FIRST STEP MIGRATION – TERMS AND CONDITIONS
(Company incorporated in England & Wales, No. 16535072)
Hereinafter “First Step Migration”, “FSM”, “we”, “us” or “our”

1. DEFINITIONS & INTERPRETATION
1.1 “Ancillary Channels” denotes any telephonic, electronic, digital, physical or other medium by which the Client may communicate with FSM.
1.2 “Applicable Law” includes, without limitation, the Data Protection Act 2018, the UK GDPR, the Consumer Rights Act 2015 and all superseding enactments or common-law principles extant in England and Wales.
1.3 “Introduced Service Provider” signifies any third-party, natural or juristic, to whom the Client’s particulars are transmitted or introduced by FSM for the procurement of specialist assistance.
1.4 “Services” encompasses all outreach, promotional, eligibility triage, documentary collation, advisory, scheduling, or introduction facilities offered by FSM, whether gratuitous or remunerated, including but not limited to immigration, benefits claims, mobility support, and allied services. The nature and scope of the Services may necessitate the collection of diverse categories and volumes of personal data contingent upon the Client’s individual circumstances and the particular service engaged.
1.5 “Client” means any individual who engages FSM for Services.

2. CONTRACTUAL ASSENT
2.1 By accessing or using the FSM website, Services or Ancillary Channels, you irrevocably agree to be bound by these Terms, our Privacy Notice and any contemporaneous policies, all of which shall be read pari materia.
2.2 The Client warrants that he or she is a natural person aged not less than eighteen (18) years and possesses full capacity to contract.
2.3 These Terms and any related policies may be updated from time to time to reflect operational, legal, or technological developments. By continuing to use FSM’s website, Services, or Ancillary Channels after such updates, you agree to be bound by the revised Terms. FSM commits that no changes will be made that are detrimental to Clients unless required by law or regulatory authority, or unless such changes are reasonably intended to improve the overall quality, efficiency, or security of the Services, balancing any potential impact on Clients.

3. NATURE & DELIMITATION OF FSM’S UNDERTAKING
3.1 FSM is not a firm of solicitors, an OISC-regulated immigration adviser, a fiduciary, trustee, financial institution, insurer or investment professional, nor does it purport to be any such entity.
3.2 FSM’s mandate is strictly circumscribed to:
(a) public-facing promotional and informational outreach;
(b) preliminary, non-binding eligibility triage predicated exclusively upon Client-supplied data;
(c) receipt, digitisation, storage and orderly collation of documents;
(d) onward transmission of the foregoing to an Introduced Service Provider; and
(e) ancillary liaison and scheduling.
3.3 No template, statement or representation—oral, written or digital—emanating from FSM shall constitute legal, tax, medical, investment or other regulated advice. The Client must obtain such advice from duly qualified professionals.
3.4 Regulated Services and Referrals
Where the Services requested by the Client require the involvement of a regulated provider (such as a solicitor, OISC-regulated immigration adviser, or other professional subject to statutory regulation), FSM shall exercise reasonable due diligence to introduce or refer the Client to an appropriately regulated third party to perform those Services. FSM is not itself a regulated entity for the purposes of providing legal, immigration, or other regulated advice or representation at this time, but may seek to obtain such regulation in the future. FSM’s role in such circumstances is strictly limited to facilitating the introduction and does not extend to the provision of regulated services unless and until FSM becomes duly authorised and regulated to do so.
3.5 FSM may, at its sole discretion, consult solicitors, barristers or other advisers and undertake in-house research to contextualise or corroborate advice. Whilst FSM shall act with reasonable skill and care, it disclaims any warranty as to the accuracy or completeness of third-party advice and the ultimate outcome of a matter.
3.6 The Client acknowledges that FSM employs proprietary methodologies and emergent technologies, including artificial intelligence, which are commercially sensitive and confidential. Detailed disclosure of such processes is therefore precluded.
3.7 FSM typically conducts an initial appraisal and thereafter, where appropriate, requests further documentation to augment the Client’s prospects. Engagement may be limited to discrete stages, and additional work is subject to prior quotation and acceptance.
3.8 FSM may outsource or subcontract the performance of services to third parties as deemed necessary, especially during the initial stages of operation when FSM functions primarily as a hub coordinating multiple service providers. Such subcontracting may be offered on a no win no fee basis or other commercial terms to ensure that client cases are handled diligently and business continuity is maintained. FSM is committed to carrying out work on behalf of clients under all circumstances to meet its promises and obligations. Over time, FSM intends to progressively internalize these services and provide them directly in-house.
3.9 FSM reserves an unfettered right to subcontract or engage third parties as deemed expedient. Terms may be amended to reflect legislative or operational changes.
3.10 The Client further recognises that FSM’s innovative paradigm entails inherent uncertainties; successful outcomes are contingent upon the Client’s diligence and cooperation.
3.11 Intermediary Capacity and Third-Party Performance
FSM functions as a coordinating nexus only. It liaises with independent third parties to advance the Client’s objectives but affords no warranty—express or implied—that such third parties shall honour deadlines, milestones or service-level undertakings. FSM exercises commercially reasonable diligence in selecting reputable counterparties and shall act in the Client’s best interests; nevertheless, the novel nature of FSM’s model entails risks beyond its control which the Client expressly accepts. Subcontracting arrangements may include no win no fee or other terms designed to ensure effective case progression and fulfilment of FSM’s commitments.
3.12 FSM may engage any third party it deems necessary to ensure efficient process flow, acting at all times in what it reasonably perceives to be the collective best interests of all stakeholders.
3.13 CONNECTING HUB DISCLAIMER
FSM is only a connecting hub. We will do our best to connect you to reputable and professional vendors of services. We cannot, and will not, take any responsibility for their capacity, ability, or performance. We are merely a convenience tool and we ensure we do what we can, to the best of our ability, to ensure that everything goes smoothly. If something does go wrong, it is highly likely not due to FSM. Responsibility for the delivery and quality of services rests solely with the third-party providers to whom you are introduced.

4. REFERRAL REMUNERATION & COMMERCIAL TRANSPARENCY
4.1 The Client acknowledges that FSM may derive pecuniary benefit—by fee, commission or other emolument—from Introduced Service Providers.
4.2 Such remuneration shall not augment sums payable by the Client to the Introduced Service Provider unless expressly disclosed by that provider.

5. CLIENT COVENANTS & WARRANTIES
The Client irrevocably undertakes to:
(a) furnish information that is true, complete and not misleading;
(b) notify FSM promptly of any material change;
(c) supply documentation requested by FSM or an Introduced Service Provider in a timely manner;
(d) abstain from impersonation or submission of falsified material;
(e) indemnify FSM against all losses arising from breach of these covenants;
(f) refrain from excessive or vexatious communications;
(g) cooperate diligently, acknowledging that failure so to do may result in suspension of Services and fees levied for work performed. The Client acknowledges that delays in providing requested information or documentation may impact the case timeline and may result in additional fees.
(h) The Client acknowledges and consents that FSM may require the collection of an extensive array of personal data and documentation pertinent to the specific Services rendered. Depending upon the bespoke nature of the Services, FSM may request supplementary information or documentation beyond that initially provided, to ensure the efficacious delivery of its services.

6. SUBMISSION OF PASSPORTS & PERSONAL DETAILS
FSM does not require passports or similar identification at the outset. Such documentation may be uploaded to the designated portal or email address once the matter is live. Submission to FSM or the competent authority will, however, ultimately be indispensable to progress the case.

7. CLAIMS PREPARATION, SUBMISSION & RESPONSIBILITY
Where FSM harbours reservations regarding the veracity of a matter, it may decline to lodge a claim. Ordinarily, FSM refines or constructs claims for Client submission, providing guidance only. Verification of external documents is onerous; FSM would levy substantially higher fees to assume responsibility therefor. Unless unequivocally agreed otherwise, FSM bears no liability for actions the Client elects to take on the basis of FSM’s clarifications.

8. INVESTIGATION OF CONCERNS
If FSM has questions or concerns regarding the material provided by the Client, FSM may need to investigate these matters in its own time. FSM shall maintain strict confidentiality regarding such investigations and shall not disclose any details to third parties. In cases where fraudulent activity is suspected, FSM acknowledges that it cannot intervene in the natural course of events but reserves the right to conduct initial investigations to determine the validity of the concerns.

9. FEES, CHARGES & REFUNDS
9.1 All invoices are payable in advance and are non-refundable save as mandated by law.
9.2 Any discretionary refund shall in no event exceed the monies actually received for the specific Service.

9A. REFUND POLICY & GUARANTEE
FSM guarantees only the diligent provision of the Services described. Refunds are strictly confined to non-delivery, material misrepresentation, or unresolved service fault, and are subject to FSM’s complaints procedure.
Each case requires a reasonable processing period, typically between three (3) to six (6) months, to ensure thorough assessment, refinement, and submission aligned with current policies and comparable case outcomes. This timeline is necessary to maximise the prospect of success.
FSM uses artificial intelligence technology to build and manage cases efficiently and may offer a refund guarantee on cases that ultimately fail. Initial costs may be higher due to case complexity but are expected to decrease as efficiencies improve.
The refund guarantee applies solely to the initial payment for Services. FSM may, at its sole discretion, extend this to subsequent payments for additional services, but this is not guaranteed.
Refund Processing Time:
(a) The Agreement Period — time taken for FSM and Client to mutually agree on refund entitlement, varying by case complexity and evidence.
(b) The Processing Period — time for FSM to execute refund payment after agreement, not exceeding thirty (30) calendar days.

9B. CASE SUBMISSION, BATCH PROCESSING & WITHDRAWAL
FSM may aggregate cases for strategic submission. External contingencies may cause deferral for at least nine (9) months. Withdrawal pre-submission is subject to a retention schedule; post-submission refunds are unavailable except as required by law.

9C. CLIENT COMPLIANCE AND FEE OBLIGATIONS
9C.1 If, after onboarding, the Client refuses or fails to provide requested documents or information necessary for case progression, FSM reserves the right to charge the initial fee for non-compliance and any fees incurred to that point. Fees for partially or not yet performed services may also be charged at FSM’s discretion.
9C.2 These charges cover FSM’s time, resources, and operational costs expended relying on Client engagement.

9D. CANCELLATION RIGHTS AND MATERIAL WORK
9D.1 The statutory 14-day cancellation period is forfeited once FSM initiates material work, deemed to occur upon formal notification of case progression to substantive stages.
9D.2 From this point, the Client is liable for fees corresponding to work performed; cancellation does not entitle refund of fees already incurred.

9E. ADDITIONAL PROVISIONS
FSM reserves the right to investigate any alleged failure or shortfall before considering recompense. The burden of proof lies with the Client. FSM disclaims any warranty as to ultimate success; electronic communications are binding; invalid provisions are severable.

9F. FSM’S ONGOING ROLE
Upon referral, the relevant third-party service provider assumes sole responsibility for immigration services. FSM thereafter provides only consultative support and disclaims liability for acts or omissions of any third-party provider.

9G. WITHDRAWAL ADMIN FEE
If a Client wishes to withdraw their case at any stage, an administrative fee of £500 plus £100 per week from onboarding to withdrawal request date will be charged, covering FSM’s administrative and operational costs. This fee is payable prior to document release or formal withdrawal confirmation.

10. DATA PROTECTION
FSM acts as Data Controller of personal data provided, processing strictly for legitimate purposes and subject to UK GDPR and the Data Protection Act 2018.
Categories of personal data collected may include: 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.
Data is obtained directly from the Client and may include additional information or documentation as necessary. Legal bases for processing include contract performance, legal obligations, legitimate interests, and consent where applicable.
FSM may share personal data with Introduced Service Providers, IT and service providers, government and regulatory authorities as required by law, and legal or professional advisers. Subcontracting may be conducted on a no win no fee or other commercial terms to ensure effective case progression. All third parties must comply with data protection laws and safeguard personal data.
International transfers occur only with adequate protections such as adequacy decisions or standard contractual clauses approved by the UK Information Commissioner’s Office.
Data is retained only as long as necessary, typically a minimum of seven (7) years after case conclusion.
FSM implements appropriate technical and organisational measures to protect data against unauthorised access, loss, or misuse, including encryption, access controls, and staff training.
Clients have rights under UK GDPR including access, correction, erasure, restriction or objection to processing, data portability, withdrawal of consent, and the right to complain to the Information Commissioner’s Office. To exercise rights, contact Admin@firststepmigration.co.uk.

11. MARKETING COMMUNICATIONS & COOKIES
By using the website, the Client consents to FSM’s use of cookies to enhance experience. Cookie preferences can be managed via browser settings. See FSM’s Cookie Policy for details.
The Client consents to receiving lawful marketing communications from FSM, which may be opted out of at any time.

12. LIMITATION OF LIABILITY
12.1 Whilst FSM endeavours to deliver exemplary service, it offers no assurance regarding services beyond its control, including disruptions caused by weather, industrial action or other third-party acts.
12.2 FSM is not liable for damages arising from the Client’s access or inability to access the website; the Client bears all associated risks and costs.
12.3 Nothing herein limits liability for death, personal injury or fraud. FSM’s aggregate liability shall not exceed the fees paid for the relevant Service and excludes indirect or consequential loss.

13. ACCEPTABLE USE
The website shall not be utilised for unlawful, fraudulent or harmful purposes. Data supplied must be accurate.

14. FORCE MAJEURE
FSM shall not be liable for delay or non-performance attributable to events beyond its reasonable control, including acts of God, war, terrorism, epidemics, labour disputes, governmental edicts or cyber incidents.

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

16. INTELLECTUAL PROPERTY
All intellectual property rights vest exclusively in FSM or its licensors. No part of the website may be reproduced, retained or reutilised without FSM’s prior written consent.

17. CONTRACTUAL INFORMATION
No contract for the provision of any product or Service arises until FSM issues a confirmation email, whereupon the contract shall be deemed concluded in England and subject to English jurisdiction.

18. ENTIRE AGREEMENT; ASSIGNMENT; SEVERABILITY
These Terms constitute the entire agreement concerning website and Service use, superseding all prior arrangements. FSM may assign or subcontract its rights; the Client may not assign without consent. Should any clause be adjudged invalid, the remainder shall continue in full force.

19. GOVERNING LAW & JURISDICTION
These Terms and any dispute arising herefrom shall be governed by, and construed in accordance with, the laws of England and Wales and subject to the exclusive jurisdiction of its courts.

20. CONTACT DETAILS
First Step Migration
Registered Office: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Email: Admin@firststepmigration.co.uk
Telephone: +447352400212
For data protection enquiries or to exercise your rights under UK GDPR, please contact FSM at the above email address.

21. CLIENT COMMUNICATION AND CASE UPDATES
FSM acknowledges that all cases are subject to similar legal criteria and challenges, with variations arising primarily from individual personal circumstances. Consequently, updates provided to Clients will typically be general in nature, addressing developments in the legal framework, relevant news, and prevailing challenges that impact the broader client base.
Given the substantial number of Clients FSM serves, it is impracticable and economically unviable to conduct individual telephone updates on a monthly basis. FSM will therefore issue comprehensive updates at regular intervals, primarily via email or other written communication channels. Clients are encouraged to submit any specific enquiries or requests for clarification by email to Admin@firststepmigration.co.uk.
This communication protocol enables FSM to allocate resources efficiently, maintain consistent service quality, and prioritise substantive case progression. FSM reserves the right to apply reasonable charges for excessive or repetitive telephone communications that disrupt operational effectiveness.