Last Update: March 23, 2018
Please review this policy to understand the steps Envoy has taken to secure your Personal Information.
Information You Give Us. We refer to information that can personally identify you, such as your name, address and email address as “Personal Information”. While you may visit the Platform without providing Personal Information, when you use the Support Services, you may be required to provide certain Personal Information to allow Envoy to provide the Support Services and to allow Authorized Representatives and Attorneys to process Matters on your Employer’s behalf (see further details below). “Authorized Representatives” are (i) local representatives engaged to assist with Matters in countries outside the United States and (ii) third parties, including government agencies, to whom Envoy or the Attorneys or Authorized Representatives are authorized to make disclosures for purposes of pursuing Matters. “Attorneys” are, collectively, the attorneys and such attorneys’ support staff at Global Immigration Associates, P.C. (“GIA PC”), an Illinois professional corporation, and other attorneys and attorney support staff who have agreed to provide legal services to process the immigration matters on behalf of our clients’ employees or potential employees (“Matters”). “Employer” means either your employer or prospective employer.
If Envoy is helping your Employer seek permission for you to work in the United States, Envoy is providing its Support Services to your Employer, and the Attorneys are providing your Employer with legal assistance. While Envoy and the Attorneys do not represent you, as an individual, in order to complete the process for applying for a work authorization, your Employer will need you to provide certain information to the Attorneys. Envoy collects and processes this information (including any of your Personal Information) on behalf of your Employer and we may use your Personal Information to provide the Support Services and to facilitate the Attorneys’ and their Authorized Representatives’ processing of their Matters. If you have any questions as to how this information (including any of your Personal Information) is used by your Employer (or on behalf of your Employer), please raise these with your Employer.
If you do provide Envoy with information (including Personal Information) as part of the Support Services, you hereby consent to the use of such information for us to provide the Support Services and as part of the process of applying for the work authorization requested by your Employer.
We may also use your Personal Information to contact you about our services or information that may interest you, and to provide you with information you have requested (such as if you contact us about the services we provide, or if you sign up for our email blog updates). You can opt-out of these communications by unsubscribing to such emails.
Usage Information. We collect non-personal statistical information that does not personally identify you. This includes non-personal statistical information about your internet connection, the equipment that you use to access our Platform, and how you use the Platform. We refer to this information as “Usage Information”. This information allows us to optimize the Platform to the internet connections and equipment that are used to access the Platform. We collect Usage Information directly from you when you provide it to us and automatically as you navigate through and interact with our Platform. Information collected this way includes: (i) details of your visits to our Platform, including traffic data, location data, logs, other communication data, and the resources that you access and use on the Platform; and (ii) information about your computer and internet connection, including your IP address, operating system, and browser type. The technologies we use for this automatic data collection may include:
Whilst we collect this Usage Information to optimize the Platform and monitor and improve our Support Services, we do not use these technologies to collect information that would identity you, as an individual, or use the Usage Information to profile identifiable individuals or to monitor the behavior of identifiable individuals.
Third-party Service Providers
We may use subcontractors, vendors or other third-parties in order to efficiently provide the Platform and our Support Services (“Service Providers”). Service Providers may include, but are not limited to, those providing data hosting and credit card processing. Some Service Providers will collect information directly from you. Information collected directly from these Service Providers is governed by their privacy policies. You should view the privacy policies of Service Providers before providing information to them.
We may disclose Usage Information and aggregated information about our users without restriction. This information cannot be used to personally identify our users. We do not disclose your Personal Information except in the circumstances described here:
We strive to provide you with choices regarding the information you provide to us. We have created mechanisms to provide you with the following control over your information:
Accessing and Correcting Your Information
Envoy acknowledges the right of access by EU individuals. If you are a registered user of our Support Services, you can review and change your Personal Information by logging into the Platform and visiting your account’s My Login page.
If you are an authorized representative an Employer you may also contact your account manager or send us an email at firstname.lastname@example.org to request access to, correct or delete any Personal Information that you have provided to us.
Please note that if you delete some or all of your Personal Information, we may not be able to provide the Support Services and the Attorneys and Authorized Representatives may not be able to process the relevant Matters. We may not accommodate a request to change Personal Information if we believe the change would violate any law or legal requirement or cause the Personal Information to be incorrect.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Platform 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 email@example.com.
We have implemented measures designed to secure Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Additional details about the specific technologies used to secure Personal Information are available upon request by sending an email to firstname.lastname@example.org.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platform.
We operate the Platform and manage the provision of the Support Services from the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Platform, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Envoy has certified certain of our services, for which we act as a data processor, under the EU-U.S. Privacy Shield Framework (the “Privacy Shield”).
Envoy’s participation in the Privacy Shield applies to Personal Information processed on behalf of Employers where such Personal Data is received from the European Union. This may include human resources data (as relevant to the immigration matters we are handling on behalf of Employers). Envoy is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).
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 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 email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
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 firstname.lastname@example.org.
Envoy’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, Envoy 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 Envoy proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Envoy 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 Envoy by email at email@example.com.
Envoy 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.
If your complaint involves human resources data transferred to the United States from the EU in the context of the employment relationship, and Envoy does not address it satisfactorily, Envoy 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
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