PassPro Immigration Services Privacy Policy

Last Updated: May 25, 2018

We are committed to respecting and protecting your privacy.

This privacy policy (this " Policy") explains how personal information is collected, used, and disclosed by PassPro Immigration Services (referred to henceforth as, "PassPro," “our Company” " we," "our" or " us"). This Policy applies to visitors and users (individually, " you ") of all PassPro websites, landing pages, portals, and any channel you have used to communicate with us including but not limited to email, WhatsApp, any hard-copy communication, in order to provide information for the purpose of being contacted regarding your interest in second citizenship, a call back or contact us form, a subscription link, or filling a disclosure form, a citizenship application form or any other information provided for application and due diligence requirements associated with applying for legal second citizenship, obtaining a Naturalization Certificate, passport or other forms of official Government-issued IDs.

By visiting or using our Sites, to the extent permitted by applicable law, you are consenting to us gathering and processing information about you in accordance with this Policy, although consent may not be required for all of the elements described in this Policy. For particular types of information or processing, we may provide you with choices or request your further consent related to what information we collect and how we may process it.

Third parties such as browsers used to access our sites and software used to contact our Company as well as social networks that you use in connection with our Sites may also collect, use, and share information about you. This Policy does not cover such third parties or their services and we do not take any responsibility for how such third parties may use any information they collect. For information about third-party privacy practices, please consult with them directly.

BRIEF OVERVIEW

Information We Collect: We may collect your personal contact information in order to promote legal second citizenship. We are required to collect personal biodata, proof of identity documents, financial records and medical records in order to comply with the requirements of applying for second citizenship, on the signing of a contract with our Company.

How We Use Your Information: We may use your information to provide services, respond to and fulfill your requests, operate and market our Sites, comply with applicable law, and as otherwise permitted by applicable law.

How We Share Your Information: We may share your information with Government Units and service providers who require your information in order to fulfil a requirement relating to the processing of your citizenship, once a contract is signed between you and our Company and limited to a clear objective related to processing your citizenship application, as otherwise consented to by you or as permitted by applicable law. Under certain circumstances, we act as the data processor of your information. We will never share any of your data with an external marketing or soliciting entity.

Security of Your Information: We maintain commercially-reasonable technical, administrative, and physical security measures designed to protect your information.

Cookies and Other Tracking Technologies: We may use cookies and similar technologies to help provide our Sites the ability to offer you a more personalized user experience and market our own related products and services to you. Our Cookie policy is available here for your review.

Your Choices: You can opt out of receiving marketing communications from us by emailing us at [email protected] with the subject “Opt out of Marketing Communication”

Access and Correction of Your Information: We provide you the opportunity to access, correct and update your information by emailing us on [email protected] with the subject “Access my Information”

International Transfers: We are regularly required to transfer your information outside of your home country in order to facilitate your citizenship application. To protect your information, any such international transfers will be made in accordance with applicable law.

Changes to This Policy: You will be notified about any material changes to this Policy via a posting on our Sites, and as otherwise required by applicable law.

Contact Us: If you have questions about this Policy, please contact us.

I. INFORMATION WE COLLECT

Personal Information. By visiting or using our Sites, we may collect the following categories of personal information ("personal information ") you provide to us: name; email address; and phone number (including your mobile phone number and country code). In the course of processing your citizenship application such as billing information; photos of you, financial and medical records, documented travel history, criminal history in the public record, physical address as shared and obtained solely from you and contracted due diligence services such as “World Check”.

Device Information. When you visit our Sites or open communications (such as emails) , some information is automatically collected from devices (e.g., mobile, computer, laptop, tablet) used to visit or use our Sites including, but not limited to, operating system, access times, browser information (e.g., type, language, and history), settings, and other data about your device that we use to provide the services or as otherwise described in this Policy (" device information"). We also collect information about your usage and activity on our Sites using certain technologies, such as cookies, web beacons and other technologies.

Location Information. If you use our Site, we may receive your generic location (such as city or neighborhood) or, with your consent, precise geographic location data from your mobile device when the app is running and when it is not running.

Personal information, device information, and location information are collectively referred to as "your information."

II. HOW WE USE YOUR INFORMATION

We may use your information to provide services, respond to and fulfill your requests, operate and market our Sites, comply with applicable law, and as otherwise permitted by applicable law.

Electronic Communications. Consistent with the above Purposes, we may communicate with you via electronic messages, including email, text message, or mobile push notification to, for example: send you information relating to our products and services, or updates on your application. We believe in a no spam policy and will only communicate news that we believe to be of genuine use and interest to our clients and contacts, which includes topics relating to investing in second citizenship and relevant policy and price updates from the Government Citizenship by Investment Units. We may also share information about our company that may be important for our clients.

Our Role as Data Controller and Data Processor. We generally act as the data controller of your information; however, Government Units and their contracted service providers will be required to process some of your data. External service providers such as legal translation service providers, attestation service providers and other related service providers may have to access to and be required to process your personal data. We are not responsible for how they may use your data.

Aggregated Information. We may aggregate personal information collected from you and other users as well as device information and location information to produce general statistics that cannot be linked to you or any other specific user and with which we attempt to provide you with a better experience, to improve our services, and to analyze and understand how our Sites and products are used.

Retention. We will retain your information for the period necessary to fulfill the Purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.

III. HOW WE SHARE YOUR INFORMATION

a. Information Shared Government Units and Other Service Providers

We may share your information with Government Units and service providers who require your information in order to fulfil a requirement relating to the processing of your citizenship, once a contract is signed between you and our Company and limited to a clear objective related to processing your citizenship application, as otherwise consented to by you or as permitted by applicable law. Under certain circumstances, we act as the data processor of your information. We will never share any of your data with an external marketing or soliciting entity.

Government Units and their contracted service providers will be required to process some of your data. External service providers such as legal translation service providers, attestation service providers and other related service providers may have to access to and be required to process your personal data.

b. Information You Share Socially

Our Sites may allow you to connect and share your actions, comments, content, and information publicly or with friends. Please be mindful of your personal privacy needs and the privacy needs of others as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.

c. Other Sharing

We do not share your information with third parties other than as described above and below:

  • We may share information with third-party vendors, consultants, and other service providers who perform functions on our behalf (translation, attestation, courier services, marketing, etc.) We do not authorize these third parties to use your information for purposes other than for which it has been provided, and do not authorize these third parties to disclose that information to unauthorized parties. While we require these third parties to maintain appropriate security to protect your information from unauthorized access or processing, we cannot be held responsible for their actions.
  • We may disclose your information to regulatory authorities, courts, government agencies and other third parties where we believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights, and/or property of PassPro Immigration Services or others, or to respond to emergencies.
  • We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding.
  • We may share aggregate statistical data for the improvement of services offered by our Sites. We may also share aggregated or de-identified information with third parties in our discretion.
  • We may otherwise share your information as directed by you or subject to your consent.

IV. SECURITY OF YOUR INFORMATION

PassPro takes commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

V. COOKIES AND OTHER TRACKING TECHNOLOGIES

We collect information about your usage and activity on our Sites using certain technologies, such as cookies, web beacons, and other technologies. Third parties may also view, edit, or set their own cookies. Our Cookie policy is available here for your review.

VI. YOUR CHOICES

Email. If you do not want to receive marketing and promotional emails from PassPro, you may click on the "unsubscribe" link in the email to unsubscribe and opt-out of marketing email communications or specifically contact us at [email protected] with the subject “Opt out of Marketing Communication”. Please note that even if you opt-out of receiving marketing communications from us, we may need to send you service-related communications, related to processing your application.

Text and WhatsApp Messages. We may use text and WhatsApp Messaging to contact you from time to time. Please note that even if you opt-out of receiving marketing communications from us, we may need to send you service-related communications, related to processing your application.

VII. ACCESS AND CORRECTION OF YOUR INFORMATION

We provide you the opportunity to access, correct and update your information by emailing us on [email protected] with the subject “Access my Information”

VIII. INTERNATIONAL TRANSFERS

We are regularly required to transfer your information outside of your home country in order to facilitate your citizenship application. To protect your information, any such international transfers will be made in accordance with applicable law.

IX. CHANGES TO THIS POLICY

Except to the extent limited by applicable law, we reserve the right to update this Policy to reflect changes to our information practices by prominently posting notice of the update on our Sites, and as required, obtaining your consent. Any updates will become effective immediately after posting the updates to this Policy and apply to all information collected about you, or where required, upon your consent. You agree that you will review this Policy periodically. If we make any changes to this Policy, we will change the "Last Updated" date above. You are free to decide whether or not to accept a modified version of this Policy, but accepting this Policy, as modified, is required for you to continue using our Sites. If you do not agree to the terms of this Policy or any modified version of this Policy, your sole recourse is to terminate your use of our Sites.

If we make any changes to this Policy that materially impacts previously collected information about you, we will obtain your prior express consent.

X. CONTACT US

If you have any questions about this Policy or information we have collected about you, please contact us by email at [email protected]

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