information (information we did not request), we will assess whether we could have collected it under APP 3. If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so (APP 4).
For users located in the European Economic Area (EEA) or United Kingdom, we process personal data under the following legal bases under the GDPR:
• Contract: Processing necessary to perform our contract with you (e.g., providing the Platform services you signed up for)
• Legitimate interests: Processing necessary for our legitimate business interests (e.g., fraud prevention, analytics, service improvement), provided these do not override your rights
• Consent: Where you have given explicit consent (e.g., marketing communications)
• Legal obligation: Processing necessary to comply with a legal obligation

5. How We Share Your Personal Information
We do not sell your personal information to third parties.
We share your personal information in the following circumstances:
5.1 Between Migrants and Agents
When a Migrant books a consultation with an Agent, we share relevant information between the parties to facilitate the service — including name, email address, booking details, and the description of needs provided by the Migrant. After a consultation is booked, the Agent may contact you directly in relation to that booking.
5.2 Service providers
We share personal information with third-party service providers who perform services on our behalf, including:
Provider Type Purpose Data Shared
Stripe Payment processing and payouts Payment information, transaction data
Hosting provider (e.g., Cloudways, WP Engine) Website hosting and infrastructure All data stored on the Platform
Email service provider (e.g., SendGrid, Mailchimp) Transactional and marketing emails Name, email address
Analytics (e.g., Google Analytics, Microsoft Clarity) Usage analytics and performance monitoring Device information, usage data (anonymised/pseudonymised where possible)
Customer support tools Managing support inquiries Name, email, inquiry content
CDN provider (e.g., Cloudflare) Content delivery and security IP address, request data
All service providers are contractually required to protect your information and only use it for the purposes for which it was disclosed.
5.3 Legal and regulatory
We may disclose personal information where required or permitted by law, including:
• To comply with a court order, subpoena, or other legal process
• To respond to requests from government agencies, regulators, or law enforcement (including MARA, CICC, and the OAIC)
• To enforce our Terms and Conditions or protect our rights, property, or safety
• To protect the rights, property, or safety of our users or the public
5.4 Business transfers
In the event of a merger, acquisition, reorganisation, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.
5.5 With your consent
We may share your information for other purposes with your explicit consent.

6. International Data Transfers
Emigration Guru is based in Australia. Your personal information may be transferred to, stored, and processed in countries other than Australia, including:
• United States — where some of our service providers are based (e.g., Stripe, Google Analytics, Cloudflare)
• Canada — where some of our Agent users and associated regulatory bodies are based
Where we transfer personal information to countries that may not have equivalent data protection laws to Australia, we take reasonable steps to ensure your information receives an adequate level of protection, including:
• Entering into data processing agreements with service providers that include appropriate safeguards
• Using service providers that participate in recognised data protection frameworks
• Relying on the contractual obligations of our service providers to protect your data
For users in the EEA/UK, international transfers are made pursuant to Standard Contractual Clauses (SCCs) approved by the European Commission or other appropriate safeguards under the GDPR.

7. Data Security
We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, and disclosure, including:
• Encryption: All data is transmitted using TLS/SSL encryption (HTTPS). Sensitive data is encrypted at rest.
• Password security: Passwords are stored using industry-standard hashing algorithms (not in plain text).
• Payment security: We do not store credit card information. All payment processing is handled by Stripe, which is PCI DSS Level 1 compliant.
• Access controls: Personal information is accessible only to authorised personnel on a need-to-know basis.
• Infrastructure security: Our hosting environment includes firewalls, DDoS protection, and regular security updates.
• Monitoring: We monitor for security incidents and have procedures in place to respond to data breaches.
While we take reasonable precautions, no method of electronic storage or transmission over the internet is 100% secure. We cannot guarantee absolute security of your information.
Data breach notification
In the event of a notifiable data breach (as defined under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act 1988), we will notify affected individuals and the OAIC as required by law.

8. Cookies and Tracking Technologies
What are cookies?
Cookies are small text files stored on your device when you visit a website. They help the website remember your preferences and improve your experience.
How we use cookies
Cookie Type Purpose Examples
Essential cookies Required for the Platform to function (login sessions, security, booking flow) Session cookies, CSRF tokens, authentication tokens
Functional cookies Remember your preferences and settings (language, timezone, search filters) Language preference, recently viewed agents
Analytics cookies Help us understand how users interact with the Platform Google Analytics, Microsoft Clarity
Marketing cookies Used to deliver relevant advertisements and measure campaign effectiveness Google Ads, Facebook Pixel (if applicable)
Managing cookies
You can control cookies through your browser settings:
• Block all cookies: You can set your browser to block all cookies, but this may prevent parts of the Platform from functioning correctly (e.g., you may not be able to log in or complete bookings).
• Block third-party cookies: You can block cookies from third parties while allowing first-party cookies.
• Delete cookies: You can delete cookies at any time through your browser settings.
You can also opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.
We will display a cookie consent banner when you first visit the Platform, allowing you to accept or manage your cookie preferences.

9. Your Rights
9.1 Under Australian Privacy Law (APPs)
Under the Australian Privacy Act 1988, you have the right to:
• Access your personal information held by us (APP 12)
• Request correction of inaccurate, out-of-date, incomplete, irrelevant, or misleading personal information (APP 13)
• Complain about a breach of the APPs (see Section 13 below)
• Opt out of receiving direct marketing communications at any time
• Request anonymity or use a pseudonym where it is practicable for us to deal with you without identifying you (APP 2) — noting this may limit your ability to use certain Platform features (e.g., booking consultations)
9.2 Under the GDPR (EEA/UK users)
If you are located in the European Economic Area or United Kingdom, you also have the following rights under the GDPR:
• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate personal data
• Right to erasure (“right to be forgotten”): Request deletion of your personal data in certain circumstances
• Right to restriction of processing: Request that we limit the processing of your personal data
• Right to data portability: Request your personal data in a structured, commonly used, machine-readable format
• Right to object: Object to processing based on legitimate interests, including profiling
• Right to withdraw consent: Where processing is based on consent, withdraw your consent at any time
9.3 Under PIPEDA (Canadian users)
If you are located in Canada, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA), including the right to access and correct your personal information, and to withdraw consent for the collection, use, or disclosure of your information.
9.4 How to exercise your rights
To exercise any of these rights, contact us at:
• Email: privacy@emigrationguru.com
• Mail: Emigration Guru Pty Ltd, [Insert Address], Australia
We will respond to your request within 30 days (or sooner where required by applicable law). We may need to verify your identity before processing your request.

10. Data Retention
We retain your personal information for as long as reasonably necessary to fulfil the purposes for which it was collected, including:
Data Category Retention Period
Active user accounts Retained while your account is active
Booking and transaction records 7 years from the date of the transaction (for tax, accounting, and legal compliance purposes)
Reviews Retained for the life of the Platform (reviews remain published unless removed by admin for policy violations)
Agent verification records Retained while the Agent’s profile is active, plus 7 years after account closure
Support inquiries 3 years from the date of resolution
Marketing consent records Retained until consent is withdrawn, plus a record of the withdrawal
Closed accounts Personal information is deleted or de-identified within 90 days of account closure, except where retention is required by law
When personal information is no longer needed, we securely delete or de-identify it.

11. Children’s Privacy
The Platform is not intended for use by children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information as soon as practicable.
If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@emigrationguru.com.

12. Third-Party Links
The Platform may contain links to third-party websites, services, or resources that are not operated by us (including government immigration websites, language testing providers, and Agent external websites). We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party website you visit.

13. Complaints
If you believe we have breached the Australian Privacy Principles or handled your personal information inappropriately, you may lodge a complaint with us:
• Email: admin@emigrationguru.com
We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. We will keep you informed of the progress and outcome of your complaint.
If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC):
• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Mail: GPO Box 5218, Sydney NSW 2001
For users in Canada, complaints may be directed to the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.
For users in the EEA/UK, complaints may be directed to your local data protection authority.

14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. When we make material changes, we will:
• Update the “Last updated” date at the top of this page
• Notify registered users by email
• Display a prominent notice on the Platform
Your continued use of the Platform after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically.

15. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us:
Emigration Guru Pty Ltd - Email: admin@emigrationguru.com - General inquiries: contact@emigrationguru.com - Website: www.emigrationguru.com