Sales: 312-922-9035 | Service: 312-964-6499
Sales: 312-922-9035 | Service: 312-964-6499

Privacy Policy

Last Update:  March 23, 2018

OUR COMMITMENT TO PRIVACY

Envoy Global, Inc. (formerly VISANOW.com, Inc.) (“Envoy”, “we” or “us”) is committed to protecting the privacy of all users of our services, which may include business organizations and their individual employees or potential employees or service providers (“you”). We are providing this Privacy Policy to communicate our policies with respect to your information when you use our website located at www.envoyglobal.com and related mobile applications (collectively, the “Platform”) or any Envoy services made available through the Platform, including technology, tools, and administrative support (the “Support Services”).

Please review this policy to understand the steps Envoy has taken to secure your Personal Information.

INFORMATION WE COLLECT AND HOW WE USE IT

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.

Except as specifically stated in this Privacy Policy, we do not disclose your Personal Information to third parties.

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:

  • Cookies (or browser cookies): A cookie is a small file placed on the hard drive of your computer. We use session cookies to keep track of your login information. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you use the Platform.
  • Pixel Tags / Web Beacons: Webpages on our Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email. We may also use these web beacons for other related Platform statistics (e.g., recording the popularity of certain content and verifying system and server integrity).
  • Device Identifiers: When you use a mobile device like a tablet or phone to access our Platform, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us.
  • Tracking URLs: These are links that allow Envoy to determine the effectiveness of a particular part of the Platform. For instance, emails from a marketing campaign may include tracking URLs to help Envoy see how popular the page is.  This helps us serve more relevant content and information.

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.

WHEN AND HOW WE SHARE YOUR INFORMATION

Sharing Information

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:

  • Your Consent: We may share or disclose your Personal Information in connection with our provision of the Support Services.  Specifically, we will share your Personal Information with Attorneys and Authorized Representatives in connection with processing of Matters on behalf of your Employer.
  • Service Providers: We may share or disclose your Personal Information with Service Providers in order to provide or maintain the Platform and as part of Envoy’s provision of the Support Services.
  • Business Transfers: In the event that Envoy is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, your Personal Information held by us may be among the assets transferred.
  • Law and Harm: Notwithstanding anything to the contrary in this Privacy Policy, we may disclose or share your Personal Information in order to comply with any court order, law, or legal process, including to respond to any government, public authority or regulatory request, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Envoy, our customers, or others. This includes exchanging Personal Information with other companies and organizations for the purposes of fraud protection and credit risk reduction. 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.
  • Enforcement: We may disclose your Personal Information in order to enforce or apply our Terms and other agreements, including for billing and collection purposes.
  • Disclosed when Collected: For any other purpose disclosed by us when you provide the Personal Information.

YOUR CHOICES ABOUT YOUR INFORMATION

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:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Platform may then be inaccessible or not function properly.
  • Email Newsletters from Envoy. If you do not wish to have your contact information used by Envoy to notify you of updates and educational opportunities related to immigration matters or to promote our own or third parties’ products or services, you can opt-out by unsubscribing to such emails.

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 privacy@envoyglobal.com 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 privacy@envoyglobal.com.

HOW WE PROTECT YOUR INFORMATION

Data Security

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 privacy@envoyglobal.com.

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.

PRIVACY SHIELD

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).

Envoy 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.  Envoy 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/.

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 privacy@envoyglobal.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 privacy@envoyglobal.com.

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 privacy@envoyglobal.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

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ Personal Information, as determined in our sole discretion, we will notify you by email to the email address specified in your registered account and/or through a notice on the Platform.

The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you (where you are a registered user of our Platform), and for periodically visiting the Platform and this Privacy Policy to check for any changes.

Contact Information

To ask questions or concerns about this Privacy Policy and our privacy practices or if you would like to make a complaint pursuant to the Privacy Shield Principles, please contact us at privacy@envoyglobal.com.