This policy is effective from 22.5.18. Smart Steps to Australia understands the significant importance of data protection and privacy and is fully committed to achieving compliance with the EU General Data Protection Regulation (GDPR.)
1.1 We are committed to safeguarding the privacy of visitors and service users of Smart Steps to Australia https://www.smartstepstoaustralia.com and https://www.movetoaustraliatoolkit.com/.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of visitors and service users of https://www.smartstepstoaustralia.com in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
1.5 In this policy, “we”, “us” and “our” refer to Karen Bleakley, Founder of https://www.smartstepstoaustralia.com and https://www.movetoaustraliatoolkit.com/ any staff involved in working on the website. For more information about us, see Section 13.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
- How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely [the proper administration of our website and business.
3.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name and email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business.
3.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business.
3.6 We may process [information that you post for publication on our website or through our services] (“publication data“). The publication data may be processed [for the purposes of enabling such publication and administering our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].
3.7 We may process [information contained in any inquiry you submit to us regarding goods and/or services] (“inquiry data“). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details and the purchase details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. No payment details are held or processed by Smart Steps to Australia. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.15 Please do not supply any other person’s personal data to us.
- Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 Financial transactions relating to our website and services are handled by our payment services providers, Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.paypal.com/au/webapps/mpp/ua/privacy-full.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 We have an office in Australia. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.3 The hosting facilities for our website are situated in USA, UK, Singapore and the Netherlands. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
5.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Analytics data associated with cookies, user identifiers or advertising identifiers will be retained for a maximum period of 50 months following collection.
(b) Email addresses and names will be retained as long as you remain subscribed to our email newsletter. Your details can be unsubscribed and removed at any time.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy [by email or through the private messaging system on our website.
- Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
- About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
- Cookies used by our service providers
11.4 You can also visit the following sites to read their privacy policies and how they track individuals across the web:
- Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
- Links to other sites
14. Our details
14.1 https://www.smartstepstoaustralia.com/ and https://www.movetoaustraliatoolkit.com/ is owned and operated by Karen Bleakley.
14.2 https://www.smartstepstoaustralia.com/ and https://www.movetoaustraliatoolkit.com/ are run in Australia under the ABN: 38443343036 Our registered address is PO Box 299, North Lakes Qld 4509.
14.3 You can contact us:
(a) by post, to the postal address given above;
(b) or by email, using firstname.lastname@example.org
General Website Terms and Conditions
ACCURACY: The information contained in this website is for general information purposes only. The information is provided by Karen Bleakley at Smart Steps to Australia and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, suitability, accuracy, reliability, or availability with respect to the website or the information, services, content, products or related graphics contained on the website or associated social media, for any purpose. Any reliance you place on such information is, therefore, strictly at your own risk.
In no event will we be liable for any loss or damage, including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website or its content.
AVAILABILITY: Every effort is made to keep the website running smoothly. However, Karen Bleakley at Smart Steps to Australia takes no responsibility for, and will not be liable for, the website or Premium content being temporarily unavailable due to technical issues beyond our control.
ONLINE CONTENT/ACCURACY: Karen Bleakley at Smart Steps to Australia attempts to be as accurate as possible in all online content. However, Karen Bleakley at Smart Steps to Australia does not warrant that the content on the website or in the Premium areas of the site themselves is accurate, complete, reliable, current, or error-free. If a product offered by Karen Bleakley at Smart Steps to Australia is identified as incorrect, or not as described, you should contact email@example.com providing full details.
LIMITATION OF LIABILITY: In no event will Karen Bleakley at Smart Steps to Australia be liable to you for any incidental, consequential or indirect damages arising from the use of this website, the associated Move to Australia Facebook group or through using any of the external services that are linked to on the website. Our liability to you for any cause whatsoever and regardless of the form of the action, will at all time be limited to the amount paid, if any, by you to us.
INTELLECTUAL PROPERTY: All intellectual property rights are owned by Karen Bleakley at Smart Steps to Australia. Those rights include, but are not limited to, copyright, database rights, design rights (whether registered or unregistered), trademarks (whether registered or unregistered) and other similar rights, wherever existing in the world, together with the right to apply for protection of the same. All other trademarks, logos, service marks, company or product names referenced on the website are the property of their respective owners.
EMAIL COMMUNICATION: When you visit Smart Steps to Australia or send e-mails to us, you are communicating with us electronically. You consent to receive communications from us electronically. We will communicate with you by e-mail or by posting notices on this site.
COPYRIGHT: All content included on this site, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations, and software, is the property of Karen Bleakley at Smart Steps to Australia or its content suppliers and protected by international copyright laws. The compilation of all content on this site is the exclusive property of Karen Bleakley at Smart Steps to Australia.
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DISPUTES: Any dispute relating in any way to your visit to Smart Steps to Australia’s website or to Premium products you purchase from Karen Bleakley at Smart Steps to Australia can be submitted to email@example.com in the first instance.
PREMIUM MEMBERSHIP TERMS AND CONDITIONS:
- By purchasing the Premium content on Smart Steps to Australia you agree to the membership terms and conditions below and any other term, conditions, disclaimers displayed elsewhere on www.smartstepstoaustralia.com
- You confirm the information that you have provided through site membership is true and correct.
- You understand that the information you provide through site membership is stored in the Smart Steps to Australia membership database which may be hosted by a contracted service provider to Smart Steps to Australia.
- By becoming a Smart Steps to Australia site member you consent to your personal information being used for the following purposes:
- to register your interest in similar Premium content as it becomes available.
- to identify any future events or business developments that may be of interest to you.
- Please note that if you opt-out to receive email updates as part of your site membership registration Karen Bleakley at Smart Steps to Australia may still contact you in relation to your purchase.
GUARANTEES: Karen Bleakley at Smart Steps to Australia / Move to Australia Toolkit does not guarantee eligibility to migrate to Australia. Purchasing the Premium content will not remove all work from the process of emigrating. Karen Bleakley at Smart Steps to Australia / Move to Australia Toolkit does not guarantee the outcome of your move to Australia will be successful. Any action you take as a result of reading Smart Steps to Australia or buying items from Move to Australia Toolkit, the Premium content and the Move to Australia Facebook group should be backed up by your own research and by engaging relevant, qualified professionals.
Information and facts provided in the Premium content will be reviewed and updated regularly. However, ad hoc changes will be made as and when Karen Bleakley at Smart Steps to Australia becomes aware of them.
CONTENT: Smart Steps to Australia is a website and blog © copyrighted by Karen Bleakley of Smart Steps to Australia. Move to Australia Toolkit is a website © copyrighted by Karen Bleakley of Smart Steps to Australia. No part of either website or downloads from the sites may be copied, or changed in any format, sold, or used in any way, online or offline under any circumstances without express permission from Karen Bleakley. You can contact firstname.lastname@example.org with any questions.
The site contains the following:
EDITORIAL: This is content written by Karen Bleakley. No compensation is received for editorial content published on the blog.
REVIEW POSTS: In the case of review posts, Karen Bleakley at Smart Steps to Australia may have been sent an item to review or given a service for free in return for writing an honest review or paid for her time to conduct a review. Karen Bleakley also sometimes reviews things she has purchased herself. All views are entirely personal opinions. Not all items that are sent for review will be included in the blog. Contact email@example.com to discuss review opportunities.
GUEST POSTS: These may be written by another blogger or business with a link back to their site. Guest posts must be relevant to the audience and be unique. Contact firstname.lastname@example.org to discuss guest post opportunities.
SPONSORED POSTS: This is content where Karen Bleakley at Smart Steps to Australia has received compensation in the form of payment, or a cash alternative, in return for writing a post, publishing a guest post or hosting a competition. Only relevant sponsored content is considered, and only ‘no follow’ links are used in this instance in line with Google requirements. Sponsored posts are identified as ‘sponsored’ or ‘in collaboration with’ in the post.
CONSUMER GUARANTEES: Premium content on Smart Steps to Australia or the Move to Australia Toolkit website is delivered as per the outline on the sales page. Content is delivered via a secure membership system. If you have any queries, questions, complaints or compliments about the content please email email@example.com.
RETURNS POLICY: As content is digital, no ‘returns’ can be given, as such. There are no refunds given for products charged with a one-off price. When you buy items from the Move to Australia Toolkit with a one-off price, you receive lifetime access to that item including any future updates that are made to it.
Migration Mastermind members on a recurring subscription have seven days to request a refund on their first payment. Please contact firstname.lastname@example.org. Provide your reason for requesting a refund and confirm your PayPal email address. Refunds will be made within 30 days of receipt of your request. The Migration Mastermind membership is on a rolling monthly or annual contract. If you cancel after the seven-day period, this will stop the next payment from being withdrawn and you will retain access to the content up until your payment period ends then you will no longer have access to the content.
OUTCOME: If you decide to purchase the Premium content, this has no connection to whether you are eligible for a visa or not. If you buy access and then are not invited to apply for a visa, or find out you are ineligible, no refund can be given unless it is within the 7-day period for Migration Mastermind members. Therefore, you are advised to ascertain as much as possible your eligibility by speaking to a registered migration agent before purchasing. Karen Bleakley at Smart Steps to Australia does not guarantee that you will obtain a visa or place any guarantee on the outcome of your intended move to Australia. Your results depend on a number of different factors, and expert advice should always be sought.
PROFESSIONAL ADVICE: The information contained in or made available through our sites (including but not limited to information contained on videos, comments, live hangouts, in-person events, in emails, in text files, on social media, in the Move to Australia Facebook group or in chats) cannot replace or substitute for the services of trained professionals in any field, including, but not limited to, financial, medical, or legal matters.
THIRD PARTIES: If/When you purchase from any referral links on the website or associated social media, your relationship is entirely with the business providing that product or service. You are advised to check their terms and conditions carefully before purchasing. However, Karen Bleakley at Smart Steps to Australia is interested in receiving feedback about the businesses we link to so would welcome feedback of any kind to email@example.com.
DAMAGES: Neither we nor our partners, or any of their affiliates, will be liable for any direct, indirect, consequential, special, exemplary or other damages that may result, including but not limited to economic loss, injury, illness or death. You alone are responsible and accountable for your decisions, actions and results in life, and by your use of the Sites, you agree not to attempt to hold us liable for any such decisions, actions or results, at any time, under any circumstance.
DISCLAIMER: Karen Bleakley at Smart Steps to Australia / Move to Australia Toolkit is not a registered migration agent or a financial adviser and therefore is unable to provide visa or financial advice.