VAZIR GROUP – PRIVACY POLICY

Policy version: 18/01/2022

The Vazir Group website and portal, available at: https://vazirgroup.com/ (our website) is provided by Vazir Immigration Services DMCC, trading as Vazir Group (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. As we are based outside of the European Economic Area (EEA) and do not supply our services, or target individuals resident in the EEA, we are not usually bound by EEA data protection laws. However, given the nature of our services and the fact that we pride our approach to quality, we have chosen to apply the gold standard when it comes to your privacy. Therefore, we implement practices and process personal data in accordance with the General Data Protection Regulation (GDPR).

Given the nature of our website and our services, we do not expect to collect the personal data directly from anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website without parental or guardian consent, please let us know so that we can delete that data.

What this policy applies to

This privacy policy relates to your use of our website only, whether you are an applicant undertaking an immigration process, a client/customer of Vazir Group, or whether you are one of our partner agents.

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:

  • your name, address and contact information, including email address and telephone number (and company details if you are a partner agent) and any historical address or contact information supplied as part of an immigration application
  • information to check and verify your identity, e.g. date of birth
  • your gender
  • your billing information, transaction and payment card or other payment method information
  • bank account and payment details
  • details of any information, feedback or other matters you give us by phone, email, post or via social media
  • your account details, such as username and login details when you create a portal account as a user of our services or as a partner agent
  • your activities on, and use of, our website
  • your personal, academic or professional interests, financial status and background, and general life experience and background
  • details of any university or study applications, and of any obtained diplomas or qualifications
  • where applicable, information regarding outstanding achievements (such as in the field or sport, science and research and entertainment)
  • your professional online presence, e.g. LinkedIn profile
  • information about the services we provide to you (or where you are a partner agent, the services you provide us)
  • your contact history, application history, purchase and payment history and saved, successful and unsuccessful immigration applications
  • details of any criminal background checks
  • information about how you use our website and technology systems
  • your responses to surveys, competitions and promotions
  • information about your family members and relatives to be included on the immigration application, such as marriage certificates, birth certificates, adoption certificates, death certificates
  • information about your current visa or immigration status and location, including your current passport, social security numbers, proof of address and proof of employment and tax status
  • information about your immigration requirements and goals, including previous successful or rejected applications
  • information about your health status and that of your family members and relatives to be included on the immigration application

If you do not provide personal data we ask for where it is required, it may delay or prevent us from providing our immigration services to you or from providing a complete application to the relevant authorities. This may have an impact on the success of your application(s).

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

  • directly, when you enter or send us information, such as when you create a portal account on our website and supply such information to us, when you register with us as a user or partner agent when you contact us (including via email), send us feedback, purchase services via our website or from our company, post or upload material generally to our website and complete surveys or participate in competitions via our website, and
  • indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies]’ below

We also collect personal data about you from other sources as follows:

  • Information that is supplied to us by an national immigration agency or authority as part of an application that we are handling on your behalf
  • Information that you supply to us via a partner agent.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract, or
  • for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Create and manage your portal account with us and to sign you up as a user or partner agent

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

and

To perform our contract with you or to take steps at your request before entering into a contract

Providing immigration services to you

To perform our contract with you or to take steps at your request before entering into a contract

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us

To comply with our legal and regulatory obligations

and

For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our website —see ‘Cookies and other tracking technologies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended

Depending on the circumstances:

—your consent as gathered by the separate cookies tool on our website —see ‘Cookies and other tracking technologies’ below

—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Protecting the security of systems and data

To comply with our legal and regulatory obligations

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

Updating and enhancing customer records

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract

—to comply with our legal and regulatory obligations

—where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing applications and new services we offer

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant.

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

See ‘Marketing’ below for further information

External audits and quality checks, e.g. for the audit of our accounts

For our legitimate interests or a those of a third party, i.e. to to comply with legal and accounting obligations and also to demonstrate we operate at the highest standards

To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets

 

Certain personal data we collect is treated as a special category data or sensitive data to which additional protections apply under data protection law. This will apply when we have to process sensitive data about you in order to assess and progress your immigration application.

Special category data or sensitive data includes items of personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, biometric data and data concerning health, sex life or sexual orientation. For more information on the type of sensitive data we may require, please see the section ‘Personal data we collect about you’ above.

Where we process such special category personal data, we will always let you know what is required and the reasons why this is required. We will also ensure we are permitted to collect such data under data protection laws. This will mainly involve relying on your express consent to share your sensitive data with us via the secure portal on our website. As we rely on your consent, you have full control over the sensitive data that you share with us and you can ask for such sensitive data to be deleted or removed at any time. Please note that if you do require us to stop processing your sensitive data, this may mean that we are unable to progress your immigration application. We can always discuss any issues you may have as and when they arise, and we will always let you know the consequences of failing to share sensitive data with us or relevant immigration authorities, or withdrawing your consent to do so.

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • contacting us
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
  • updating your marketing preferences within your personal portal space on our website.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations outside of the Vazir Group for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

  • third parties we use to help deliver our services to you, e.g. partner agents, payment service providers, national immigration authorities or such other relevant entity mandated to progress your immigration application
  • other third parties we use to help us run our business, e.g. marketing and development agencies or website hosts and website analytics providers and customer-relationship-manager (CRM) systems.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. Where applicable, we will also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share personal data with:

  • external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
  • professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
  • other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, we will keep your personal data throughout the duration of your immigration application and for as long as we are supplying services to you. We will also keep your personal data and application(s) on a separate storage system for a period of up to 10 years thereafter, to comply with tax and fiscal obligations and in the event of defence or pursuit of legal claims.

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

International transfers of your personal data

As you (and we) are based outside of the EEA, some countries outside the EEA have differing data protection laws, some of which may provide lower levels of protection of privacy.

We will process your personal data outside of the EEA as we are based in the UAE and also you are based outside of the EEA. We will comply with local data processing laws applicable to us. If we do need to share your personal data with countries outside the UAE and where you are usually resident, and if this is to a country outside of the EEA, we will comply with applicable laws designed to ensure the privacy of your personal data.

We will always let you know where we will send your personal data, such as to the country or countries in which you wish us to carry out an immigration application on your behalf. Such transfers will always be done on the basis of your consent when you engage us to provide you with our services.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies and on our website.

For further information on cookies, our use them, when we will request your consent before placing them and how to disable them, please see our Cookie Policy available here: https://vazirgroup.com/legal-documents/cookie-policy/.

Your rights

When you are based in the EEA, you generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data

The right to be provided with a copy of your personal data

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data

 

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object to use

The right to object:

—at any time to your personal data being used for direct marketing (including profiling)

—in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

We do not make any such decisions based on data collected by our website.

 

For further information on each of those rights, including the circumstances in which they do and do not apply (including when you are not resident in the EEA), please contact us (see ‘How to contact us’ below).

If you would like to exercise any of those rights, email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.

For a list of EEA data protection supervisory authorities and their contact details see here.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.

How to contact us

Our contact details are shown below:

Our contact details

Our Data Protection Officer’s contact details

Registered Address – 3O-01-BA283, Jewellery & Gemplex 3, Plot No: DMCC-PH2-J&GPlexS, Jewellery & Gemplex, Dubai, UAE

Business Address - Office #2701-2702, Oberoi Business Tower, Business Bay, Dubai, UAE

Palak Shah

dataprotection@vazirgroup.com