Migrate studies and migration  S.A.S as a company registered in Colombia and Services Links PTY LTD, as a company registered in Australia and commercial name Migrate, are responsible as legal entities for all data processing and personal information provided by all users who enter our website www.migrate-au.com or those users who use our digital media and social networks.

Our organization is governed by international standards such as the data protection guidelines (GDPR), the European Union and the Colombia legal of the “Law 1581 of 2012 that issued the General Regime of Protection of Personal Data, which, according to its article 1, has in order to ‘develop the constitutional right of all persons to to know, update and rectify the information that has been collected about them in databases or archives, and the other rights, freedoms and guarantees constitutional provisions referred to in Article 15 of the Political Constitution; and the right to information enshrined in Article 20 thereof in the Law 1581 of 2012‘.

We also adhere to the good practices of personal data processing of each country including Australia, Canada, New Zealand, Colombia, Mexico, Chile, Peru, Ecuador among other countries. Likewise, we are complying with the data security requirements of the different social networks and internet media that we manage such as Facebook Migrate, Correos Migrate, LinkedIn Migrate, YouTube Migrate and WhatsApp Migrate.

1.SCOPE

This Personal Data Protection Policy shall apply to all Databases and/or Files containing Personal Data that are processed by MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S., which is considered responsible for and/or in charge of the processing of Personal Data.

2. Controller identification responsible for the processing of personal data

Services Links PTY LTD . company domiciled in Level 1/150 Adelaide St. QLD 4000 Brisbane, Australia, identified with the Identification Number  ACN 128223825 

Email: info1@migrate-au.com 

Whatsapp:  +61449877735

3. DEFINITIONS

- Authorization: Prior, express and informed consent of the Holder to carry out the Processing of Personal Data.

- Privacy Notice: Verbal or written communication generated by the responsible, addressed to the Holder to treat his Personal Data, which informs you about the existence of the Treatment of information that will apply to you, the way to access the same and the purposes of the treatment that should give the data personal.

- Data Base: Organized set of Personal Data that is the object of Treatment.

- Personal Data: Any information linked or that can be associated with a or several determined or determinable natural persons.

- Sensitive Data: Information that affects the privacy of individuals or whose misuse may cause discrimination (racial or ethnic origin, orientation political, philosophical or religious convictions, relevance to unions or social organizations or human rights, health data, sexual life and biometrics).

- Holder of Personal Data: Natural or legal person, public or private, that by itself or in association with others, carries out the Data Processing Personal on behalf of the person responsible for the treatment. In the events in which the person responsible does not work as a Database Manager, he or she will be identified expressly who will be the Manager.

Person in charge of the treatment: Natural or legal person, public or private, that by itself or in association with others, decides on the Database and/or the Data processing.

Terms and Conditions: general framework in which the conditions for participants in commercial or related activities.

- Holder: Natural person whose Personal Data are subject to processing.

- Processing: Any operation or set of operations on Data Personal, such as collection, storage, use, circulation or suppression.

- Transfer: Data transfer takes place when the person responsible and/or in charge of the treatment of personal data, in Colombia, sends the information or personal data to a recipient Responsible for the treatment and is in or out of the country.

Transmission: Treatment of Personal Data that implies the communication of the same within or outside the territory of the Republic of Colombia when its purpose is to carry out a Treatment by the person in charge on behalf of the person responsible.

4. TREATMENT

Migrate Estudios y Migración SAS, acting as Responsible for the Processing of Personal Data, for the proper development of its commercial activities, as well as for the strengthening of its relationships with third parties, collects, stores, uses, circulates and deletes Personal Data corresponding to Natural persons with whom it has or has had a relationship, such as, without the enumeration implying limitation, workers and relatives of these, shareholders, consumers, clients, distributors, suppliers, creditors and debtors.

5. PURPOSE

Personal Data are processed by Migrate Estudios y Migración S.A.S with the following purposes:

5.1 Participation in different types of surveys through online registration or forms.
5.2 Filling of subscription requests, software orders and online services, or to facilitate the request for specific information that is required of us.
5.3 Make it easier for you to use our website.
5.4 Tailor the most relevant content to your interests.
5.5 Inform you of important news concerning Migrate Estudios y Migración S.A.S
5.6 Inform you about our new products or services, product updates, technical support issues, events, and special offers.
5.7 Promote products and services on our website and the websites of our business partners or partners.
5.8 Prevent and detect fraud or other illegal or prohibited activities.
5.9 Ensure the security and integrity of our Website.
5.10 As part of an ongoing sales process.
5.11 While technical support or consulting regarding a product is provided.
5. 12 To be part of the maintenance and modernization process of our products.

5. 13 To be part of automated means such as communication protocols.

RIGHTS OF THE HOLDERS OF PERSONAL DATA

Data processing in the personal field

People who enter the Migrate website and the aforementioned sites published on the internet will be aware of their own responsibility since they do so voluntarily and freely. Migrate collects information to provide Study Abroad and Qualified Migration services, that is why when Migrate receives Personal information from users through its internet means it undertakes to give private use of the information with processes that allow the ethical management of All the information provided, in no case will the information be delivered to third parties or used for illicit acts, therefore Migrate is committed to providing security and reliability of all data collected.

If for any reason the user believes that their information is not secure on our internet media, we appreciate communicating with us to give a personalized treatment of the situation and give priority to the protection of user data. You can contact us at info1@migrate-au.com

Natural persons whose Personal Data is processed by Migrate Estudios y Migración S.A.S., have the following rights, which they can exercise at any time:

6. Know the Personal Data on which MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S.

you are performing the Treatment. In the same way, the Holder can request at any time that their data be updated or rectified, for example, if they find that their data is partial, inaccurate, incomplete, fractioned, misleading, or those whose Treatment is expressly prohibited or not has been authorized.
6. Request proof of the authorization granted to MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. for the Treatment of your Personal Data.
6. Be informed by MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S., upon request, regarding the use that it has given to your Personal Data.
6. Submit complaints to the Superintendency of Industry and Commerce for violations of the provisions of the Law on Protection of Personal Data.
6. Request to MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. the deletion of your Personal Data and / or revoke the authorization granted for the Treatment thereof, by filing a claim, in accordance with the procedures established in numeral 11 of this Policy. However, the request for the deletion of the information and the revocation of the authorization will not proceed when the Holder of the information has a legal or contractual duty to remain in the Database and / or Files, nor while the relationship between the Owner and MIGRATE EDUCACIÓN Y MIGRACIÓN SAS, by virtue of which your data was collected.
6. Access your Personal Data subject to Treatment for free.

7. AREA RESPONSIBLE FOR THE IMPLEMENTATION AND OBSERVANCE OF THIS POLICY

Legal Matters MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. is in charge of the development, implementation, training and enforcement of this Policy. For this purpose, all officials who carry out the Processing of Personal Data in the different areas of Migrate Estudios y Migración SAS, are obliged to report these Data Bases to Legal Affairs and to immediately transfer all requests to it, complaints or claims received by the Personal Data Holders.

Legal Affairs has also been designated by MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. as an area responsible for the attention of requests, queries, complaints and claims before which the Holder of the information may exercise their rights to know, update, rectify and delete the data and revoke the authorization.

8. AUTHORIZATION

Exclusive use of Personal Information

Our organization uses the personal information of users interested in our services to:

• Deliver study and migration option quotes.
• Make enrollment in educational institutions.
• Carry out visa processes before the different governments.
• After-sales service and monitoring.
• Give news updates from different governments.
• Deliver invitations to immigration and study seminars.
• Exclusive Migrate Marketing and Advertising.

We carry out the security processes of user information with secure systems techniques that allow us to sort the information in our exclusive and confidential database of our company to guarantee the proper use of the information.

When you connect to the Migrate website to search for information, manage a form or send an email to Migrate, you are providing personal information for which the user is responsible. This information may include personal data such as your IP address, name and surname, physical address, email address, telephone number, and other information. By providing this information, you give your consent for your information to be managed and stored by Migrate.

We are not responsible for the uses made of the links we make to other websites. Each user will be responsible for entering new web pages found within the links in Migrate web.

MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. You must request prior, express and informed authorization from the Holders of the Personal Data on which you need to carry out the Treatment.

8. Prior authorization means that consent must be granted by the Holder, at the latest at the time of collection of Personal Data.
8. Express authorization means that the consent of the Holder must be explicit and concrete, open and non-specific authorizations are not valid. The Holder is required to express her willingness to authorize MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. carry out the Treatment of your Personal Data. This manifestation of the will of the Holder can be given through different mechanisms made available by MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S., such as:

• In writing, for example, by completing an authorization form such as that indicated in Annex 1.
• Orally, for example, in a telephone conversation or in a video conference.
• Through unequivocal behaviors that allow concluding that you granted your authorization, for example, through your express acceptance of the Terms and Conditions of an activity within which the authorization of the participants is required for the Treatment of their Personal Data.

IMPORTANT: In no case MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. will assimilate the Owner's silence to unequivocal conduct. Whatever the mechanism used by SAS, it is necessary that the authorization be kept in order to be consulted later.

• Informed Authorization means that, at the time of requesting the consent of the Holder, he must be clearly informed:
• The Personal Data that will be collected.
• The identification and contact details of the person in charge and the Person in Charge of Treatment.
• The specific purposes of the Treatment that is intended to be carried out, that is: how and for what the collection, use, and circulation of Personal Data will be done
• What are the rights you have as the Owner of Personal Data; For this purpose, see numeral 6 of this Policy.
• The optional nature of the answer to the questions that are asked, when these relate to sensitive data or the data of girls, boys and adolescents.

Veracity of Personal Data

The users of our internet sites undertake that the data provided to Migrate are correct, complete, exact and current, as well as to keep them duly updated.

As a User of the Migrate internet sites, you are solely responsible for the veracity and correctness of the data that you send to the site, exonerating Migrate from any responsibility in this regard.

Revocability

To assert your rights of access, rectification, cancellation, portability and opposition, you have to send an email to info1@migrate-au.com along with valid proof in law, such as a photocopy of the I.D. or the equivalent.

The exercise of your rights does not include any data that Migrate is obliged to keep for administrative, legal or security purposes.

9. SPECIAL PROVISIONS FOR THE TREATMENT OF PERSONAL DATA OF A SENSITIVE NATURE.

In accordance with the Personal Data Protection Law, data of a sensitive nature are those that affect privacy or whose improper use may generate discrimination, such as those related to:

• Racial or ethnic origin.
• Political orientation.
• Religious / philosophical convictions.
• Membership of trade unions, social organizations, human rights organizations or political parties.
• Health.
• Sex life.
• Biometric data (such as fingerprint, signature, and photo).

The Processing of Personal Data of a sensitive nature is prohibited by law, unless there is express, prior and informed authorization from the Holder, among other exceptions enshrined in Article 6 of Law 1581 of 2012.

In this case, in addition to meeting the requirements established for authorization, MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. shall:

• Inform the Holder that because it is sensitive data, she is not obliged to authorize its Treatment.
• Inform the Holder which of the data that will be processed are sensitive and the purpose of the Treatment.

IMPORTANT: No activity may be conditioned on the Owner providing sensitive Personal Data.

10. SPECIAL PROVISIONS FOR THE PROCESSING OF PERSONAL DATA OF CHILDREN, GIRLS AND ADOLESCENTS

According to the provisions of Article 7 of Law 1581 of 2012 and Article 12 of Decree 1377 of 2013, MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. It will only carry out the Treatment, that is, the collection, storage, use, circulation and / or deletion of Personal Data corresponding to children and adolescents, as long as this Treatment responds and respects the best interests of children and adolescents and ensure respect for their fundamental rights.

Once the above requirements have been met, MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. You must obtain the Authorization of the legal representative of the child or adolescent, after the minor's exercise of their right to be heard, an opinion that will be valued taking into account the maturity, autonomy and ability to understand the matter.

11 PROCEDURE FOR ATTENTION AND RESPONSE TO REQUESTS, CONSULTATIONS, COMPLAINTS AND CLAIMS OF THE HOLDERS OF PERSONAL DATA

The Holders of the Personal Data that are being collected, stored, used, put into circulation by MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S., may at any time exercise their rights to know, update, rectify and delete information and revoke the authorization.

For this purpose, the following procedure will be followed, in accordance with the Personal Data Protection Law:

11.1 ATTENTION AND RESPONSE TO REQUESTS AND INQUIRIES:

What does the procedure consist of?

The Holder or her successors in title may request MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S., through the means indicated below:

• Information about the Owner's Personal Data that are subject to Treatment.
• Request proof of the authorization granted to MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. for the Treatment of your Personal Data.
• Information regarding the use that has been given by MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. to your personal data.

Means enabled for the presentation of petitions and inquiries:

MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. has arranged the following means for the reception and attention of requests and inquiries, all of which allow us to keep proof of them:

• Communication addressed to MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. Legal Affairs, Carrera 15 # 93ª - 84 Office 513 of the city of Bogotá D.C in the city of Bogotá D.C. Australia: Level 1/150 Adelaide St Brisbane City. QLD. 4000. Australia.
• Request submitted to email: info1@migrate-au.com

Attention and response from MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S .:

Requests and inquiries will be answered within a maximum term of ten (10) business days from the date of receipt of the same. When it is not possible to attend to the request or query within said term, the interested party will be informed, stating the reasons for the delay and indicating that their request or query will be addressed, which in no case may exceed five (5) business days following the expiration of the first term.

11.2 ATTENTION AND RESPONSE TO COMPLAINTS AND CLAIMS:

What does the procedure consist of?

The Holder or her successors in title, may request THE COMPANY, through a complaint or claim presented through the channels indicated below:

• The correction or updating of the information.
• The deletion of your Personal Data or the revocation of the authorization granted for the Treatment thereof.
• That the alleged breach of any of the duties contained in the Personal Data Protection Law be remedied or corrected.

The request must contain the description of the facts that give rise to the complaint or claim, the address and contact information of the applicant, and must be accompanied by the documents that are to be asserted.

Means enabled for the presentation of complaints and claims:

MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. has arranged the following means for the reception and attention of complaints and claims, all of which allow us to keep proof of their presentation:

Communication addressed to MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. Carrera 15 # 93ª - 84 Office 513 of the city of Bogotá D.C in the city of Bogotá D.C. Australia: Level 1/150 Adelaide St Brisbane City. QLD. 4000. Australia
Request submitted to email: info1@migrate-au.com

Attention and response from MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S .:

If the complaint or claim is incomplete, MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. must require the interested party within five (5) days following receipt of the complaint or claim to remedy the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has withdrawn the complaint or claim.

In the event that the person who receives the complaint or claim is not competent to resolve it, they will send the Legal Affairs of MIGRATE EDUCACIÓN Y MIGRACIÓN SAS, within a maximum term of two (2) business days and inform the interested party of the situation.

Once the complaint or complete claim is received, a legend that says "claim in process" and the reason for it will be included in the Database, within a term not exceeding two (2) business days. Said legend shall be kept until the complaint or claim is decided.

The maximum term to attend to the complaint or claim will be fifteen (15) business days from the day following the date of receipt. When it is not possible to address the complaint or claim within said term, the interested party will be informed of the reasons for the delay and the date on which the complaint or claim will be addressed, which in no case may exceed eight (8) days following the expiration of the first term.

12.INFORMATION OBTAINED IN PASSIVE FORM

When the services contained within the MIGRATE EDUCACIÓN Y MIGRACIÓN SAS website are accessed or used, it may collect information passively through information management technologies, such as "cookies", through which it is collected. information about the hardware and software of the equipment, IP address, browser type, operating system, domain name, access time and the addresses of the websites of origin; Through the use of these tools, no personal data is collected directly from users. Information about the pages that the person visits most frequently on these websites will also be collected in order to know their browsing habits. However, the user of the SAS website has the possibility of configuring the operation of "cookies", according to the options of their internet browser.

13. SECURITY OF PERSONAL DATA

MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S., in strict application of the of Security in the Treatment of Personal Data, will provide the measures technical, human and administrative resources necessary to provide security to the records avoiding their adulteration, loss, consultation, use or access not allowed or fraudulent. The obligation and responsibility of SAS is limited to have the means for this purpose. MIGRATE EDUCACIÓN and MIGRACIÓN S.A.S. does not guarantee the total security of your information, nor does it be responsible for any consequences arising from technical failures or from the entry The data is transferred to the database or archive where the data is stored. Personal Data processed by MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. and its Managers. MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. will require the service providers it hires to adopt and comply with adequate technical, human and administrative measures to protecting Personal Data in relation to which such providers to act as Managers.

14. TRANSFER, TRANSMISSION, AND DISCLOSURE OF PERSONAL DATA

SAS may disclose to its related companies worldwide, the Data Personal on which it performs the treatment, for its use and Treatment according to this Personal Data Protection Policy.

Likewise, MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. may deliver the Personal Data to third parties not related to MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S. when:

- It is about contractors in execution of contracts for the development of activities of MIGRATE EDUCACIÓN Y MIGRACIÓN S.A.S.

- By transfer to any title of any business line with which it relates the information.

- To keep confidentiality regarding the treatment of personal data.

15. APPLICABLE LEGISLATION

This Personal Data Protection Policy, the Privacy Notice and the Authorization Form that is part of this Policy as Annex 1, are governed by the current legislation on protecting personal data referred to in Article 15 of the Political Constitution of Colombia, Law 1266 of 2008, Law 1581 of 2012, Decree 1377 of 2013, Decree 1727 of 2009 and other regulations that change, repeal or replace them.

16. VALIDITY

This Personal Data Protection Policy is in force since April 15 of 2020.

17.ACCEPTANCE AND CONSENT

Users of Migrate internet sites declare that they have been informed of the conditions on the protection of personal data, accept and consent to their treatment by Migrate in the manner and for the purposes indicated in this Privacy Policy.

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