PRIVACY NOTICE
EFFECTIVE DATE: May 1, 2024
________________________________________________________________________________Gilroy Documents Clearing Services and our related affiliates and subsidiaries* (collectively, “Gilroy” or “we”) want to ensure that our clients, employees and any affected data subjects (“you”) are informed about the security and use of the personal information that we receive and process on your behalf. We are committed to continual improvement of our privacy program, standards and compliance, both locally and globally.
Accordingly, this Privacy Notice (“Privacy Notice”) is intended to inform you about Gilroy’s privacy practices. It describes the types of personal information we collect, how we may use that information, with whom it may be shared and the measures taken to ensure its security.
In addition, we provide information on how to contact us to: (1) exercise your right to object to the processing of certain aspects of your personal information in accordance with applicable laws; (2) access, correct, or delete your personal information; (3) ask any questions you may have about our privacy practices.
In some instances we are engaged directly by corporations or business groups, which results in the processing of employee information at their request. Where we refer to “employer” below, it is in these circumstances where corporations or other business groups have engaged us to act. You may at any time, if you prefer, address any concerns directly to your employer, where applicable.
________________________________________ ________________________________________Personal Information We Collect and How We Use It
________________________________________ ________________________________________PERSONAL INFORMATION WE COLLECT ABOUT YOU
Gilroy collects certain personal information about you and, if required, your family members and employer for the purposes of providing immigration consulting and legal services. We will not be able to provide the services requested if we are not provided with all relevant personal information. Below are set forth the purposes for which personal information is used and examples of the types of information that may be required. If, through the course of our representation, you and/or your employer request additional services, such as [visa extensions, permanent residency applications and changes in employment], we may be required to collect additional types of personal information to provide the requested services.
CLIENT SERVICES
For purposes of providing client services, including the applicable legal services, and/or immigration consulting services you and/or your employer request, Gilroy collects and processes personal information such as name, address, telephone number, date of birth, marital status, passport number, employment history, educational background, tax status, employee number, job title and function, and expatriate status. Where required for the service, Gilroy collects certain personal documents such as passport copies, educational documents, CVs, visa copies, birth certificates, and other documents.
We obtain the personal information from a number of sources, such as through our online portals, our mobile website or applications, online questionnaires and forms you complete, and other information you provide directly to us, including by email or in conversation with our lawyers, consultants and staff. In addition, we obtain personal information from third-party sources, such as former employers, educational institutions you attended, relocation companies, and your current or prospective employer. We use this information to provide immigration consulting and legal services, including analyzing, completing and processing immigration, visa and related filings and submissions to relevant government agencies, providing legal and consultative advice as to eligibility to obtain immigration benefits, and assisting with relocation and other expatriate issues. 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.
We also use your personal information in other instances in connection with the services we provide. This use occurs only when there is a legitimate interest to do so that is not overridden by your data protection rights as required by law, such as assisting in the management and administration of our clients’ global mobility programs (such as visa expiration tracking, immigration program compliance, etc.), providing access to online case-management tools, where applicable, and analyzing immigration trends, such as visa processing times and government approval rates. Where we are engaged by your employer, we process your personal information because it is in our legitimate interests to do so in order to fulfill our contract with your employer for client services.
In addition to providing you or your employer with our services, we process personal information to comply with our legal and regulatory obligations including record-keeping requirements. For example, we process personal information under “know your customer”, anti-money laundering regulations, anti-bribery regulations and professional regulations.
INFORMATION REQUESTS
If you request information about our services directly, you may choose to provide personal information such as your name, address, email address and telephone number. We use your information to respond to your request.
OTHER USES OF INFORMATION
Where it is in our legitimate interests and not outweighed by your data protection rights, we use personal information we collect and process for client and Gilroy administration, compliance audits, compliance with Gilroy policies and procedures, ensuring the security and integrity of our services and in ensuring that our IT systems function effectively.
In addition, we process your personal information with your consent, such as when we use your contact details to respond to a request or question by you, or where required by law.
________________________________________ ________________________________________SENSITIVE PERSONAL INFORMATION
________________________________________ ________________________________________IMMIGRATION SERVICES
Governments worldwide require the collection and processing of a wide variety of personal information from foreign nationals seeking to enter the country and obtain immigration benefits such as employment authorization or residency status. Governments require this information for reasons such as the protection of borders, health, sovereignty, national security, and the regulation of the local employment market. Certain categories of personal information may be considered “sensitive” and are subject to a higher level of data protection. These categories may include race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation, physical or mental health or condition, data relating to offenses and/or criminal convictions, and biometric data, such as fingerprints, when used to uniquely identify you.
INFORMATION WE COLLECT BY AUTOMATED MEANS
We use cookies and related technologies on our websites and other web-based interfaces, such as Gilroy Mobility, employer-specific Immigration Home Page Applications, our mobile website and applications. We use these technologies to understand how many users visited our sites and the pages they accessed so that we can best tailor our web services to our visitors.
COOKIES
Cookies are small text files that are placed on your computer’s hard drive when you visit certain websites that help collect data. We may use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify site features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site.
Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies, you may not be able to take advantage of all our website features.
LOG FILES, USAGE DATA AND IP ADDRESSES
Log files are web server files (containing information such as domain name or IP address, URL, http response code, or the date and duration of your visit) that are automatically created when an Internet user visits a website. An IP address is an identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our website, our servers log your IP address. In combination with other data, this information helps us understand which features are of interest to our visitors and the regions of the world where these visitors are located. In addition, log files help detect disruptions that may interfere with the provision of our website.
INFORMATION WE SHARE
We will not sell, share, transfer, rent, use, or distribute your information for purposes other than those disclosed here unless required by law or as authorized by you or your employer. We share the information you provide among our subsidiaries, affiliates and your current or prospective employer or a third party as your employer instructs us, as appropriate or necessary in connection with the services (such as your employer’s relocation provider, or to protect the interests of any person, where permitted by applicable law. Where our services are retained by your employer on your behalf, we share your personal information as instructed by your employer, for tax purposes, to assist you in obtaining relocation services, and for any other purpose required to provide the services as permitted by applicable law.
In addition, as part of the immigration consulting and legal services we have been directed to provide, Gilroy discloses personal information to government agencies, your former, current, or prospective employer and its related entities. In order to obtain immigration benefits on your or your employer’s behalf, we will disclose personal information to government agencies and immigration authorities.
We also share the information with certain service providers we have retained in connection with the services we provide, such as translators, education evaluation services, couriers, or other necessary entities. We take steps to require that service providers protect the information consistently with this Privacy Notice. These service providers are authorized to use the information only as necessary to perform services on our behalf or to comply with law or legal process. Where we have knowledge that a service provider processes your personal information in a manner contrary to this Privacy Notice, we will take reasonable steps to prevent or stop the processing. In addition, we will disclose information about you: (1) if we are required to do so by law or legal process, (2) to law enforcement authorities or other government officials, (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity; or (4) if necessary to protect the vital interests of any person.
HOW WE PROTECT PERSONAL INFORMATION
We seek to ensure that any personal information that we hold about you is accurate, complete, current and otherwise reliable based on data you or an employer provide in order to provide the immigration consulting and legal services. We seek to collect only that personal information that is adequate, relevant and not excessive for these purposes.
We maintain appropriate administrative, technical, organizational, and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of personal information.
We educate our employees and strive to maintain appropriate standards of conduct with regard to the protection of personal information.
We take steps to require that third parties who assist in our provision of services abide by all applicable privacy and data protection laws and prohibit them from using your information other than in connection with the services they have been engaged to provide.
We retain personal information for only as long as we need it to provide the services you or your employer has requested, for our own administration and internal purposes, and for any periods that are mandated by law or otherwise agreed to with our clients, after which, we take steps to delete or anonymize the information.
YOUR CHOICES AND RIGHTS
As set out above, Gilroy may collect certain information about you in conjunction with providing immigration consulting and legal services. We will respect your decision if subsequently your employer informs us or, where you instruct us directly, you inform us that you wish to opt- out of personal information. If sensitive personal information is involved for the delivery of a new purpose we will only use your information if you actively communicate your consent to this processing to your employer or us, as applicable, when it is necessary to deliver requested service, or in accordance with the requirements of applicable laws. We will follow the identical procedure if we disclose personal information to third parties that are expected to process the personal information for their own independent purposes.
We also will assist our clients to provide you, or provide you directly, where appropriate, with access to your personal information and, as applicable, with the ability to review and correct inaccuracies, delete unnecessary personal information, and receive a copy of your personal information in a structured machine-readable format. We may, where applicable, use reasonable efforts to assist your employer in responding to a request to access, correct, delete or restrict processing of your personal information or, where required by law, to respond directly to such a request within a reasonable period of time. In the event that either you or your employer informs us in writing that you wish to opt-out of future processing of personal information we will respect your request.
To help protect your privacy and the security of your information, Gilroy takes reasonable steps to verify your identity before granting access to information. Where we rely solely on your consent, you may withdraw it at any time. You may also object to processing that is based on our legitimate interests alone. In such instances, our business interests must be found to be compelling and to not jeopardize your individual rights before further processing may continue. To exercise these rights, please contact your employer or Gilroy, as applicable. If you have unresolved concerns, where provided by local law, you may 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.
UPDATES TO OUR PRIVACY NOTICE
This Privacy Notice may be updated periodically without prior notice to you to reflect changes in our information practices. We will post a notice on our applicable websites or materials to advise of any significant changes to our Privacy Notice and indicate in the notice when it was most recently updated. In certain countries, additional or different procedures not inconsistent with this Privacy Notice may apply as necessary to satisfy local legal requirements.
HOW TO CONTACT US
The controllers for your personal information are the Gilroy offices providing the services to you. If you have any questions or comments about this Privacy Notice, please contact our data protection officer by email at contact@gilroy.ae. You also may write to us at:
Gilroy Documents Clearing Services
P.O. Box 451136
Dubai, UAE