Draft, legal counsel review required before publication
This document is a working draft prepared for review by qualified legal counsel in our governing jurisdiction. It is published on the site in good faith to give visitors visibility into how we intend to handle data, but the final wording, statutory references, and binding commitments must be confirmed by a privacy lawyer before they take legal effect. Items in square brackets are placeholders awaiting confirmation by the business or counsel.
The clients who use our services are often in situations where their safety depends on confidentiality. This policy is not a formality, it is a commitment that our operation's reputation and our clients' lives rest on. We do not have a separate "internal policy" that contradicts what is written here. What is written here is how we operate.
1. Who We Are
Move Now Group Pty Ltd [ACN to be confirmed by counsel] is a private company [registration jurisdiction to be confirmed] providing crisis relocation assistance, emergency travel documentation facilitation, private aviation brokerage, international money transfer services, cryptocurrency exchange facilitation, and equipment supply.
Our services are provided globally, with an emphasis on regions experiencing armed conflict, sanctions regimes, civil unrest, or severe humanitarian conditions. References in this policy to "we," "us," "our," or "Move Now Group" mean Move Now Group Pty Ltd.
For privacy-related enquiries, contact us at: support@movenowgroup.com
2. What We Collect
We collect only what is necessary to assess your situation and deliver the service you are requesting. We do not collect data speculatively, for marketing purposes, or for any purpose other than direct service delivery.
| Category | Examples | Why Collected |
|---|---|---|
| Identity | Full name, date of birth, nationality, passport details | Required for travel documents, aviation manifests, and identity verification |
| Contact | Phone number, WhatsApp/Signal/Telegram handle, email address | Communicating with you about your case, including emergencies |
| Location | Country currently located in, city, border crossing preference | Assessing logistical options and planning extraction or transit routes |
| Situation Details | Nature of threat, family composition, travel history, visa status | Determining which services are available and appropriate to your circumstances |
| Financial | Payment method, cryptocurrency wallet address (for USDT transactions), amount range | Processing payment and complying with our own internal financial record-keeping |
| Technical | IP address, browser type, referring URL | Basic server logging for security and abuse prevention, not used for profiling |
We do not collect biometric data, political opinions, religious beliefs, sexual orientation, or medical information unless you voluntarily provide it as context relevant to your situation (for example, describing a medical condition that affects transportation requirements). Even when provided, such information is used solely to better assist you and is subject to the same protections as all other data.
We do not purchase data from brokers, compile profiles from social media, or aggregate your information with any external sources.
3. How We Use Your Data
Your data is used for one purpose: helping you. More specifically:
- Assessing your situation. When you first contact us, we review the information you provide to understand your circumstances and determine what we can offer.
- Delivering the service. Depending on which service you engage us for, your information may be used to book aviation, liaise with document facilitators, arrange money transfers, or coordinate logistics on the ground.
- Communicating with you. We use your contact details to update you on progress, alert you to changes (flight times, border conditions), and respond to your questions.
- Internal records. We maintain encrypted internal records of completed engagements for our own operational continuity and financial compliance purposes. These are not accessible to any third party.
- Safety and fraud prevention. In rare cases, we may review information to identify and block fraudulent enquiries or attempts to abuse our services.
We do not use your data for automated decision-making that produces legal effects. Every assessment of a client's situation involves a human team member. We do not use your data to train any machine-learning model or AI system, including systems operated by third parties.
4. No Third-Party Sharing
We do not share your personal information with governments, law enforcement agencies, intelligence services, international organisations, sanctions authorities, or any database, including those operated by the United States (OFAC, FBI), the United Nations, the European Union, Australia (AUSTRAC, ASIO), or any other jurisdiction.
We recognise that many of our clients come from countries whose governments they are fleeing. Sharing client data with state actors would directly contradict the reason we exist. No government agency, domestic or foreign, has standing access to our systems or our records.
In the extremely limited circumstances where we must engage operational partners (for example, a ground transportation contractor or a document courier in a specific country), those partners:
- Receive only the minimum information necessary to complete their specific task.
- Are bound by confidentiality obligations at least as strict as those in this policy.
- Do not retain the information after the task is completed.
- Are never given your full profile, financial information, or the nature of your situation beyond what is operationally required.
If we are ever served with a valid legal compulsion order by an Australian court requiring disclosure of specific client data, we will:
- Immediately engage legal counsel to contest or narrow the scope of the order.
- Notify the affected client as soon as we are legally permitted to do so.
- Disclose only the precise data specified by the court order, nothing more.
We publish this process so that clients understand what would happen in the event we were ever compelled to act against our preferences. We will publicly disclose the number of legal compulsion orders received each calendar year in an annual transparency note, redacted of any identifying detail about affected clients.
5. Retention & Deletion
We retain your personal data for the minimum period necessary. The following schedule applies:
| Data Type | Retention Period |
|---|---|
| Enquiries that did not result in a service engagement | 90 days from last contact, then deleted |
| Active service engagements | Duration of service plus 30 days |
| Financial transaction records (internal) | 7 years, as required by Australian tax law (encrypted, access-controlled) |
| Technical server logs (IP address, timestamps) | 30 days, then purged automatically |
| Communications (encrypted messages, emails) | Deleted within 30 days of service completion unless you request otherwise |
You may request early deletion of any personal data we hold about you at any time. Subject to our legal record-keeping obligations (such as financial records required under the Corporations Act 2001 (Cth)), we will action deletion requests within 14 days and confirm completion in writing.
6. Security Measures
We operate under the assumption that our clients face adversaries with significant surveillance capabilities. Our security posture reflects this. The following measures are in place:
- Encryption in transit. All data transmitted to and from our systems uses TLS 1.3 or stronger. We do not accept connections over unencrypted protocols.
- Encryption at rest. Client records are stored using AES-256 encryption on servers located in jurisdictions chosen for their strong data protection laws and distance from conflict-zone authorities.
- Access control. Client information is accessible only to team members directly working on your case. All access is logged, time-limited, and reviewed periodically.
- Secure communications. We prefer end-to-end encrypted channels (Signal, WhatsApp, Telegram) for operational communication. Email is used for non-sensitive correspondence only.
- No cloud storage on major US platforms. We do not store client data on AWS, Google Cloud, Microsoft Azure, or similar platforms that are subject to US legal process. Our infrastructure is hosted on privacy-respecting European and Australian providers.
- Limited analytics. We use Google Analytics 4 (GA4) and Google Ads conversion tracking for aggregate, IP-anonymised measurement of how visitors find and use this site. We do not use Facebook Pixel, advertising retargeting cookies, behavioural profiling, or any tool that builds an individual visitor profile. GA4 is configured to anonymise IP addresses and we do not link analytics events to identifying client records. We use Microsoft Clarity for session replay strictly to debug usability issues; Clarity automatically masks input field contents, and we further mask sensitive form fields explicitly.
We commit to notifying affected clients within 72 hours of discovering any breach that could materially affect their personal data, consistent with applicable obligations including the Privacy Act 1988 (Cth) and the Notifiable Data Breaches scheme where relevant.
7. Cookies
This website uses cookies for limited purposes. We do not use cookies for advertising retargeting or behavioural profiling. Specifically:
- Session and form state. Used to maintain your session state when using our contact forms and to capture UTM parameters once per session so we can attribute leads. Expires when you close your browser unless otherwise stated.
- Language preference. Stored in localStorage so the site loads in your preferred language on subsequent visits. Contains no personal information.
- Translation cookie (googtrans). Set when you change language via the dropdown. Used by Google Translate to render the selected language. Contains the language code only.
- Emergency bar state. If you dismiss the emergency bar, a flag records that preference for the session.
- Analytics cookies. Google Analytics 4 sets cookies (_ga, _ga_*) for measurement. We have enabled IP anonymisation and disabled advertising features.
If you disable all cookies in your browser, the site will continue to function for browsing. Forms will still submit; analytics events will simply not fire.
You can review and delete cookies at any time using your browser's settings.
8. Your Rights
Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), you have the following rights with respect to your personal data:
- Access. You may request a copy of the personal information we hold about you. We will respond within 30 days.
- Correction. If any information we hold is inaccurate, incomplete, or out of date, you may ask us to correct it. We will action this promptly.
- Deletion. You may request that we delete your personal data. We will do so except where retention is required by law (for example, financial records). Deletion requests are confirmed in writing.
- Portability. You may request your data in a structured, commonly used format if you wish to transfer it elsewhere.
- Objection. You may object to any specific use of your data. We will either cease that use or explain why we cannot.
- Withdrawal of consent. If you provided consent for a specific use of your data, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, contact us at support@movenowgroup.com. We do not require you to use any specific form. A plain-language email describing your request is sufficient. We do not charge a fee for any privacy request.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
9. International Data Transfers
The nature of our work means that limited personal information must sometimes move across borders, for example, a name and passport number shared with a ground partner in Turkey to arrange transport. When this occurs, we take the following steps:
- We assess the privacy and security laws of the recipient country before any transfer.
- We transfer only the minimum data necessary for the specific task.
- We obtain contractual commitments from recipients to protect the data at least to the standard of this policy.
- We do not transfer data to countries where we believe it would be accessible to authorities hostile to our clients' interests.
We do not transfer your data to any foreign government, embassy, consular service, international sanctions body, or law enforcement agency under any circumstances.
10. Minors
Our services are available to individuals of all ages, including children in crisis situations, but contracts and service agreements must be entered into by an adult (18 years or older) on behalf of any minor. Where we collect information about a minor (for example, a child included in a family relocation), we apply the same protections as for adult clients, and we take particular care with that information given the heightened vulnerability of children in conflict situations.
We do not knowingly collect personal information from children for any purpose other than facilitating their safe movement as part of a family or guardian's service engagement.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our operations, applicable law, or best practice. When we do, we will update the "Last Updated" date at the top of the page. We will not make material changes that reduce your protections without providing clear notice on this page.
If you have an active service engagement with us at the time of a material change, we will contact you directly to inform you of the change and provide an opportunity to object or withdraw.
Your continued use of our services after a policy update constitutes acceptance of the revised terms.
12. Contact for Privacy Requests
All privacy-related correspondence, access requests, deletion requests, corrections, complaints, or general questions, should be directed to:
Privacy Officer
Move Now Group Pty Ltd
[Registered address to be confirmed by counsel]
Email: support@movenowgroup.com
Phone (24/7): +1 (423) 766-9105 · WhatsApp: +1 (423) 766-9105
General enquiries: Contact page, or reach us via Signal, WhatsApp, or Telegram for encrypted communication.
We aim to acknowledge all privacy requests within 2 business days and resolve them within 30 days. Complex requests involving retrieval of archived records may take longer; we will inform you of any delay and provide a revised timeline.