Last Update: 11/3/2020
Information You Give Us. In order to provide the Platform and Support Services, we may request the following information about you, including:
If Envoy is helping your Employer seek permission for you to work in the United States or otherwise in a jurisdiction that is not your home jurisdiction, Envoy is providing its Support Services to your Employer, and your Employer’s Law Firm and/or Authorized Representatives are providing your Employer with legal and/or immigration assistance. While Envoy does not provide services to you and your Employer’s Law Firm does not represent you (except in limited cases, such as the green card process), 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 your Employer’s Law Firm or Authorized Representatives. Envoy collects and processes this information on behalf of your Employer and we may use your information to provide the Support Services and to facilitate your Employer’s Law Firm’s and the 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 your information as part of the Support Services, we will use such information 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 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 via the unsubscribe link found in the footer of each email.
Device and Usage Information. When you navigate through and interact with our Platform, we automatically collect certain information about your device, internet connection, the equipment that you use to access our Platform, and how you use the Platform. We refer to this information as “Device and 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. Device and Usage Information includes:
The technologies we use for this automatic data collection may include:
We may disclose deidentified and aggregated information about our users without restriction. This information cannot be used to personally identify our users. We do not disclose your information that can personally identify you except in the circumstances described here:
We strive to provide you with choices regarding the information you provide to us. You can exercise control over your information in the following ways:
Accessing and Correcting Your Information
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.
Depending on your jurisdiction of residence, you may have additional rights, such as the right to access, delete, and correct your information. If you are an individual employee or candidate, please contact your Employer, prospective Employer, Law Firm or Authorized Representative to exercise these rights. If you are a Law Firm, Authorized Representative or an Employer you may also contact your account manager or send us an email at email@example.com to request access to, correct or delete any personal data that we process on your behalf.
Please note that if you delete some or all of your information, we may not be able to provide the Support Services and your Employer’s Law Firm and Authorized Representatives may not be able to process the relevant Matters. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
California Shine the Light Disclosure
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 purpose. We do not share your Personal Information with third parties for their own direct marketing purposes.
We have implemented measures designed to secure information we process from accidental loss and from unauthorized access, use, alteration, and disclosure. Additional details about the specific technologies used to secure 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 information, we cannot guarantee the security of any 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.
INTERNATIONAL DATA TRANSFERS
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”). On July 16, 2020, Europe’s highest court, the CJEU, invalidated the EU-US Privacy Shield with respect to transfers of data between the European Economic Area (“EEA”) and the United States (the decision did not apply to the Swiss-US Privacy Shield, which remains a valid data transfer mechanism for transfers from Switzerland to the US). Envoy is taking steps to comply with the CJEU decision, including by entering into Standard Contractual Clauses with its customers and subprocessors upon request. Additionally, Envoy will continue to protect EEA, UK, and Swiss data in compliance with the Privacy Shield Principles, as described herein.
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. You also have the right to access, correct, amend, or delete the data 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.
Envoy’s accountability for personal data that it receives from EU data subjects 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 data 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. As such, Envoy is subject to the investigatory and enforcement powers of the FTC. European Union individuals with Privacy Shield inquiries or complaints should first contact Envoy by email at firstname.lastname@example.org.
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
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