Privacy Policy

Effective Date: June 10, 2024

This Privacy Policy applies to CIBT Inc., CIBTVisas, Entriva, Newland Chase, Newland Chase Education, Blair Consular, our subsidiaries and affiliates, and any Services that link directly to this Privacy Policy (collectively, “CIBT”, “we”, “our”, or “us”). We are committed to providing our customers with excellent service. As part of this commitment, we take the trust our customers and site visitors place in us very seriously. We recognize that it is our responsibility to inform you of our personal information collection practices through our Privacy Policy. Our Privacy Policy outlines:

Privacy Policy

1. The Personal Information We Collect
2. How Personal Information Is Used
3. How We May Disclose and Transfer Personal Information
4. Compliance with the EU and Swiss Data Privacy Framework
5. Cookies and Tracking Technologies
6. Your Choice
7. Privacy Notice for California Consumers
8. Other State Privacy Rights
9. Security
10. Data Retention
11. How to Opt-Out of Further Communication
12. Links to Other Websites
13. Personal Information from Children
14. Additional Information for Individuals Located in the EEA/UK
15. How to Contact Us
16. China Addendum
17. Canada Addendum

We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the beginning of this Privacy Policy.

In some instances, we are engaged directly by travel partners, corporations, or business groups, including your employer, which results in our processing of personal information on the behalf of such travel partners, corporations, or business groups. In these circumstances, you should address any concerns regarding the processing of your personal information directly with the party with whom you have a primary relationship, where applicable.

If you are a resident of California, certain U.S. States, China, or Canada, you may have certain specific rights in connection with your personal information: please refer to the section or addendum relevant to your jurisdiction of residence for further information.

We have designated a Privacy Officer who is responsible for our compliance with this Privacy Policy. The Privacy ‎‎Officer may be contacted as described below in section 14.‎

1. The Personal Information We Collect

Our suite of services includes travel, tour, flight, and hotel bookings; travel protection and insurance services; passport, travel visa, driving permit and document assistance; background checks and clearance forms; immigration services; and travel information.

Personal Information We Collect Directly. By using our websites, apps, and/or our services (“Services”), we may collect and request information, including personal information, which includes your name, address, telephone number, date of birth, marital status, government IDs such as birth certificate, driver’s license or passport images or numbers, employment history, educational background, tax status, employee number, job title and function, expatriate status, e-mail address and payment and transaction information. We may collect this information from you directly (e.g., form consumer surveys), or, with your consent or when permitted by applicable law, other parties such as your travel agent; family, friends, or travel companions; government agencies; trip providers (e.g., accommodations and transportation services, attractions and tour providers, travel insurance companies, or other booking companies); and/or your employer. Where required for the Services, we collect certain personal documents such as passport copies, educational documents, CVs, visa copies, birth certificates, and other documents.

Personal Information We Collect Automatically. Other information we collect automatically from your device, which may be considered personal information in your jurisdiction, or from third parties may include the following, such as:

• Unique IDs such as a cookie placed on a computer or advertising IDs;
• Internet Protocol address (“IP address”);
• Information about a device such as information contained in HTTP headers or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings, and information about or from the presence or use of “apps” on mobile devices; or
• Publicly available information about you.

Sensitive Personal Information. If, for instance, we are handling your visa or immigration matter, additional information may be requested by the application forms of the destination country. These additional items can include items such as your personal and family information, educational background, employment history, travel history, and financial records. If required by relevant visa or governmental authorities, additional sensitive information can include ethnicity, race, religion, trade union membership, health related information, and information about criminal history where permitted by law.

2. How Personal Information Is Used

We may use your personal information in the following ways and for the following purposes based on the specific Services and/or your or your agents’ interaction with us, including, for example, to:

• Create an Account: You may create an account on certain of our Services including on our websites and apps. The type of personal information that we collect from you varies, but includes, at a minimum, your name and contact information.
• Providing our Services, Including Visa Services: When you or your agent obtains Services or makes a purchase from us, including requesting visa services, we will collect your name, billing and shipping addresses, email, phone number, payment card information (which is processed through our payment processor), and items or Services purchased. When we assist you with obtaining a visa, our collection and use of your personal information is dependent on the requirements of the country issuing the visa so our practices may vary.
• When you Book with us: You can book a variety of vacation or holiday services and accommodations as well as additional specific services. If you enquire about a booking, by telephone, email, chat or in any other way, we process the necessary personal information to be able to provide you with suitable offers and Services. If you book through our properties, we collect and process the necessary personal information for the conclusion of the contract, the implementation of your booking and for additional support. This also includes the transfer of your personal information to the respective providers of the booked services.
• When you Upload Photos. When using our Services to apply for or obtain a visa or for other travel purposes, we may need to collect an image of you. We use these images to provide our Services.
• Sign Up for Information or Marketing: We collect your name and contact information if you sign up receive information or marketing from us.
• Post to our Services or Our Social Media Pages: You may post, or grant us permission to post, your photos, reviews, ideas or other content to our Services, as indicated, and on our social media pages.
• Communicate with You: We collect personal information about you when subscribe to newsletters or when you otherwise communicate with us. This includes your name, contact information, and scope of your inquiry. We may also use your email address to send you reminders of expiring visas, passports, or immigration status. If you would like to discontinue receiving this information, see the How to Opt-out of Further Communication section below. Calls to our call center may be recorded for quality assurance, security, and training purposes.
• Participate in Promotions: If you participate in a promotion or sweepstakes, then we will collect the personal information that you submit as part of your entry. We may offer promotions or sweepstakes in connection with other entities, and, in some cases, our promotions or sweepstakes will be governed by additional or different privacy notices. We will notify you at the time of collection if your personal information is subject to an additional or different policy. Some jurisdictions require us to post personal information of winners.
• Interact at Events: We collect personal information from you that you choose to provide to us at virtual or in-person events (e.g., to our employees or other representatives). We collect the personal information that you choose to provide to us, which may include, for example, your contact information and information about Services you may be interested in obtaining.
• Administration: for administrative purposes, including to manage our inventory; to help us better understand how our customers access and use our Services, including the pages viewed, ad impressions clicked, or other Services activity; to maintain security and operability of our Services (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you, others and us; to enforce this Privacy Policy, our Terms of Use, and other policies.
• Research and Development/Analytical Purposes: for research and development purposes, including to improve our Services, products, and customer experience; to understand what parts of our Services are most popular or to improve upon our products and Services; to understand our customer demographics; and for other research and analytical purposes.
• Legal compliance: to comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.
• Protection of you, us and others: where we believe it is necessary to protect you, us and others, including, without limitation to detect, prevent, and respond to fraud, security incidents, or other issues where we believe it is appropriate to protect us and others.
• Work with our Trip Providers: For example, we may partner with an airline, hotel, school, association, corporation, travel agency or credit card company to provide Services to their members or frequent travelers. Please review our partner’s privacy policy for their privacy practices.
• Follow-Up Services: In many instances such as visa extensions, permanent residency, and other cases related to changes in employment, the Services we provide require follow-up services. If such follow-up is required, the information we have collected previously is used to provide the additional related Services for which we have been engaged.
• Other uses: that we notify you of or that you may consent to.

3. How We May Disclose and Transfer Personal Information

We may disclose and transfer personal information we collect for the purposes described above, and to service providers and third parties as follows:

• Affiliates and Subsidiaries. To support and provide the Services including, as applicable, to process trip and booking requests, complete your visa, document legalization, or immigration process request as necessary to provide visa and immigration services to you and your family. This may include providing sensitive data required for an immigration process request to visa application centers, logistics companies, and/or translators/solicitors. We may also disclose certain information to improve our products and services, provide superior customer service, and identify market opportunities.
• Vendors and Service Providers. To our service providers, processors and others who perform functions on our behalf. These may include, for example, IT service providers, help desk, chatbots, analytics providers, and consultants. Additionally, we may share images you have uploaded with image review vendors to enable more efficient processing of your images for visa and travel purposes.
• Trip Providers. To support and provide the Services, including to help you book accommodation, travel, tourist attractions, tours, and to enable or facilitate entry requirements as may be required, including invitation providers to secure official invitations related to visa applications or entry requirements, and background check providers as required by the destination country.
• Business Partners and Third Parties, Including Third-Party Platforms, Providers, and Networks. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes. We also share information to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also (and, where required by applicable law, with your consent) make certain information (such as browsing information) available to third parties in support of our marketing, advertising, and campaign management.
• Travel Companions (e.g., Friends and Family). To support and provide the Services, including if you or your friend/family member organize group trips.
• Government Entities. To support and provide the Services, including as necessary for visa applications, immigration services, and logistics purposes. Sensitive data may be disclosed as necessary.
• Customers and Clients. To support and provide the Services, including if we are providing services on behalf of a business.
• To Others As Required by Law. We may also disclose personal data to third parties to the extent permitted by applicable law and legal obligations. This may include regulators, government entities, and law enforcement as required by law or legal process, subject at all times to obligations under relevant laws. In addition, it may include certain disclosures that we are required to make, such as the names of sweepstakes and contest winners.

We may also disclose your personal information in the following circumstances:

• In Support of Business Transfers – If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and act in response to violations of our Terms of Use. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may, to the extent permitted by applicable law, use, disclose, and otherwise process aggregate and deidentified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes.
• Other Disclosures. We may disclose personal information in other ways not described above, including as required or permitted by applicable law. If necessary, we will notify you and, if necessary, obtain your consent.

4. Compliance with the EU and Swiss Data Privacy Framework

CIBT Inc. (as well as the entities listed above) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. CIBT has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. CIBT has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit: https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, CIBT commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, CIBT commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact CIBT at: [email protected].

Additional information in support of the Data Privacy Framework:

• By complying with the Data Privacy Framework, CIBT is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
• We may disclose information related to the transactions we perform for you to third parties. We contractually commit any third-party organizations that we engage with to the same level of protection as we follow. Your data is only used for the specified purpose. If for any reason it is determined that the third party cannot meet these obligations, then the contract is terminated. The current third parties, the reason for their use and the company information are listed in the following link: https://corporate.cibt.com/security-documentation/.
• You may access your data by using the web site(s) with your credentials or make a request to [email protected].
• You may restrict the use of your data for marketing purposes by sending an email to [email protected].
• Under certain conditions, you may invoke binding arbitration. CIBT is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles. The International Centre for Dispute Resolution®-American Arbitration Association® (ICDR-AAA®) was selected by the U.S. Department of Commerce to administer arbitrations pursuant to the arbitral fund identified in Annex I of the DPF Principle, provided that you have invoked binding arbitration by delivering notice to CIBT and following the procedures and subject to conditions set forth in Annex I of Principles.
• In the event of a lawful request from public authorities, you may be required to disclose personal information in response to that request to meet national security or law enforcement requirements.
• We remain responsible for all the personal information we receive under the DPF and that we subsequently transfer to third parties acting as agents on our behalf if they process personal information in a manner inconsistent with the DPF principles.

5. Cookies and Tracking Technologies

We and our providers use cookies, pixel tags, and other similar tracking mechanisms to automatically collect personal information about browsing activity, type of device, and similar information within our Services. We use this personal information to, for example, analyze and understand how you access, use, and interact with us through our Services; to identify and resolve bugs and errors in our Services; to assess, secure, protect, optimize, and improve the performance of our Services; for marketing, advertising, measurement and analytics purposes; and to personalize content in our Services. We may also aggregate personal information to analyze trends, administer our Services, and gather broad demographic information.

Cookies. “Cookies” are alphanumeric identifiers we transfer to your device’s hard drive through your web browser for tracking purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within the Services.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.

Third Party Analytics. We use third party tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Services. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Services to provide us with reports and metrics that help us evaluate usage and improve our Services and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to manage how your personal information is used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Tracking. We and our providers may use the personal information we collect about you within our Services and on other third-party websites and services to help us and other third parties identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Services.

Third-Party Advertising. We work with third-party ad networks, analytics, marketing partners, and others (“third-party ad companies”) to personalize content and display advertising within our Services as well as to manage our advertising on third-party sites. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information within our Services (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other online identifiers. We and these third-party ad companies use this personal information to provide you more relevant ads and content within our Services and on third-party sites, and to evaluate the success of such ads and content.

Do Not Track. Currently, our Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed below (e.g., by disabling cookies).

Development of new and improvement of existing technologies. We process the necessary data as part of the development of new technologies and the improvement of existing technologies in order to improve our services and set new standards in the area of data protection and information security. This includes in particular the areas of machine learning, artificial intelligence, and deep learning. In doing so we only use pseudonymized or aggregated data as far as technically possible.

6. Your Choices

You have certain choices regarding the personal information we collect about you. For example, you may:

• Opt Out of Promotional Email Communications. You may opt out of promotional emails by clicking on the unsubscribe link in the email. To opt-out of further communications, contact us by email at [email protected].
• Opt Out of Interest-Based Advertising. We use third party providers to help us provide advertisements to you that are tailored to you based on interests that you have expressed on our Services or elsewhere (“Interest-Based Ads”). Any tracking done by third parties ad partners through cookies and other mechanisms are subject to those parties own privacy policies. You may manage Google cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en.

  You also may opt out of receiving Interest-Based Ads from many third-party ad networks, such as those provided by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding Interest-Based Ads by NAI members and DAA members, including how to opt out of Interest-Based Ads provided by NAI and DAA members, please visit their respective websites: optout.networkadvertising.org and optout.aboutads.info.
  You must opt out on each browser and on each device.

• Industry ad choice programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you.
• U.S. Users: you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device.
• EU Users: youronlinechoices.eu (European Interactive Digital Advertising Alliance)
• Canada Users: youradchoices.ca/choices/ (Digital Advertising Alliance of Canada)
• Japan: http://www.ddai.info/optout (Data Driven Advertising Initiative in Japan)

Please note that opting out of participating ad networks does not mean that you will not see advertisements at all, and you will continue to receive advertisements on other websites and from companies that do not participate in the above programs. Even if you opt out of interest-based ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type and recent, previous searches related to your current search.

Please note that even if you opt out of receiving marketing communications from us, we may still send you communications about your account or any products or services you have purchased from us and we will still respond to your inquiries and requests for information.

Mobile Device Settings. In addition to the above, some of our apps may include third-party advertising and analytics. For iOS devices, you can turn off “Allow Apps to Request to Track” setting (go to Settings>Privacy> Tracking). For Android devices, turn on “Opt out of Ads Personalization” setting (go to Settings>Privacy>Tracking and select/toggle on Opt out of Ads Personalization). In addition, our apps may include analytics and related personalization that you can opt out of through an in-app settings for that app (you can access this setting from the main menu).

7. Privacy Notice for California Consumers

Last Updated: May 26, 2023.

This Privacy Notice for California consumers supplements our Privacy Policy and applies solely to California consumers.

This Privacy Notice uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (the “CCPA”). Consumers with disabilities may access this Statement in an alternative format by sending an email to [email protected].

Notice of Collection and Use of Personal Information

We may collect and use (and have collected in the previous 12 months) the following categories of personal information about you as described below.

• Personal Identifiers such as a real name, alias, postal address, images of your face, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. We may obtain this information from (1) you, when you use our website and social media platforms or otherwise communicate with us; (2) publicly available databases; (3) joint marketing partners and event sponsors, when they share the information with us; and (4) referral sources. We may share this information with vendors who provide services on our behalf, such as to provide our products and services to you and manage our relationship with you.
• Information necessary to provide our products and services to you such as order information and payment, credit and transaction information for billing purposes. We may obtain this information from you and share it with vendors who provide services on our behalf, such as to provide our products and services to you and manage our relationship with you.
• Commercial information including products or services purchased, obtained or considered; and other purchase histories or tendencies. We may obtain this information from you and share it with vendors who provide services on our behalf, such as to provide our products and services to you and manage our relationship with you.
• Internet and other electronic network and app activity information such as browsing history, search history, and information regarding your interaction with an internet website, application or advertisement. We may obtain this information from you and through the use of website or app cookies and web beacons. We may obtain this information from you and share it with vendors who provide services on our behalf, such as to provide our products and services to you and manage our relationship with you.
• Geolocation information. We may obtain this information from you and your devices through various location technologies (such as GPS) and share this information with vendors who provide services on our behalf, such as to provide products and services to you based on your geographic location.
• Professional, employment-related, and educational information. We may obtain this information from you, employment recruiters and referral sources when you apply for a job with us or become employed by us. We may use and share this information with vendors who provide services on our behalf, such as to manage our human resources activities or perform background checks.
• Sensitive Personal Information. Additional sensitive information can include social security number, driver’s license number, passport number or other similar identifiers, ethnicity, race, religion, trade union membership, health related information, biometrics, government identifiers, precise geolocation, and information about criminal history.
• Inferences drawn from any of the categories of personal information listed above to create a profile about you regarding your preferences, characteristics, psychological trends, predispositions, behavior attitudes, intelligence, abilities and aptitudes. We may develop these inferences internally or obtain this information from vendors who provide services on our behalf, such as to us with our business.

Sale and Sharing of Personal Information. Additionally, the CCPA defines “sale” as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” means disclosing or making available Personal Information to a third party for purposes of cross-contextual behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may disclose the following categories of Personal Information: identifiers, profiles and inferences, and internet or other electric network activity information to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not knowingly sell or share any Personal Information about individuals who we know are under sixteen (16) years old.

Sources of Personal Information. We collect personal information from the following sources: directly from you; advertising networks; data analytics providers; social networks; internet service providers; operating systems and platforms; your friends; affiliated entities; partners (e.g., if we offer a joint promotion); and government entities.

Sensitive Personal Information. Notwithstanding the purposes described above, we do not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require CIBT to provide a right to limit under the CCPA.

Purposes for Collecting and Disclosing Personal Information. We may use the categories of personal information listed above for the purposes described in our Privacy Policy in Section 3. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described below:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, processing images to verify usability, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, providing storage or providing similar services.
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use,
• Providing advertising and marketing services.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance the service.

California Consumer Privacy Rights

The CCPA provides you with certain rights regarding your personal information. This section describes those rights and how to exercise them. Please note that these rights are subject to certain conditions and exceptions. As noted above, we provide Services to other businesses, which may mean that you need to contact the business with whom you have a primary relationship to exercise these rights. Where we believe this is the case, we will notify you.

Right to Know/Request Access. You have the right to know:

• The categories of personal information we collected about you;
• The categories of sources from which we collected your personal information;
• The business or commercial purposes for collecting, selling, or sharing your personal information;
• The categories of third parties to whom we have disclosed your personal information; and
• The specific pieces of your personal information we have collected.

Right to Delete. Subject to certain conditions and exceptions, you have the right to request we delete your personal information.

Right to Correct. Subject to certain conditions and exceptions, you have the right to request that we correct inaccuracies in your personal information.

Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA, including using an opt-out preference signal. While we do not “sell” personal information in the traditional sense (i.e., for money), our use of third-party analytics and advertising cookies may be considered “selling” and “sharing” under CCPA.

To exercise your right to opt-out of the “sale” or “sharing” of your personal information, please click here or use the Do Not Sell or Share My Personal Information link in the footer of our website.

We honor your right to opt out of “sales” or “sharing” as signaled by a universal opt out signal or Global Privacy Control (“GPC”). To learn more about GPC, you can visit the Global Privacy Control page at https://globalprivacycontrol.org. If you download a supported browser or extension and exercise your privacy rights with GPC, third-party advertising cookies on our website will be blocked once our website detects a GPC signal. If you visit our Services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Authorized Agents. You may designate someone as an authorized agent to submit requests and act on your behalf.

To submit a request, please do so by emailing [email protected] or calling us at: 1-800-929-2428.

To help protect your privacy and maintain the security of your personal information, we will take steps to verify your identity. If you request access to your personal information, we may require you to log into your account or provide any of the following information: contact information, one-time password, information about your interactions with us or information that you have submitted.

If you designate an authorized agent to make a request, we will require your authorized agent to provide us with your written authorization permitting the authorized agent to request access to your personal information on your behalf, and we also will require you to verify your own identity directly with us.

In connection with your request, you must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Financial Incentives

A business may offer “financial incentives” (as defined by the CCPA) for the collection, sale or deletion of California consumers’ personal information, provided the incentive is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California consumers have the right to be notified of any financial incentive offers and their material terms, the right to opt-out of such incentives at any time and may not be included in such incentives without their prior informed opt-in consent. From time to time, we may offer free shipping or other incentives (such as a discount if you sign up for email marketing from us). We will notify you of the incentive at the time of offer.

8. Other State Privacy Rights

Residents of certain U.S. states may have additional rights under applicable privacy laws, subject to certain limitations and exceptions. These rights may include:

• Right to Access/Know. To confirm whether we are processing your personal data and to access such personal data and obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format.
• Right to Correct. To correct inaccuracies in your personal data.
• Right to Delete. To delete personal data provided to or obtained about you.
• Rights to Opt-Out/Respond to GPC. To opt out of certain types of processing, including:
  • if applicable, to opt out of the sale of their personal information.
  • to opt out of our use of their personal information for purposes of targeted advertising.
  • If applicable, to opt out of our processing of personal information for purposes of making decisions that produce legal or similarly significant effects.
• Right to Appeal. If we deny your request, you may appeal our decision by contacting us at [email protected] or (ii) calling us at: 1-800-929-2428.

You may submit a request to exercise your applicable state privacy rights by contacting us at [email protected] or calling us at: 1-800-929-2428.

9. Security

We have implemented safeguards that are intended to protect the personal information that we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
There are also certain steps you can take to better protect against unauthorized access to your personal information. For example, you should choose a strong password that is unique to the Services (and do not reuse passwords across multiple sites and services or share your password with others). If you believe that your password or account has been compromised, please reset your password, and promptly notify us at [email protected].

10. Data Retention

We will retain and use your personal information as long as is necessary for the purposes described above or otherwise disclosed to you at the time of collection, to comply with our legal obligations, government auditing requirements, resolve disputes, and enforce our agreements (including those agreed with our clients).

11. How to Opt-Out of Further Communication

We provide users the opportunity to opt-out of receiving marketing communications from us at their request. To opt-out of marketing communications, contact us by email at [email protected] or click on the unsubscribe link at the bottom of the email.

12. Links to Other Websites

This site may contain links to other sites. We are not responsible for the privacy practices or the content of such sites. We encourage you to read the privacy policies of these sites before transmitting any personal information to third parties.

The website may include social media features, such as the Facebook Like button and widgets, such as the “Share this” button or interactive mini-programs that run on the website. These features may collect your IP address, which page you are visiting on the website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the website. Your interactions with these features are governed by the privacy policy of the company providing it.

13. Personal Information from Children

We do not knowingly collect personal information from children. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission. If we learn we have inadvertently received personal information from a child, we will delete such information from our records. If you are a parent of a child and believe we have collected your child’s information, contact us at [email protected].

14. Additional Information for Individuals Located in the EEA/UK

Lawful Basis for Collecting Personal Information: We collect and process personal information in order to fulfill your visa, passport, document legalization, or immigration process request and our contract with you. This information is collected and processed in accordance with local laws including GDPR regulations in the European Union, United Kingdom and Switzerland. For those individuals to whom the GDPR applies, general personal information is collected and processed on the basis of the contract formed or to be formed between us, but any additional sensitive personal information is collected and processed under the lawful basis of consent. By placing the order and, where necessary and permissible, giving your consent, you are giving us the following rights:

• The right to collect your personal information
• The right to process your personal information
• The right to share your personal information with third party providers and government entities as needed, such as Government Authorities, Visa Application Centers, Logistics Companies, Invitation Providers and/or Translators/Solicitors relevant to your request for services.

You maintain the right to revoke consent at any time by emailing [email protected].

The Right to Have Your Personal Information Corrected, Amended or Deleted: At any time, you have the right to request that we request a correction or amendment of your personal information. You also have a right to request that we erase the personal information you have provided to us. We will erase any personal information as long as it is legally allowed to according the laws and regulations in the countries in which we operate. In lieu of emailing us, go to this link, https://cibtvisas.com/right-to-erasure. The following will then occur:

• We will acknowledge your request.
• We will review your specific request and the country of its origin, and determine if we are lawfully allowed to oblige the request.
• We will then either:
  • inform you that your personal information has been removed from our systems; or
  • inform you as to the date that we are legally allowed to remove said personal information from our systems given the nature of the personal information and the country of its origin.

The Right to Access Your Personal Information: At any time, you have the right to access a copy of your personal information held by us.

The Right to Restrict Your Personal Information: You have the right to request that we restrict processing of your personal information, if you contest the accuracy of your Personal Information or the lawfulness of how we process of your personal information.

The Right to Portability of Your Personal Information: You have the right to receive your personal information in a structured, commonly-used and machine-readable format. You also have the right to transmit your personal information to another organization.

The Right to Object to Processing of Your Personal Information: You have the right to object, on grounds relating to your particular situation, to how we process your personal information, unless we demonstrate compelling legitimate grounds for continuing such processing. You also have the right to object to any automated decision-making (such as user profiling).

The Right to Withdraw Consent to Processing of Your Personal Information: In instances where you have provided your consent for us to use your personal information, you can withdraw your consent at any time with future effect. You can do so by contacting us directly at [email protected].

These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority where you reside, where you work or where you believe there has been an infringement of data protection laws.

International Transfer of Your Personal Information: Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. By using our Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Some of the non-European Economic Area countries are recognized by the European Commission, the UK and Swiss data protection authorities as providing an adequate level of data protection according to EEA, the UK or Swiss standards (the full list of these countries is available here). For transfers from the EEA, the UK or Switzerland to countries not considered adequate by the European Commission, the UK or Switzerland, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission or contracts approved by the Swiss Commissioner, to protect your personal information.

Complaint to Supervisory Authority:

UK: If you consider that we have breached your rights under UK GDPR you may complain to the data protection authority in the country in which you reside or to the lead supervisory authority at https://ico.org.uk/concerns/ or by phone at +44 303 123 1113.

EU: If you wish to lodge a complaint about our data privacy practices with a regulatory authority in your country, you can find details at this link: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

Switzerland Individuals in Switzerland should contact the Swiss Federal Data Protection and Information Commissioner (the Swiss Commissioner) for resolution. Information regarding the Swiss Commissioner is located at: https://www.edoeb.admin.ch/edoeb/en/home.html.

Personal Information We Disclose

We may share some of your personal information with our other offices or affiliates to provide you with information that will be relevant to your interests and to connect you with advisors who may be useful to you. For these purposes, your personal information may be processed in, or accessed from, jurisdictions that do not have equivalent data protection laws to those in your country of residence.

We safeguard your data within our group of companies through the use of European Commission-approved standard contractual data protection clauses.

Personal information will be shared with companies providing services under contract to us for the purposes described in this Privacy Policy that may be located in a different country than you. When transferring your personal information, we rely on European Commission-approved standard contractual data protection clauses with service providers or approved binding corporate rules that protect your personal information.

If you have any questions about our information handling practices or if you wish to access your personal information you should contact our Data Privacy Office at: [email protected].

You may have other rights within the EU and UK as well as other locations.

We will retain your personal information only for as long as we need it for the purposes described in this Privacy Policy, after which we will take steps to delete your personal information or hold it in a form that no longer identifies you.

How We Collect Personal Information

We may collect personal information from you in the following ways:

• By Asking: We may collect personal information from you by asking that you provide it to us. We will only collect personal information that is needed to help us provide the Service you request.
• Cookies: We uses cookies to enhance your experience while using our website. Cookies are small text files that reside on your computer to identify you as a unique user. Cookies may also allow us to track your status or progress when requesting our Services or information. We employ third-party cookies to perform functions on our behalf such as data analysis and marketing assistance. This data is used for specific functions that require broad-based user statistics, which help to improve the overall customer experience. If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on the website, or that we may put on the website in the future. We do not respond to web browser ‘do not track’ signals, however we will continue to monitor relevant legislation and policy updates and adjust our ‘do not track’ strategy as required.
• Web Beacons: A web beacon is an electronic file on a web page that allows us to count and recognize users who have visited that page. Among other things, a web beacon can be used in HTML-formatted email to determine responses to our communications and measure their effectiveness. For instance, if you get an email from us and click on a link in that email to go to the website. You can generally avoid web beacons in email by turning off HTML display and displaying only the text portion of your email.
• Web Server Logs: Web server logs are records of activity created by the computer that delivers the webpages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you the webpage. The web server log also may record information about your browser, such as your IP address and the cookies set on your web browser by the server.

15. How to Contact Us

If you have any questions about this Privacy Policy, contact the Data Protection Officer [email protected], CIBT, Inc., ATTN: Data Privacy Officer, 1600 International Drive Suite 600, McLean, VA 22102, or 1-800-929-2428.
More information and related documentation is available here.

16. China Addendum

If you resident in the People’s Republic of China (for the purpose of this Privacy Policy only, excluding Hong Kong, Macau and Taiwan) (“China”), the following clauses apply to our processing of your Personal Information. In case of any discrepancies between this Addendum and the main body of the Privacy Policy, this Addendum shall prevail.

1. Data controller. The data controller who determines the purposes and means of the processing of your Personal Information is: Bill Coquelin, [email protected].
2. Update. If we update this Privacy Policy and the processing activities related to the update require your consent by the applicable Chinese data protection laws, we will use proper mechanisms (e.g. pop up window) to obtain your consent.
3. Sensitive Personal Information. Under the Chinese data protection law, Sensitive Personal Information refers to Personal Information that, once leaked or illegally used, will easily lead to infringement of the human dignity or harm to the personal or property safety of a natural person, including ID card number, biometric recognition, religious belief, specific identity, medical and health, financial account, personal location tracking and whereabout of a natural person, as well as any Personal Information of a minor under the age of 14.
4. How We May Disclose Personal Information. Other than official government offices and recipients in the country to which you intend to travel, we do not disclose your Personal Information to third-parties for their independent purposes and means of processing when we collect your data within China.
5. Your rights to your Personal Information. Subject to conditions and requirements provided by the applicable data protection law, you may have the following rights to your Personal Information:
   • Right to access and request a copy of your Personal Information;
   • Right to rectify or supplement your Personal Information where it is not accurate or complete, after necessary verification;
   • Right to request the deletion of your Personal Information if (i) the purpose of the processing has been achieved or cannot be achieved, (ii) the processing is based on your consent and you withdraw the consent; or (iii) the processing violates any legal requirements;
   • Right to request your Personal Information to be transferred to another data controller, provided that such a request satisfies certain conditions to be set by the data regulator;
   • Where your Personal Information is used for automated decision and we use the decisions to send marketing messages or promotions, right to refuse such processing or request non-customized messages or promotions; and
   • Where your Personal Information is used for automated decision and such decision may cause material impact on your rights or interests, right to refuse to accept any determination that is made merely relying on the automated decision.
6. Personal Information from Children. We do not knowingly collect Personal Information from children under the age of 14. As a parent or legal guardian, please do not to allow your children to submit Personal Information without your permission.

17. Canada Addendum

If you are a resident of Canada, the following ‎clauses apply to our processing of your Personal Information, in addition to those clauses in the main body of the Privacy Policy which are not intended to apply only in specific jurisdictions (i.e. sections 6, 7 and 13). In case of any ‎discrepancies between this Addendum and the main body of the Privacy Policy, ‎this Addendum shall prevail. You may have different rights depending on your province or territory of residence within Canada: please consult the section below relevant to your province or territory of residence.

Unless otherwise allowed by the laws applicable in your province or territory of residence, we will only ‎collect, use, or communicate your personal information with your consent.‎ You are generally not obliged to provide your personal information, however please note that we may be unable to process an application on your behalf or provide certain services to you if you refuse to disclose certain personal ‎information.‎

You have certain rights in relation with your personal information, the particulars of which may vary depending on your province or territory of residence. These include:

• The Right to Withdraw Consent to Processing of Your Personal Information: You have the right to revoke consent to use or communication of your personal information at any time by emailing [email protected]. Please note however that we may be unable to process an application on your behalf or offer you ‎certain services if you withdraw your consent. Withdrawing your consent will not affect the ‎lawfulness of any processing which happened before such withdrawal, nor does it create an ‎obligation for us to delete personal information which we are otherwise allowed or required to ‎retain under applicable law.;
• The Right to Have Your Personal Information Corrected or Amended: At any time, you have the right to request that we make a correction or amendment of your personal information (if we do not correct or amend your information to your satisfaction, we ‎‎will annotate the personal information under our control with a note that the correction was requested ‎but ‎not made‎); and
• The Right to Access Your Personal Information: At any time, you have the right to access a copy of your personal information held by us, and to receive information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. In some situations, we may not be able to provide access to certain personal information; if we refuse an access request, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

If you are a resident of the province of Québec, the following rights are available to you, in addition to the rights identified above:

• The Right to Portability of Your Personal Information: You have the right to receive your personal information in a structured, commonly-used and machine-readable format. You also have the right to request that we transmit your personal information to another organization; and
• The right to de-indexation: You have the right to request, in certain circumstances, that we cease disseminating your personal information or to ‎de-‎index any hyperlink that allows access to that personal information by technological means, if ‎‎such dissemination contravenes applicable law or a court.

These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority where you reside, where you work or where you believe there has been an infringement of data protection or privacy laws.

International Transfer of Your Personal Information:

Your personal information may be communicated, stored and processed outside of your province or territory of residence, in any other province, territory, or country where we have facilities or in which we engage service providers. By using our Services you understand that your information will be transferred to provinces, territories, or countries outside of your place of residence, including the United States, which may have data protection rules that are different from those of your country. Such ‎transfers will only be made in full compliance with all the requirements of applicable privacy laws, and we will ensure that adequate safeguards are in place so that your personal information will receive an adequate degree of protection.‎ However, you acknowledge that your personal ‎information may be processed and stored in foreign ‎jurisdictions and that governments, courts, law ‎enforcement or government or regulatory agencies in the ‎USA, Canada and elsewhere may be able to ‎access or obtain disclosure of your personal information ‎under a lawful order or otherwise through the ‎laws of the foreign jurisdiction, irrespective of the ‎safeguards we have put in place for the protection of ‎your personal information.

Complaint to Supervisory Authority:

If you consider that your privacy rights have been breached and wish to lodge a complaint about our privacy practices, you may raise a concern or file a formal complaint with the Federal Office of the Privacy Commissioner at ‎https://www.priv.gc.ca/en.

If you are a resident of the province of British Columbia, you should contact the Office of the Information & Privacy Commissioner for British Columbia at https://www.oipc.bc.ca/.

If you are a resident of the province of Alberta, you should contact the Office of the Information and Privacy Commissioner of Alberta at https://oipc.ab.ca/.

If you are a resident of the province of Québec, you should contact the Quebec Commission d’accès à l’information at https://www.cai.gouv.qc.ca/.

If you have any questions about our privacy or information handling practices or if you wish to access your personal information, you should contact our Data Privacy Office at: [email protected].