Effective Date: September 15, 2020
Corporate Immigration Partners, LLP, our related affiliates, and subsidiaries (collectively, “CIP” or “we”) want to ensure that our clients, their employees, and any affected data subjects (“you”) are informed about the security and use of the personal information that we receive and process on your behalf.
Accordingly, this Privacy Notice (“Privacy Notice”) is intended to inform you about CIP’s privacy practices. It describes the types of personal information we collect, how we may use that information, with whom it may be shared, and the measures are taken to ensure its security.
In addition, we provide information on how to contact us to
- Exercise your right to object to the processing of certain aspects of your data under applicable laws;
- Access, correct, or delete your data;
- Ask any questions you may have about our privacy practices.
In some instances, we are engaged directly by corporations or business groups, which results in the processing of employee information at their request. Where we refer to “employer” below, it is in these circumstances where corporations or other business groups have engaged us to act. You may at any time, if you prefer, address any concerns directly to your employer, where applicable.
BROWSING OR USING OUR SITE DOES NOT MAKE YOU OUR CLIENT
Please be advised that browsing the website or using its services or functionality does not make you a client of Corporate Immigration Partners, LLP. The site is provided for general informational purposes and convenience, and not for creating an attorney-client relationship. If you need legal advice, you should contact an attorney or your local bar association.
PERSONAL INFORMATION WE COLLECT ABOUT YOU
CIP collects certain personal information about you and, if required, your family members and employer to provide immigration consulting and legal services. We will not be able to provide the services requested if we are not provided with all relevant personal information.
For purposes of providing client services, including the applicable legal services, and immigration consulting services you or your employer request, CIP collects and processes personal information such as name, address, telephone number, date of birth, marital status, passport number, employment history, educational background, tax status, employee number, job title and function, and expatriate status through our case management system, Immigration Tracker, or in conversation with our lawyers, consultants, and staff. Where required for the service, CIP collects certain personal documents such as passport copies, educational records, CVs, visa copies, birth certificates, and other materials.
We also obtain personal information from third-party sources, such as former employers, educational institutions you attended, relocation companies, and your current or prospective employer. We use this information to provide immigration consulting and legal services, including analyzing, completing and processing immigration, visa and related filings and submissions to relevant government agencies, providing legal and consultative advice on eligibility to obtain immigration benefits, and assisting with relocation and other expatriate issues.
We use your personal information in other instances in connection with the services we provide. This use occurs only when there is a legitimate interest to do so that is not overridden by your data protection rights as required by law, such as assisting in the management and administration of our clients’ global mobility programs (such as visa expiration tracking, immigration program compliance, etc.), providing access to online case-management tools, where applicable, and analyzing immigration trends, such as visa processing times and government approval rates. Where your employer engages us, we process your personal information because it is in our legitimate interests to fulfill our contract with your employer for client services.
In addition to providing you or your employer with our services, we process personal information to comply with our legal and regulatory obligations, including record-keeping requirements. For example, we process personal data under “know your customer,” anti-money laundering regulations, anti-bribery regulations, and professional regulations.
Certain countries require verification of new employees’ employment eligibility at the time of hire. Examples of such requirements include the Immigration Reform and Control Act of 1986 (“IRCA”) in the United States and the Immigration, Asylum, and Nationality Act of 2006 in the United Kingdom, pursuant to which CIP collects and processes personal information such as your name, email address, home address, military service, and citizenship status.
If you request information about our services directly, you may choose to provide personal information such as your name, address, email address, and telephone number. We use your information to respond to your request.
OTHER USES OF INFORMATION
Where it is in our legitimate interests and not outweighed by your data protection rights, we use the personal information we collect and process for client and CIP administration, compliance audits, compliance with CIP policies and procedures, ensuring the security and integrity of our services and in ensuring that our Information Technology (IT) systems function effectively.
Furthermore, we process your personal information with your consent, such as when we use your contact details to respond to a request or question by you, or where required by law.
SENSITIVE PERSONAL INFORMATION
Governments worldwide require the collection and processing of a wide variety of personal information from foreign nationals seeking to enter the country and obtain immigration benefits such as employment authorization or residency status. Governments require this information for reasons such as the protection of borders, health, sovereignty, national security, and the regulation of the local employment market. Specific categories of personal information may be considered “sensitive” and are subject to a higher level of data protection. These categories may include race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, physical or mental health or condition, data relating to offenses or criminal convictions, and biometric data, such as fingerprints when used to uniquely identify you.
In the context of the services we provide, CIP collects sensitive personal information when the submission of such data is necessary to comply with the country’s legal obligations in which you are seeking a visa or work permit. CIP may need to inquire about certain sensitive information to provide legal or consultative advice about your eligibility to travel to or obtain an immigration benefit from a specific country. For instance, we may need to ask whether you have been previously convicted of any criminal offenses, have particular political affiliations, or other personal matters when the local applicable immigration laws would require such data for purposes of preparing an application or petition on your behalf or evaluating whether certain personal information would bar you from entering the country. In some instances, the laws of EU member states require that we process sensitive personal data for these purposes as permitted by the terms of the GDPR; on other occasions, we will ask for your explicit consent.
INFORMATION WE COLLECT BY AUTOMATED MEANS
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LOG FILES, USAGE DATA, AND IP ADDRESSES
Log files are web server files (containing information such as domain name or IP address, URL, HTTP response code, or the date and duration of your visit) that are automatically created when an Internet user visits a website. An IP address is an identifier that specific electronic devices use to identify and communicate with each other on the internet. When you visit our website, our servers log your IP address. In combination with other data, this information helps us understand which features are of interest to our visitors and the regions of the world where these visitors are located. Also, log files help detect disruptions that may interfere with the provision of our website.
INFORMATION WE SHARE
We will not sell, share, transfer, rent, use, or distribute your information for purposes other than those disclosed unless required by law or as authorized by you or your employer. We share the information you provide among our subsidiaries, affiliates and your current or prospective employer or a third party as your employer instructs us, as appropriate or necessary in connection with the services (such as your employer’s relocation provider, or to protect the interests of any person, where permitted by applicable law. Where your employer retains our services on your behalf, we share your personal information as instructed by your employer, for tax purposes, to assist you in obtaining relocation services, and for any other purpose required to provide the services as permitted by applicable law.
As part of the immigration consulting and legal services, we have been directed to provide, CIP discloses personal information to government agencies, former, current, prospective employers, and related entities. To obtain immigration benefits on your or your employer’s behalf, we will disclose personal information to government agencies and immigration authorities.
We also share the information with certain service providers we have retained in connection with the services we provide, such as translators, education evaluation services, couriers, or other necessary entities. We take steps to require that service providers protect the information consistently with this Privacy Notice. These service providers are authorized to use the information only as necessary to perform services on our behalf or to comply with the law or legal process. We will take reasonable steps to prevent or stop the processing when we know that a service provider processes your personal information in a manner contrary to this Privacy Notice.
We will disclose information about you:
- If we are required to do so by law or legal process
- To law enforcement authorities or other government officials
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity
- If required to protect the vital interests of any person
HOW WE PROTECT PERSONAL INFORMATION
We seek to ensure that any personal information that we hold about you is accurate, complete, current, and otherwise reliable based on data you or an employer provide to provide the immigration consulting and legal services. We seek to collect only that personal information that is adequate, relevant, and not excessive for these purposes.
We maintain appropriate administrative, technical, organizational, and physical safeguards to protect against the loss, misuse or unauthorized access, disclosure, alteration, or destruction of personal information.
We educate our employees and strive to maintain appropriate standards of conduct regarding the protection of personal information.
We take steps to require that third parties who assist in our provision of services abide by all applicable privacy and data protection laws and prohibit them from using your information other than in connection with the services they have been engaged to provide.
We retain personal information for only as long as we need it to provide the services you or your employer has requested, for our own administration and internal purposes, and for any periods that are mandated by law or otherwise agreed to with our clients, after which, we take steps to delete or anonymize the information.
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. CIP does not solicit to children who are less than 13 years of age. CIP does not knowingly acquire, store, or use personal information relating to children who are less than 13 years of age unless it is in the course of what is necessary for visa applications. If CIP learns that personal information of persons less than 13 years of age (other than Service Data) has been collected via the website without parental consent, then CIP will take appropriate steps to delete this information from its systems.
YOUR CALIFORNIA PRIVACY RIGHTS
Under California Civil Code Section 1798.83, California users are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.
INFORMATION WE TRANSFER
TRANSFERS REQUIRED FOR THE SERVICES
When we transfer your information to other countries, we will use, share, and safeguard that information as described in this Privacy Notice. We transfer personal information to third countries where it is necessary to provide you the service you (or your employer) requested. For example, the Government requires specific personal data to review applications, screen foreign nationals, issue visas, and other work authorization documents, etc. We also provide your personal information to local advisors, translators, and other service providers, where it is necessary to provide the service you requested.
YOUR CHOICES AND RIGHTS
As set out above, CIP may collect certain information about you in conjunction with providing immigration consulting and legal services. We will respect your decision if your employer subsequently informs us or where you instruct us directly, and you tell us that you wish to opt-out of personal information. If sensitive personal information is involved for the delivery of a new purpose, we will only use your information if you actively communicate your consent to this processing to your employer or us, as applicable, when it is necessary to deliver the requested service, or following the requirements of applicable laws. We will track the identical procedure if we disclose personal information to third parties that are expected to process the personal data for their independent purposes.
We also will assist our clients to provide you, or provide you directly, where appropriate, with access to your personal information and, as applicable, with the ability to review and correct inaccuracies, delete unnecessary personal information, and receive a copy of your personal information in a structured, machine-readable format. We may, where applicable, use reasonable efforts to assist your employer in responding to a request to access, correct, delete or restrict processing of your personal information or, where required by law, to respond directly to such a request within a reasonable period. If either you or your employer informs us in writing that you wish to opt-out of future processing of personal information, we will respect your request.
To help protect your privacy and the security of your information, CIP takes reasonable steps to verify your identity before granting access to information. Where we rely solely on your consent, you may withdraw it at any time. You may also object to processing that is based on our legitimate interests alone. In such instances, our business interests must be found to be compelling and not to jeopardize your rights before further processing may continue. To exercise these rights, please contact your employer or CIP, as applicable. If you have unresolved concerns, were provided by local law, you may have the right to complain to a data protection authority where you reside, where you work or where you believe there has been an infringement of data protection laws.
UPDATES TO OUR PRIVACY NOTICE
This Privacy Notice may be updated periodically without prior notice to reflect changes in our information practices. We will post a notice on our relevant websites or materials to advise of any significant changes to our Privacy Notice and indicate in the notice when it was most recently updated. In certain countries, additional or different procedures not inconsistent with this Privacy Notice may apply as necessary to satisfy local legal requirements.
HOW TO CONTACT US
The controller for your personal information is Corporate Immigration Partners, LLP. If you have any questions or comments about this Privacy Notice directed at any of the data controllers listed above, please contact our data protection officer by email at firstname.lastname@example.org.
You also may write to us at:
Corporate Immigration Partners, LLP.
465 California Street, Suite 700
San Francisco, California 94104