Privacy Policy

Global Immigration Associates PC Privacy Policy

Overview – the key information you should be aware of

(A)        Who we are: We are Global Immigration Associates P.C., a law firm offering immigration services. If you need it, our registered office is 230 W Monroe, Suite 2800, Chicago, Illinois, 60606, USA. Global Immigration Associates P.C. is the controller of your personal information, and is responsible for your personal information. All references in this policy to “Global Immigration Associates P.C.”, “GIA” “our”, “us” or “we” refer to Global Immigration Associates P.C. All references in this policy to “our website”, refer to the website provided by GIA at https://giafirm.com/.

 

(B)        Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find further detail on here.
In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.
We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this privacy policy, please let us know using our contact details in section 13.

 

(C)        Who this policy applies to: This policy applies to:
1.  Visitors to our website and individuals who enquire about our services;
2.  Clients of GIA;
Depending on our relationship, we will collect and use your information in different ways.

 

(D)        What this policy contains: This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):
1.  How we obtain your personal information;
2.  Collection of your personal information and how we use it;
3.  Our legal basis for using your personal information;
4.  How and why we share your personal information with others;
5.  How long we store your personal information www.envoyglobal.com;
6.  Your rights;
7.  Children;
8.  Marketing;
9.  Where we may transfer your personal information;
10. Risks and how we keep your personal information secure;
11. Links to other websites;
12. Changes to this privacy policy; and
13. Further questions and how to make a complaint.

 

(E)        Your rights to object: You have various rights in respect of our use of your personal information as set out in section 6. Two of the key rights to be aware of are that:
1.  you may ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
2.  you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.
You can find out more information in section 6.

 

(F)        What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

 

The detail – the key information you should be aware of

1.        How we obtain your personal information
1.1      You may provide us with your personal information voluntarily. We may also receive information about you from third parties such as Envoy who is providing the technology platform and nonlegal services, while GIA is assisting with the application filing process.

2.        Collection of your personal information and how we use it
Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information. We refer to this as “personal information” throughout this policy.

2.1      Visitors to our website and individuals who enquire about our services
(a)     What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i)     your name including your title;
(ii)    your postal address;
(iii)   your email address;
(iv)   your telephone number;
(v)    information provided when you correspond with us;
(vi)   any updates to information provided to us;
(vii)  personal information we collect about you or that we obtain from our third party sources;
(viii) the following information created and recorded automatically when you visit our website:
(A)     Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages; and
(B)     Information about your visit and your behavior on our website (for example, the pages that you click on).  This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.
(b)     How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i)     to allow you to access and use our website;
(ii)    for improvement and maintenance of our website and to provide technical support for our website;
(iii)   to ensure the security of our website;
(iv)  to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymized as far as reasonably possible and you will not be identifiable from the information collected.
Please see sections 2.3 and 2.4 for more details about how we use your personal information.
(c)      A word about cookies
(i)     Some pages on our website use cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
(ii)    Where we use cookies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.
(iii)   For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here.

2.1      Clients
          (a)     What personal information we collect about you
(i)     We, or third parties on our behalf, will collect and use the following information about you:
(ii)    your name;
(iii)   your postal address;
(iv)   your email address;
(v)    your telephone number;
(vi)   your government identification number such as social security and drivers license number, state identification card number, passport number, alien registration number, taxpayer identification number)
(vii)  your age;
(viii) your gender;
(ix)   your date of birth;
(x)    your country of birth and citizenship;
(xi)   copies of your passports, birth certificates, marriage certificates and degrees;
(i)     information provided when you correspond with us;
(ii)    information provided by immigration authorities and other governmental departments in respect of your immigration application;
(iii)    any updates to information provided to us;
(iv)    information about the  services we provide to you:
(A)     information needed to provide the services to you;
(B)     customer services information; and
(C)    customer relationship management and marketing information.
(b)    How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i)     to provide you with our immigration services including preparing the necessary forms and supporting documents to obtain work authorized status in the US for you and (where applicable) your family members;
(ii)    to deal with any inquiries or issues you have about our services;
(iii)    to send you certain communications (including by email or post) about our products and services such as administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);
Please see sections 2.3 and 2.4 for more details about how we use your personal information.
(c)    Source of personal information. We may receive some of your personal information from third parties, such as from your employer or a family member.
(d)    Special categories of data. Some of the personal information that we collect about you or which you provide to us may be special categories of data.  Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.
(d)    Information we need to provide services to you. We need certain types of personal information so that we can provide services to you and perform contractual and other legal obligations that we have to you. If you do not provide us with such personal information, or if you ask us to delete it, you may no longer be able to access our services.
2.3       Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:
(a)    to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you.  If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
(b)    for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.  We may process your personal information for these purposes where it is in our legitimate interests to do so;
(c)    to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(d)    to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
2.3       Further processing
Before using your personal information for any purposes which fall outside those set out in this section 2, we will assess whether our new use of your personal information is compatible with the purposes set out in this section 2. Please contact us using the details in section 13 if you want further information on the assessment we will undertake.
3.          Legal basis for use of your personal information
3.1        We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
(a)    our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with our contract to provide services to you or you contract with your employer); or
(b)    our use of your personal information is necessary for complying with our legal and regulatory obligations; or
(b)    where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
(i)     provide immigration services
(ii)    providing you with our newsletter and / or other marketing material
(iii)   providing the functionality of our services and fulfilling your requests; and
(iv)   for internal group administrative purposes.
If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
3.2           If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at privacy@giafirm.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our immigration services and associated services to you.
4.        How and why we share your personal information with others
4.1      We will share your personal information with the following third parties or categories of third parties:
(a)    Your employer who is assisting you and us with your immigration application;
(b)    Immigration authorities and governmental departments who will process the immigration application that we prepare on your behalf or who provide us with information about you to enable us to complete your immigration application;
(c)    Envoy who is an immigration services provider which we work with to provide you with immigration services.
(e)    our other service providers and sub-contractors, including utility providers, suppliers of technical and support services, and cloud service providers;
4.2      Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.
4.3      We will also disclose your personal information to third parties:
(a)    where it is in our legitimate interests to do so to run, grow and develop our business such as:
(i)     if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
(ii)    if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
(b)    if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(c)    in order to enforce or apply our terms of use, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
(c)    to protect the rights, property, or safety of GIA, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.
5.       How long we store your personal information
         We keep your personal information for no longer than necessary for the purposes for which the personal information is processed.  The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
6.       Your rights
6.1      Individuals in the EU have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at privacy@giafirm.com  at any time. Individuals in the EU have the following rights:
(a)    Right of access. You have a right of access to any personal information we hold about you.  You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area (“EEA”).
(b)    Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
(c)    Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 13.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are, using the contact details in section 13.
(d)    Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details in section 13.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are using the contact details in section 13.
(e)    Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes.  If you exercise this right, we will stop using your personal information for this purpose.
(f)    Right to data portability: You have a right to ask us to provide your personal information to a third-party provider of services.
This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
(g)    Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.
(h)    You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
6.2      We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
6.3      If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.
6.4      Your California Privacy Rights. California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@giafirm.com.
7.       Children
7.1     You must be aged 18 or over to purchase services from us. Our services are not directed at children and we do not knowingly collect any personal information from children for marketing purpose.
7.2     Please contact us at privacy@giafirm.com if you are aware that we may have inadvertently collected personal information from a child.
8.       Marketing
8.1     We may collect and use your personal information for undertaking marketing by email telephone and post if we have a lawful basis to do so.
8.2     If you wish to stop receiving marketing communications, you can contact us by email at privacy@giafirm.com.
9.      Where we may transfer your personal information
9.1      Your personal information may be used, stored and/or accessed by staff operating outside the EEA working for us (specifically in the USA, and India where we are based), to foreign governments or suppliers. Further details on to whom your personal information may be disclosed are set out in section 4.
9.2      9.2 For individuals in the European Union: Privacy Shield. If we provide any personal information about you to any entities in the United States, GIA has certified under the EU-U.S. Privacy Shield Framework (the “Privacy Shield”).
(a)    Our participation in the Privacy Shield applies to personal information that is received in the U.S. from the EEA in order for us to submit your immigration application. This may include human resources data, as relevant to the immigration matters we are handling.
(b)    GIA is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).
(c)    GIA complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield. GIA has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
(d)    Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@giafirm.com. If requested to remove data, we will respond within a reasonable timeframe.
(e)    We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your personal information with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@giafirm.com.
(f)    In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
(g)    GIA’s accountability for personal information that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, GIA remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal information on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless GIA proves that it is not responsible for the event giving rise to the damage.
(h)    In compliance with the Privacy Shield Principles, GIA commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact GIA by email at privacy@giafirm.com.
(i)    (GIA has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
(j)    If your complaint involves human resources data transferred to the United States from the EEA in the context of the employment relationship, and GIA does not address it satisfactorily, GIA commits to cooperate with the panel established by the EU data protection authorities (“DPA Panel”), as applicable and to comply with the advice given by the DPA Panel, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
(k)    If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
9.3      Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us using the details in section 13.
10.      Risks and how we keep your personal information secure
10.1    The main risk of our processing of your personal information is if it is lost, stolen or misused.  This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
10.2    For this reason, GIA is committed to protecting your personal information from loss, theft and misuse.  We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures including but not limited to role-based access control of data stored at a cloud provider for Document Management System as well as Envoy platform.
10.3    In the course of provision of your personal information to us, your personal information may be transferred over the internet.  Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
10.4   Where we have given you (or where you have chosen) a password which enables you to access your Envoy’s online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
11.      Links to other websites
Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
12.    Changes to our privacy policy
We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.
13.    Further questions and how to make a complaint
13.1   If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact privacy@giafirm.com.  We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information
13.2   EU data subjects may also make a complaint to the Information Commissioner’s Office in the UK, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place.  Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
The practices described in this privacy policy statement are current as of 04/15/2019

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