Marketing Consent and E-Marketing Policy

Otto Migration Services Pty Ltd (ABN 83 644 319 504)

Last updated: May 2025

 

This Marketing Consent and E-Marketing Policy explains how Otto Migration Services Pty Ltd ("we", "us", "our") obtains, records, and manages consent for marketing communications, including emails, SMS messages, and telephone calls. We are committed to complying with the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth), and the Privacy Act 1988 (Cth), as well as meeting the expectations of the Australian Communications and Media Authority (ACMA).

1. Scope

This policy applies to all marketing communications sent to individuals by Otto Migration Services Pty Ltd through the following channels:

• Email
• SMS and instant messaging
• Telephone calls 

This policy applies whether communications are sent directly by us or on our behalf by third-party service providers or affiliates.

2. Types of Consent

2.1 Express Consent

Express consent is our preferred and primary basis for sending marketing communications. Express consent means you have clearly and actively indicated your agreement to receive marketing from us. Examples include:

• Ticking a clearly labelled opt-in box on a web form
• Submitting a request to receive our newsletter or updates
• Verbally agreeing during a consultation to receive follow-up marketing information

We do not use pre-ticked boxes or bundled consent forms that obscure what you are agreeing to. Your consent will always be specific to the type of communication and purpose.

2.2 Inferred Consent

In limited circumstances, we may infer consent where there is a current and established relationship between us and where the marketing is directly relevant to that relationship. For example, where you are an existing client who has recently engaged our migration services, we may contact you about related visa updates or renewal reminders.

We will not rely on inferred consent where:

• The relationship is unclear or has lapsed
• The marketing is unrelated to the service you originally engaged
• Consent was obtained through a one-off transaction such as a payment receipt or invoice

3. Consent Records

We maintain accurate records of all consents we obtain. For each consent, we record:

• The method by which consent was obtained (e.g. web form, verbal, email)
• The date and time of consent
• The terms and conditions that applied at the time of consent, including what the consent covered

These records are stored securely and are available for review by the ACMA upon request.

4. What Your Consent Covers

When you provide consent to receive marketing from us, we will clearly explain:

• What types of communications you will receive (e.g. newsletters, service updates, promotional offers)
• Who will send those communications (Otto Migration Services and any relevant partners)
• How long your consent will be used (generally no longer than 3 years unless renewed or refreshed)
• How you can withdraw your consent at any time

5. Marketing Practices We Follow

To ensure our marketing is consumer-friendly and legally compliant, we:

• Use express consent as our primary basis for e-marketing and telemarketing where the recipient is on the Do Not Call Register
• Include clear, easy-to-use unsubscribe facilities in every commercial electronic message we send
• Process unsubscribe requests as quickly as practicable and always within 5 business days
• Provide a universal unsubscribe option in every message, not just partial opt-outs
• Cease all telemarketing calls immediately if you indicate at any time that you wish to stop the call
• Remove your details from calling and messaging lists upon request
• Consider using a double opt-in process (such as a confirmation email) when collecting consent online

6. Practices We Never Use

In line with the ACMA Statement of Expectations, we do not:

• Place your contact details on marketing lists without your consent
• Use consent that is more than 3 months old unless renewed under agreed terms
• Require you to log in or provide personal information to unsubscribe
• Use pre-checked tick boxes on forms
• Use bundled consent that does not allow separate choices for separate purposes
• Use refer-a-friend arrangements to obtain consent on behalf of third parties
• Charge you to unsubscribe (other than the standard cost of an SMS where applicable)
• Re-contact you after an unsubscribe request to encourage you to re-subscribe, unless you have subsequently provided fresh consent to do so
• Continue sending messages after receiving an unsubscribe request on the basis that someone else may be using the email address or phone number

7. The Do Not Call Register

We respect Australia's Do Not Call Register. Before conducting any outbound telemarketing, we check our calling lists against the Register. We do not make telemarketing calls to numbers registered on the Do Not Call Register unless the registered number holder has given us express consent.

Register your number:  http://www.donotcall.gov.au

8. Third-Party and Affiliate Marketing

Where we engage third-party service providers or affiliates to conduct marketing or consent gathering on our behalf, we take responsibility for ensuring they comply with the Rules. We require all third parties to:

• Obtain and store consent records in a manner that meets ACMA requirements
• Provide us with access to those records upon request
• Comply with unsubscribe requests within the required timeframes

We do not assume that third parties will manage compliance without our oversight.

9. How to Withdraw Consent or Make a Complaint

You may withdraw your consent at any time by:

• Clicking the unsubscribe link in any marketing email or SMS we send you
• Emailing us at info@ottomigration.com with the subject line "Unsubscribe"
• Calling or writing to us directly

We will action your request as quickly as practicable and no later than 5 business days from receipt.

If you believe we have breached the Spam Act or Do Not Call Register Act, you may contact the ACMA:

Website:  http://www.acma.gov.au

Phone:  1300 850 115

10. Updates to This Policy

We review this policy regularly to ensure it reflects current legal requirements and ACMA guidance. Any updates will be posted on ottomigration.com with a revised effective date.