Terms of Service & Privacy Policy

1. About Songline

Songline is operated by Dyna Solutions Pty Ltd (ABN 61 622 540 050), trading as Songline Journey, a technology company based in Australia. We provide a software platform that enables registered migration agencies to manage client journeys, track visa application milestones, store documents, and communicate with applicants through a mobile and web application.

These Terms of Service govern your use of the Songline platform, including the mobile app, web app (PWA), and any related services (collectively, "the Service").

1.1 Definitions

In these Terms, the following words have the meanings set out below:

• Agency — a registered migration agency that subscribes to Songline to manage their clients;
• Applicant — a visa applicant who accesses Songline via the mobile or web app by invitation from their Agency;
• Agent — a staff member of an Agency who uses the Songline admin panel with standard permissions (view and manage assigned clients);
• Admin Agent — a staff member of an Agency with elevated admin panel permissions, including managing other agents, agency settings, and all clients;
• Super Admin — a Songline Journey administrator with platform-wide access, responsible for onboarding agencies and managing platform settings;
• Sunny — the AI assistant built into the Songline app (see Section 6);
• We / Us / Songline — Songline Journey.

2. Acceptance of Terms

By accessing or using Songline, you confirm that you:

• Are at least 18 years of age;
• Have read, understood, and agree to be bound by these Terms;
• Have read and consent to our Privacy Policy (Section 5);
• Have authority to enter into this agreement on behalf of yourself or your organisation.

If you do not agree to these Terms, do not use the Service.

3. The Service

Songline provides the following core functionality:

• Journey tracking — milestone-based progress tracking for visa applications organised into stages and tasks;
• Document management — secure upload and storage of supporting documents;
• Communication — in-app messaging between applicants and their agency;
• AI assistant (Sunny) — a conversational assistant that can answer general questions about the migration process (see Section 6);
• Processing time information — indicative Department of Home Affairs processing times sourced from publicly available data;
• Payment processing — facilitation of agency fee payments via Stripe or bank transfer (payments go directly to the agency, not to Songline). Agencies may set up payment installments for contracts requiring multiple payments;
• Invoice delivery — when a payment is recorded, an invoice PDF is generated via Xero (if connected) and emailed to you in your preferred language, with a copy to your agency's records;
• Meeting booking — scheduling and video meetings between applicants and their agency, facilitated through Microsoft Teams where the agency has enabled this integration;
• E-signatures — electronic document signing facilitated through SignNow where the agency has enabled this integration;
• Push notifications — mobile notifications to keep you informed of journey updates, task deadlines, and messages from your agency;
• Forms — structured data collection forms created by your agency to gather information required for your visa application.

We reserve the right to modify, suspend, or discontinue any feature of the Service at any time with reasonable notice.

4. Accounts and Security

4.1 Invite-Only Access

Applicant accounts are created by invitation only, issued by a registered migration agency. You cannot self-register as an applicant on Songline. Your agency may initially create your record as a candidate (prospective client) and later promote you to a full client with an invitation to set up your account. Your agency may also revert your status back to candidate if needed — in that case, your portal access will be suspended but all your data is preserved.

4.2 Account Credentials

You are responsible for maintaining the confidentiality of your login credentials. You agree to notify your migration agency immediately if you suspect unauthorised access to your account. Songline is not liable for any loss resulting from unauthorised access due to failure to protect your credentials.

4.3 Accurate Information

You agree to provide accurate, current, and complete information when using the Service and to keep your information updated.

5. Privacy and Data Collection

5.1 What We Collect

• Identity data — name, email address, phone number, passport details, and other identity information you provide through forms or your profile;
• Application data — visa subclass, application status, milestone progress, notes added by your agent;
• Documents — files you or your agent upload to your journey (e.g. passports, birth certificates, financial records);
• Form responses — information you submit through in-app forms created by your agency (e.g. identity declarations, health details, employment history);
• Communications — messages exchanged within the app;
• Meeting data — meeting bookings, calendar availability, and video meeting attendance where your agency uses meeting features;
• E-signature data — records of documents sent for electronic signature and their completion status;
• Payment records — amounts, dates, and methods of payments made through the platform, including installment payment history;
• Referral information — how you found or were referred to your agency (e.g. search engine, social media, friend referral), where collected;
• Usage data — pages visited, features used, device type, browser, and aggregate analytics (via Vercel Analytics — no personally identifiable data is collected at the analytics layer);
• AI conversation data — messages sent to the Sunny assistant (see Section 6).

5.2 How We Use Your Data

• To deliver and improve the Service;
• To enable your migration agency to manage your case;
• To send transactional notifications (stage updates, document requests, payment confirmations, invoice delivery);
• To facilitate payment processing through Stripe;
• To comply with legal obligations.

We do not sell your personal data. We do not use your data for advertising purposes.

5.3 Data Storage and Security

Your data is stored in a PostgreSQL database hosted on Supabase, with infrastructure located in Australia (ap-southeast-2). Documents are stored in a secure cloud storage provider (configurable per agency — options include SharePoint, AWS S3, Google Drive, Dropbox, or Box). Sensitive data fields (such as passport numbers and credentials) are encrypted at rest using AES-256-GCM. Passwords are hashed using scrypt. All data in transit is encrypted using TLS 1.2 or higher.

Songline maintains an audit log of significant actions (account creation, payment processing, document uploads, template changes, impersonation events) for security and compliance purposes. Audit logs are accessible to agency admins and Super Admin.

5.4 Data Sharing

We share data only with:

• Your migration agency — who has full access to your journey data as your service provider;
• Stripe — for payment processing (subject to Stripe's Privacy Policy);
• Google (Gemini) — AI infrastructure provider that processes Sunny assistant queries and translation requests (no data is retained for model training — see Section 6);
• Tavily — web search provider used to retrieve live immigration information in response to Sunny queries;
• Xero — if your agency has enabled Xero integration, invoice and payment data (including installment records) is shared with Xero for accounting and reconciliation purposes. Invoice PDFs are downloaded from Xero and emailed to you via your agency's email provider;
• Microsoft Teams — if your agency has enabled Teams integration, meeting scheduling and video call data is shared with Microsoft;
• SignNow — if your agency has enabled e-signature integration, document signing data is shared with SignNow;
• SMTP email provider — transactional emails (invitations, notifications, invoice delivery, payment confirmations) are delivered via your agency's configured SMTP provider (e.g. SMTP2GO, Zoho);
• Expo — push notification delivery for mobile app users (device tokens only — no personal data is shared);
• Law enforcement or regulatory bodies — only when required by law.

5.5 Data Retention

Your data is retained for as long as your account is active or as required by your migration agency. You may request deletion of your personal data by contacting your agency or emailing us at privacy@songline.au. Some data may be retained for legal or compliance reasons.

5.6 Your Rights

Under the Australian Privacy Principles, you have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Make a complaint about how we handle your information.

To exercise these rights, contact privacy@songline.au.

5.7 Cookies and Analytics

We use Vercel Analytics to collect anonymised, aggregate usage statistics. No personally identifiable data is collected or stored through analytics. No third-party advertising cookies are used.

6. AI Assistant (Sunny)

6.1 What Sunny Can Do

Sunny can answer general questions about visa subclasses, Department of Home Affairs processes, document requirements, indicative processing times, and how to use the Songline app, drawing on publicly available information and the Songline user guide. Sunny may perform live web searches (via Tavily) to provide up-to-date responses. Sunny responds in the language you are using (within the set of languages enabled by your agency). On the admin side, Agent Sunny can query client data, draft emails, and search agency records to assist agents with caseload management.

6.2 Limitations and Disclaimers

• Sunny's responses are generated by AI and may be inaccurate, incomplete, or outdated;
• Sunny's responses do not constitute migration advice, legal advice, or a guarantee of any visa outcome;
• You should not rely solely on Sunny's responses for any decision affecting your visa application;
• Always consult your registered migration agent for advice specific to your circumstances.

6.3 AI Infrastructure and Data

Sunny is powered by Google Gemini 2.5 Flash. Queries are processed by Google's infrastructure. Google does not retain your data for model training under our service agreements. Conversation history is stored in Songline's database to provide continuity within your session and is accessible to your migration agent.

6.4 Translations

If your agency has enabled additional languages, UI translations are generated by Google Gemini AI and stored in our database. Translation quality may vary. In the event of any discrepancy, the English version of any content is authoritative.

7. Document Storage

Documents you upload to Songline are stored securely with your agency's chosen storage provider. You retain ownership of all documents you upload. By uploading a document, you grant Songline and your migration agency a limited licence to store, access, and process the document solely for the purpose of delivering the Service to you.

Do not upload documents containing information about third parties without their consent. Do not upload unlawful content.

You are responsible for maintaining your own copies of all uploaded documents. While we take reasonable steps to ensure data integrity, Songline is not liable for data loss caused by circumstances beyond our reasonable control.

8. Agency Relationship

Songline provides its platform to registered migration agencies ("Agencies") who use it to service their clients ("Applicants"). The contractual relationship for migration services is between you and your Agency — Songline is a technology provider only.

Your Agency is responsible for:

• The accuracy of case information entered into the platform;
• Compliance with the Migration Agents Registration Authority (MARA) obligations;
• Their own privacy obligations to you as their client;
• Any advice given through or outside the platform.

Songline is not a party to any agreement between you and your Agency and accepts no responsibility for the quality, accuracy, or outcome of migration services provided by an Agency.

9. Acceptable Use

You agree not to:

• Use the Service for any unlawful purpose;
• Upload false, misleading, or fraudulent documents or information;
• Attempt to gain unauthorised access to any part of the Service or another user's account;
• Interfere with or disrupt the integrity or performance of the Service;
• Use automated means to access the Service without our express written permission;
• Reverse engineer, decompile, or attempt to extract source code from the Service;
• Use the Service to transmit spam, malware, or other harmful content.

Violation of these terms may result in immediate suspension or termination of your account.

10. Intellectual Property

The Songline platform, including its design, software, branding, and content (excluding user-uploaded documents), is owned by Songline Journey and protected by Australian and international intellectual property laws.

You retain ownership of all content and documents you upload. You grant us a limited, non-exclusive licence to store and process your content solely to deliver the Service.

"Songline" and the Songline logo are trademarks of Songline Journey. You may not use our trademarks without prior written permission.

11. Disclaimers

The Service is provided "as is" and "as available." To the maximum extent permitted by Australian law, Songline makes no warranties, express or implied, including but not limited to:

• Warranties of merchantability or fitness for a particular purpose;
• That the Service will be uninterrupted, error-free, or secure;
• That processing time estimates or AI-generated content are accurate or current;
• That any visa application will be successful.

Processing time information is sourced from publicly available Department of Home Affairs data and is indicative only. Actual processing times may differ significantly.

12. Limitation of Liability

To the maximum extent permitted by Australian consumer law:

• Songline's total liability to you for any claim arising from your use of the Service is limited to the amount you paid to Songline (not to your Agency) in the 12 months preceding the claim, or AUD $100, whichever is greater;
• Songline is not liable for any indirect, incidental, special, consequential, or punitive damages, including loss of visa application, loss of income, or immigration consequences;
• Nothing in these Terms excludes liability that cannot be excluded under the Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010 (Cth)).

13. Termination

Your access to Songline is tied to your relationship with your migration agency. If your agency ceases to use Songline, or if your agency terminates your account, your access will be removed. Songline may also suspend or terminate your access for violation of these Terms.

Upon termination, you may request a copy of your personal data by contacting privacy@songline.au within 30 days.

14. Changes to These Terms

We may update these Terms from time to time. When we make material changes, we will update the "Last updated" date at the top of this page and notify you via the app or by email. Continued use of the Service after changes take effect constitutes your acceptance of the updated Terms.

15. Contact Us

For privacy inquiries, data access requests, or complaints:

• Email: privacy@songline.au
• General enquiries: info@songline.au
• Website: songline.au

We will respond to privacy requests within 30 days as required by the Australian Privacy Principles.

If you are unhappy with our handling of your privacy complaint, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.