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FIRST STEP MIGRATION – PRIVACY POLICY
Effective Date: 20/05/2025
(Company incorporated in England & Wales, No. 16535072)
Registered Office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: Admin@firststepmigration.co.uk
Telephone: +447352400212

INTRODUCTION
First Step Migration ("FSM", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our services, website, or communicate with us.
We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. DATA CONTROLLER
First Step Migration
Registered Office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: Admin@firststepmigration.co.uk
Telephone: +447352400212

2. PERSONAL DATA WE COLLECT
We collect a comprehensive range of personal data requisite for the provision of our immigration and ancillary services, including but not limited to: identity data (full name, date of birth, nationality), contact data (email, telephone, postal address), financial data (payment and banking details), immigration data (passport particulars, visa history, eligibility assessments), health and disability information (where applicable), employment and educational history, criminal convictions and background checks (where relevant), and other sensitive or special category data as necessitated by the service provided.

3. HOW WE COLLECT YOUR DATA
We obtain personal data directly from you and may request additional information or documentation as necessary to accommodate your individual circumstances. The precise nature and extent of data collected varies according to the personalised Services engaged.
FSM’s role is primarily to facilitate connections between clients and a network of professional service providers, and in the course of such facilitation, certain data may be shared with third parties for the purpose of progressing your matter. While FSM endeavours to ensure that all introduced service providers are reputable and professional, the ultimate responsibility for the delivery and quality of services rests with those third parties.

4. PURPOSES AND LEGAL BASIS FOR PROCESSING
We process your personal data to:

• Provide and manage immigration services and advice

• Assess eligibility and prepare applications

• Communicate regarding your case and our services

• Process payments and manage financial transactions

• Comply with legal and regulatory obligations

• Improve our services and develop AI technologies

• Send marketing communications where you have consented

Our legal bases include contract performance, compliance with legal obligations, legitimate interests, and your consent where applicable.

5. SHARING YOUR DATA
We may share your personal data with:

• Introduced Service Providers for case progression

• IT and service providers supporting our operations

• Government and regulatory authorities as required by law

• Legal and professional advisers

FSM acts as a coordinating hub, introducing clients to external service providers who are responsible for the substantive delivery of services. While we take reasonable steps to connect you with reputable and professional vendors, FSM cannot guarantee or accept liability for the capacity, performance, or outcomes of any third-party provider. Our involvement is limited to facilitating introductions and supporting the process administratively, and we act in good faith to ensure a smooth experience for all parties.

We may outsource or subcontract certain aspects of our services to third parties, particularly during initial phases when FSM acts as a coordinating hub. Such subcontracting may be on a no win no fee or other commercial terms to ensure effective case progression. All third parties must comply with applicable data protection laws and safeguard your data.

6. INTERNATIONAL TRANSFERS
Your data may be transferred outside the UK only where adequate protections are in place, such as adequacy decisions or standard contractual clauses approved by the UK Information Commissioner’s Office.

7. DATA RETENTION
We retain your personal data only as long as necessary to fulfil the purposes outlined, including legal, regulatory, and contractual requirements. Typically, client files are retained for a minimum of seven (7) years after case conclusion.

8. DATA SECURITY
We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, or misuse, including encryption, access controls, and staff training.

9. YOUR RIGHTS
Under UK GDPR, you have the right to:

• Access your personal data

• Request correction of inaccurate data

• Request erasure in certain circumstances

• Restrict or object to processing

• Data portability

• Withdraw consent where processing is based on consent

• Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise your rights, please contact us at Admin@firststepmigration.co.uk.

10. COOKIES
Our website uses cookies to enhance your experience. You can manage cookie preferences via your browser settings. For more information, see our Cookie Policy [link if available].

11. FEES, CHARGES & REFUNDS
Fees, charges, refunds, withdrawal fees, and cancellation rights are governed by our Terms and Conditions. Please refer to the Terms for full details.

12. COMPLAINTS AND DISPUTE RESOLUTION
Complaints must be submitted in writing with evidentiary support. FSM will acknowledge within five business days and adjudicate within twenty-eight. Unresolved disputes proceed to mediation in London prior to litigation.

13. CLIENT COMMUNICATION
Due to the volume of Clients, FSM provides general updates via email or written communication. Specific enquiries should be sent by email. Excessive or repetitive telephone communications may incur reasonable charges as per Terms.

14. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. Significant changes will be notified by posting the updated policy on our website with a revised effective date. Continued use of our services after changes constitutes acceptance of the updated policy.

15. CONTACT US
If you have any questions about this Privacy Policy or how we handle your personal data, please contact:
Email: Admin@firststepmigration.co.uk
Telephone: +447352400212
Address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ