Privacy Policy
Last updated: 2nd February 2024
Welcome to Yeste Group’s privacy policy.
Yeste Global Limited (collectively referred to as “we”, “us” or “our”) is committed to protecting and respecting your privacy. This policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our services. This policy also tells you about your privacy rights and how the law protects you.
So, if you’re looking for more information on how we keep your information safe and how we collect, store, use and share your personal data, this is the right place for you!
1.1 Purpose of this privacy policy
This privacy policy aims to give you information on how Yeste Group collects and processes your personal data through your use of our website or when you interact with us by any other means, including any data you may provide through the website or over the phone, WhatsApp or social media when you apply for our services, register with us, fill out our forms, make an enquiry or provide feedback.
This website is not intended for children and, although we do not knowingly collect data directly from children, we may receive data about children for the purpose of the provision of the migration services, which will be collected from children’s parents or their legal guardians.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
1.2 Controller
Yeste Group is made up of different legal entities spread around the world, including Yeste Consulting Pty Ltd (Australia), Yeste Global Pty Ltd (Australia) and Yeste Global Limited (United Kingdom). This policy is issued on behalf of the Yeste Group. All the companies in the Yeste Group have decided that Yeste Consulting Pty Ltd is our global data controller (the one responsible and in charge of the data). So when we mention “Yeste Group”, “we”, “us” or “our” in this policy, we are referring to the relevant company in the Yeste Group responsible for processing your data.
1.3 Changes to this privacy policy
We may review this privacy policy from time to time and we will notify you of any changes by uploading the new version of it on our website. We will send you an e-mail or post an update notice on our website or applications so that you become aware of the updated version of this policy. The “Last updated” date at the top of this policy will also be adjusted accordingly.
You are advised to review this privacy policy periodically for any changes. Changes to this policy are effective when they are posted on our website and/or applications.
1.4 Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.5 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you (or your family members, depending on the services for which you apply) which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, place of birth and gender.
- Professional Data includes employment history, education history and details about your income.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or out applications.
- Profile Data includes your username and password, applications made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Personal Data including general health information and immunisation history, criminal records checks and professional registrations (to the extent these are necessary for the provision of our services to you).
We also collect, use and share Aggregated Data such as statistical or demographic data for industry and market analysis, our marketing and advertising strategy or for any other business purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Professional, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- create an account on our website;
- subscribe to our service or publications;
- register and/or attend our events, conferences or webinars;
- request marketing to be sent to you; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below
Technical Data from the following parties:
- analytics providers such as Google; and
- search information providers.
Identity and Contact Data from publicly available sources:
- Facebook, Instagram, Linkedin, You Tube, Google search, etc.
We will only use your personal data when the law allows us to. Most commonly, we will use it in the following circumstances:
- Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we are about to enter into or have entered into with you.
- Necessary for the purposes of legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This may include responding to enquiries from you or third parties, optimising our website, applications and the overall user experience, informing you about our services/ products and ensuring that our operations are conducted in an appropriate and efficient manner. Ahead of processing your personal data for our legitimate interests, we consider and balance any potential impact on you (both positive and negative) and your rights. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your data to a regulatory body or law enforcement agency.
- Consent. In some circumstances, we may ask for your consent to process your information in a particular way (for example, we will get your consent before sending you direct marketing communications via email or text message, or any third party marketing. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new customer/ candidate |
(a) Identity (b) Professional (c) Contact (d) Special Categories |
Performance of a contract with you |
|
To process and deliver your application including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Professional (c) Contact (d) Financial (e) Transaction (f) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, services, marketing, customer experience |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about services/ jobs that may be of interest to you |
(a) Identity (b) Professional (c) Contact (d) Technical (e) Usage (f) Profile (g) Marketing and Communications |
Necessary for our legitimate interests (to develop our services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Professional, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
We may send you marketing communications from time to time about our new products and offers, provided that we obtain your consent to do so. If you no longer wish to receive marketing messages from us, you have the right to opt-out at any time by following the instructions in the “Opting-out” section below.
If you have already purchased goods or services from us, we may send you electronic marketing communications about products we feel may interest you (based on your prior experience with us) if you have not opted out from that marketing messages.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service experience or other transactions with us.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy in place from time to time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
- Internal Third Parties:
- Other companies in the Yeste Group, which includes Yeste Consulting Pty Ltd (Australian Migration Consultancy), Yeste Global Pty Ltd (Australian recruitment consultancy) and Yeste Global Limited (UK company).
- External Third Parties:
- Service providers based India, Malaysia and the Philippines who provide IT, marketing and back-office administration services (i.e. Leap – Migration Manager Program, Zoho CRM – back-office services, others).
- Business partners (i.e. employment recruitment agencies in the United Kingdom and Australia).
- HM Revenue & Customs, regulators and other authorities based in Australia and/or the United Kingdom who may require reporting of processing activities in certain circumstances.
- Migration Authorities, Immigration, Travel agencies, Professional registration authorities, Skill assessment authorities and Insurance companies.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Yeste Group is a company operating globally. Therefore, personal information of individuals who visit our websites and/or who use our services or otherwise interact with us may be transferred and accessed from around the world, such as from countries where Yeste Group and our service providers operate. This includes mainly transfers from Yeste Group’s companies located in Australia and the United Kingdom to our service providers in India, the Philippines and Malaysia.
Whenever we transfer your personal data outside of your jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the United Kingdom which give personal data the same protection it has in the UK (i.e. EU Standard Contractual Clauses, together with the UK Addendum).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
- Request access (“data subject access request”) – you have the right to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction – you have the right to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure (“right to be forgotten”) – you have the right to ask us to delete or remove the personal data we hold about you from our records. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons – for example, where we are legally obligated to keep the information or if it is impossible or unproportionate for us to erase the data. In this case, we won’t delete it but we will only keep it for as long as it is needed and we have time limits on our data systems.
- Object to processing – you have the right to object to processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you feel such processing impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing – you have the right to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer – you have the right to ask us to transfer the personal data we hold about you, either to you or a third party you have chosen, in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time (where we are relying on consent to process your personal data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will advise you if this is the case at the time you withdraw your consent.
- Object to automated processing, including profiling – in some circumstances you can ask us not to reach decisions that produce legal or similarly significant effects on you using automated decision-making, including profiling. Note, however, that the use of algorithms or machine learning techniques in ways that don’t have significant privacy implications on you is unlikely to render you with the right to object such automated processing.
If you wish to exercise any of the rights set out above, please contact us on the contact details set out below.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us at mail@yeste.com.au.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) or to any other data protection supervisory authority in your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or such other supervisory authority, so please contact us in the first instance should you feel unsatisfied with our treatment of your personal data.