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

Privacy Policy

Last Update: 9/14/2020

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”). This Privacy Policy also applies to any Envoy services made available through the Platform, including technology, tools, and administrative support provided by Attorneys and Authorized Representatives who have agreed to provide legal and immigration services to process immigration matters (“Matters”) on behalf of our clients’ employees or potential employees (the “Support Services”). “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 Matters. “Employer” means either your employer or prospective employer. Please review this policy to understand how we handle your information. If you do not agree to this Privacy Policy, please do not use the Platform or the Support Services.

INFORMATION WE COLLECT AND HOW WE USE IT

Information You Give Us. In order to provide the Platform and Support Services, we may request the following information about you, including:

  • Nationality
  • Title/Position/Department
  • Business contact details (e.g., address, telephone, mobile, and email)
  • Dates of employment or prospective employment
  • Accreditations
  • Personal contact details (e.g., home address, home telephone number and personal mobile number)
  • Date of birth
  • Language preference
  • Education and qualifications
  • Family member information
  • Device information and other technical information relevant to information technology management
  • Government Identification or Social Security number, Driver’s license number, state identification card number, passport number, alien registration number, taxpayer identification number, date of birth, mother’s maiden name, digital or electronic signature, or picture.

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 the Attorneys and/or Authorized Representatives are providing your Employer with legal and/or immigration assistance. While Envoy and the Attorneys do 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 the Attorneys 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 the Attorneys’ 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.

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

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:

  • 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;
  • information about your computer and internet connection, including your operating system, and browser type; and
  • device identifiers, including your IP address and mobile device ID.

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).
  • 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.

WHEN AND HOW WE SHARE YOUR INFORMATION

Sharing Information

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:

  • Attorneys and Authorized Representatives: We may share or disclose your information to enable the provision of the Support Services. Specifically, we will share your 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 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 information held by us may be among the assets transferred.
  • Comply with Law and Prevent Harm: Notwithstanding anything to the contrary in this Privacy Policy, we may disclose or share your 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 information with other companies and organizations via our service providers for the purposes of fraud protection and credit risk reduction. In certain situations, we may be required to disclose your information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • Enforcement: We may disclose your information in order to enforce or apply our Terms and other agreements, including for billing and collection purposes.

YOUR CHOICES ABOUT YOUR INFORMATION

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:

  • 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.
  • We will not share your information with third parties for a purpose that is materially different from the purposes disclosed in this Policy without your consent.

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, Attorney or Authorized Representative) to exercise these rights. If you are an Attorney, Authorized Representative or 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 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 the Attorneys 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.

 

HOW WE PROTECT YOUR INFORMATION

Data Security

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 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 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.

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 data 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 a conflict between the protections that Privacy Shield provides to individuals and the rest of this privacy policy, then the extra protections provided by Privacy Shield will 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. 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 privacy@envoyglobal.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 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’ 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.

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