Privacy Policy

Effective Date: 15 Oct 2026

Operator: Tern Visa Pty Ltd ABN 63 690 495 991

Contact: support@ternvisa.com

1. Scope

This policy explains how we handle personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) across our website, apps, and services (Services).

2. What we collect

Identity: name, date of birth, nationality, passport details, photos, visa history

Contact: email, phone, addresses

Application data: forms, evidence, declarations, travel history, employment, education, finances, dependants

Sensitive information (with consent or where allowed): health checks, character records, biometrics required for visas

Account and usage: device, IP, logs, cookies, analytics, session recordings (recordings of how you move through our site and app, used to fix problems and improve the service)

Payments: card brand and last four digits, payment metadata from Stripe (we do not store full card numbers)

Support content: messages, uploads, feedback, recordings if you consent

3. How we collect it

We collect your information directly from you through forms, uploads, supporting documentation, and payments. We also collect information indirectly where you authorise or the law permits us to, including the Department of Home Affairs (e.g., VEVO), payment processors, and analytics or operational tools.

Where you provide information about a third party, including members of your family unit, you confirm to us that you are authorised to do so.

4. Why we use it

We use your information to:

• assess, prepare, submit, and manage your visa application(s)

• provide immigration assistance by engaging through our platform with a registered practitioner

• verify your identity to prevent fraud

• process payments and issue receipts

• operate, secure, and improve our services

• communicate with you about your matter and provide service updates

• provide relocation services, with your explicit consent, such as to connect you with Australian third-party providers for optional services such as banks, mobile providers, health insurers, utilities, and superannuation funds

• comply with the law and respond to lawful requests

• for marketing purposes, where you opt in or the law allows us to.

If you do not provide us with the requested information, we may be unable to supply our services to you.

5. Legal bases

We handle personal information as permitted by the APPs. For sensitive information we rely on your consent or other permitted situations under the Privacy Act 1988 (Cth).

If you are in the European Union, the United Kingdom or an EFTA state, the GDPR or UK GDPR also applies to your information. We rely on these legal bases:

• Preparing and submitting your application, taking payment, and communicating with you about it: to perform our contract with you.

• Health and character information (health declarations, criminal convictions and other character matters): this is needed for your visa application, which is a legal process in which you establish and exercise a legal claim. We rely on the GDPR condition for the establishment, exercise or defence of legal claims. We do not ask for your consent for this, and do not need it.

• Keeping the service secure, preventing fraud, fixing errors and improving the service: our legitimate interests.

• Measuring our advertising (the advertising platforms in section 6): our legitimate interests, and for cookies in your browser, your consent (see section 9).

• Analytics and session recordings: your consent (see section 9).

• Marketing emails: your consent or, where the law allows, our legitimate interest in telling you about similar services. You can unsubscribe at any time (section 10).

• Optional relocation services: your explicit consent (section 6).

• Meeting our legal obligations: legal obligation.

6. Disclosures

We may disclose your information to:

• the Australian legal practitioner engaged through Tern

• the Department of Home Affairs and related bodies, for submission and checks

• our payment processor, to take payments and verify them

• service providers who host, process or deliver the service for us, such as cloud hosting, email and SMS, support, scheduling and meeting tools, error monitoring and analytics

• a review platform, which receives your name, email address and a reference so it can invite you to review Tern

• advertising platforms, as described below

• professional advisers, insurers, law enforcement or regulators, where required.

Advertising platforms. To measure our ads, we send advertising platforms your contact and identity details (name, email, phone, date of birth and location) in scrambled (hashed) form, plus your IP address, browser identifiers, and information about your activity on our site, such as a purchase. They never receive your documents or details of your visa application. Browser cookie controls (section 9) apply to the part collected in your browser.

We prepare and submit your application ourselves. We never hand it to another business to prepare or submit for us.

Apart from the service providers that run our service for us under contract, we share your visa-related information only with your consent, where you instruct us to (for example, to submit your application), or where the law requires it.

With your explicit consent, we may share limited information with Australian third-party providers that you select for optional relocation services. Optional relocation service providers include, but are not limited to, banks, phone or mobile providers, health insurers, utility companies or super funds. We will tell you what will be shared and with whom. You can withdraw consent at any time.

When we direct you to any third-party site, you acknowledge that we are not collecting your personal information. You should refer to the third party providers' privacy notices and policies available through their website(s).

7. Overseas disclosure

We use Amazon Web Services (AWS) as our cloud provider. Your application data, uploaded documents and our database are stored in Australia.

Some of the service providers we use to run our services are located overseas, mainly in the United States and countries of the European Union, and may hold personal information there. AI processing may also take place in other countries where AWS operates (section 8).

We take reasonable steps to ensure this information is handled consistent with the Australian Privacy Principles.

If you are in the EU or UK, we collect your information from you directly in Australia. Where our service providers outside the EU or UK hold it, we rely on standard contractual clauses or another safeguard the law recognises.

8. Automated decisions and AI

An Australian immigration lawyer writes every rule. The software applies it to your answers and documents, and has no view of its own. The Department of Home Affairs decides your visa.

Some decisions are made automatically: the software applies the lawyer's rules to your answers and documents, without a person looking at your case first. The software also does things that feed into decisions made by people. This section lists the kinds of each, and the personal information involved.

Decisions made automatically under the lawyer's rules:

• Whether you can continue past a step or submit. An answer that means the application cannot succeed, a required document that is missing, or a document the checks flag as possibly altered or fabricated can each stop you. A person at Tern reviews any such block on request (contact support@ternvisa.com), and our staff can lift a block that was raised in error.

• Which plans are offered to you and the price, including add-ons, based on your answers (for example, children included, a conviction disclosed or a previous visa refusal), and whether you need a consultation with the lawyer before going further.

• On some visas (currently visitor and working holiday), whether the refund guarantee, and the on-time promise where the plan has one, still cover your application. If the checks find a problem and you choose to go ahead, we tell you before the application is submitted that the guarantee no longer covers it. On other visas, where your plan includes the refund guarantee, the lawyer makes this call, not an automatic rule.

You can ask for a person to review any automated decision described in this section, including one about the refund guarantee, give your view and contest it, by emailing support@ternvisa.com. A person at Tern always reviews on request.

Things the software does that feed decisions made by people:

• AI reads your documents, pulls out details such as names and dates, and sorts evidence into lawyer-defined categories. It checks each document against a lawyer-set standard: is it the right kind of document, does it show signs of alteration or fabrication, is it about the right person, and does it contradict itself. On visitor and working holiday applications, a flag you leave unresolved can mean the refund guarantee no longer covers your application.

• The software compares facts across documents and your answers. Where they disagree, it shows you the mismatch and asks which is correct, without deciding which source is right.

• The software completes your visa application from your own answers and documents, and we submit it. The Department decides the outcome.

• AI drafts statements from what you told us, which are your own account, not advice, and any draft remains yours to review and edit before you sign it.

Personal information these programs use: your identity and passport details, contact details, form answers (travel, employment, education, finances, family and relationship details), uploaded documents and the details read from them, and sensitive information: your health declarations and character declarations.

What AI never does: AI makes no eligibility decision, forms no view on whether evidence is enough, makes no prediction of your chances, and never gives advice. It does not decide the outcome. When the software blocks a step, sets a plan or flags a document, that is a rule the lawyer wrote in advance, applied automatically. All advice you see in your application is written by the lawyer. Where AI checks a document, it flags what the lawyer-set standard asks about and nothing more.

AI processing runs on Amazon Bedrock under our own AWS account, and may take place in AWS regions outside Australia, as described in section 7. Your information is not sent to public AI chatbots, and it is not used to train AI models for other companies.

9. Cookies and analytics

We use cookies for authentication, preferences, security, analytics, session recordings and advertising measurement. Session recordings never include payment card details. You can control cookies in your browser. If cookies are disabled, this may lead to technical issues with some of the core features we offer as part of our services.

If you are in the EU, UK or an EFTA state, we ask for your consent before using analytics cookies, session recordings or advertising cookies in your browser, and you can decline.

10. Direct marketing

If you have consented, we will utilise your personal information to send you marketing material. You can opt out at any time through our unsubscribe links or by contacting us directly.

11. Data retention

We will retain your personal information and data for your visa related matter, our operations, and to satisfy our legal obligations. Generally, we will not keep personal information, records or data for longer than six (6) years, unless required by law. After the necessary time period has passed, we will delete your personal information, records and data.

12. Security

To secure your personal information, we apply encryption in transit, access controls, audit logging, and least-privilege access, acknowledging no security method is risk-free. You must also keep your account details secure.

13. Your rights

You may request access to your personal information and request corrections if it is inaccurate, out-of-date, incomplete, or misleading. Contact us on support@ternvisa.com.

If you are in the EU, UK or an EFTA state, you also have the right to:

• request erasure of your personal information

• request restriction of our processing

• object to processing based on our legitimate interests (including advertising measurement), and to direct marketing at any time

• request data portability

• withdraw your consent at any time, without affecting processing before you withdrew it.

Email your request to support@ternvisa.com. We respond within one month.

14. Changes to this policy

From time to time, we may update this Policy. Where necessary or required by law, we will inform you of material changes to this Policy.

15. Complaints

If you have a complaint about this policy, email us on support@ternvisa.com. We will respond within 48 hours, though resolving a complaint can take longer. If we have not responded within 30 days, or you are not satisfied with our response, you may take it to the Office of the Australian Information Commissioner (OAIC). If you are in the EU or UK, you can also complain to the data protection authority where you live or work (in the UK, the Information Commissioner's Office).

Contact

Tern Visa Pty Ltd

Email: support@ternvisa.com