Privacy Policy
Version 1.0
Issued on 2 March, 2021
1. Scope. Regulation
1.1. This privacy policy (the “Policy”) governs the privacy terms of our service (the “Service”) we provide via our
website https://www.nationbetter.uk/ (the “Website”). The Service is offered by Betternations Ltd, who is trading under
the name “Nation.better” (“we”, “us”), is a company registered in England and Wales with company number 12066785
and its registered office address at 160 Kemp House City Road, London, United Kingdom, EC1V 2NX.
1.2. The Policy is a legal statement which explains how we collect, retain, process, and transfer the Personal Data
which is any information relating to an identified or identifiable living individual (“you”) we receive.
1.3. We receive the Personal Data from various sources to provide our clients (the “Clients”) with the Service. The
Clients are (1) legal entities; and (2) individuals who pay for the Service to use it on their own; and (3) individuals who
use free features of the Service. So, you may be a visitor of the Website, the Client, the Client’s representative (the
“Representative”), or a prospective employee (the “Employee”), or the officer responsible for compliance with
immigration rules (the “Key Personnel”).
1.4. Please, read the Policy carefully as it will help you to make informed decisions about sharing your Personal Data
with us.
2. Personal Data We Collect
2.1. We collect several types of the Personal Data for various purposes to provide the Clients with the Service and to
improve it. The scope of your Personal Data we collect depends on how you interact with us.
2.2. If you provide us with the Personal Data when you create an account to use the Service or pay for the Service, you
provide us with the Submitted Data:
2.2.1. if you are the Employee, or the Client, you may provide us with the Clients’/Employees’ Data:
2.2.1.1. about yourself: first and last name, date and place of birth, age, gender, citizenship, country of residence, full or
partial home address, email address, account username and password, phone number, bank account details (if you
pay for the Service via bank transfer), date, time and amount of payment for the Service, level of education, diploma
number and date, employment history, position, salary, immigration status and history, travel history, visa type (if any),
job duties, as well as documents containing this Personal Data;
2.2.1.2. about your parents and dependants: same to clause 2.2.1.1, except account username and password, bank
account details and job duties;
2.2.2. if you are the Key Personnel, you provide us with Key Personnel Data: first and last name, email, account
username and password, phone number, employment history, position, date of birth, citizenship, passport or other ID
number, visa type (if any);
2.2.3. if you are the Representative, you provide us with Representatives’ Data: the first and last name, email address,
phone number, position at the Client’s company, account username and password.
2.3. We automatically collect the Usage Data when you visit, use or navigate the Service. We need this information to
operate the Service, to maintain its security, and for our analytics purposes. The Usage Data may include:
2.3.1.1. the information about computer or mobile device. The examples of such information are device information,
internet protocol (IP) address, browser type and version, operating system, language settings, mobile network
information, mobile operating system, type of mobile browser and version, URL-links;
2.3.1.2. information about how you use the Service, such as account settings and preferences, the time you enter and
exit the Website, which pages you visit and which features you use, technical information, such as Internet speed.
2.4. We may receive the Personal Data from other sources, including third parties and publicly available sources which
help us to update, expand, and analyze our records; prevent or detect fraud; process payments; or analyze how you use
the Services (the “Third-Party Data”). The Third-Party Data may include without limitation the data from analytics
providers (e.g., Google), identity and contact data from the Companies House.
2.5. We do not process the Personal Data relating to your racial or ethnic origin, political opinions, religious or
philosophical beliefs, trade union membership, genetic and/or biometric data, data concerning health or sex life
and/or sexual orientation.
2.6. We may anonymize the Personal Data, or use the anonymous information we receive (the “Anonymous
Information”). The Anonymous Information shall not be considered to be the Personal Data, as it does not identify you
as an individual. We may use the Anonymous Information to administer the Service, for analytics, advertising and
promotional purposes. We may share the Anonymous Information with other entities (e.g., service providers, business
partners) for such purposes. The Anonymous Information includes without limitation aggregated data which allows us
to conduct analytics and research.
3. How We Use Personal Data
3.1. To use the Personal Data, we must rely on one or more legal bases. The bases we rely on are:
3.1.1. contract performance. If you are the Client, we process the Personal Data to perform the agreement with you or
to take steps at your request before entering into the agreement;
3.1.2. consent. This will apply when you agree that we process the Personal Data, for example, when you set up your
Service account;
3.1.3. legitimate interest. We may process the Personal Data when we have a legitimate business interest to do so: for
example, to ensure that the Service is secure and safe to use;
3.1.4. to comply with our legal obligations. Sometimes we cannot comply with law without processing the Personal
Data: for example, when the court or a public authority requests it.
3.2. Please find a description of how we use the Personal Data and which legal bases we rely on. We have also
identified our legitimate interests where appropriate:
| Type of the Personal Data | Purposes | Legal Basis |
|---|---|---|
| 3.2.1. the Clients’/ Employees’ Data | 3.2.1.1. to create and maintain your
account; 3.2.1.2. to ensure that only you may access your account; 3.2.1.3. to provide you with the Service features | contract performance if you are the Client |
| 3.2.2. the Clients’/ Employees’ Data | Same to clause 3.2.1 | your consent if you are not the Client |
| 3.2.3. the Key Personnel Data, the Representatives’ Data | 3.2.3.1. to create and maintain the
Client’s account; 3.2.3.2. to ensure that only authorized users may access the Client’s account; 3.2.3.3. to provide the Client with the Service features | your consent |
| 3.2.4. the Usage Data, the Third-Party Data | 3.2.4.1. to prevent fraud, deception
and other illegal activities; 3.2.4.2. to improve our counter-fraud practices; legitimate interest which is to ensure that the Service is safe and comfortable to use3.2.4.3. to keep the Service and the Website safe and secure; 3.2.4.4. to analyze how the Service works, to evaluate and improve it; 3.2.4.5. to detect, prevent and address technical issues of the Website and of the Service; 3.2.4.6. to administer the Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; 3.2.4.7. tto ensure that we present the content of the Website to our users in the most effective manner | legitimate interest which is to ensure that the Service is safe and comfortable to use |
| 3.2.5. the Usage Data | 3.2.5.1. to optimize advertising based
on your use of the Website; 3.2.5.2. to optimize and serve advertising for you based on your past use of Google, Facebook, Linkedin, Twitter | your consent |
| 3.2.6. All types | 3.2.6.1. to respond in the course of
legal, regulatory, arbitration
procedures; 3.2.6.2. to respond the mandatory requests for information issued by public authorities or other third parties; 3.2.6.3. prevent harm as legally required.If we receive a subpoena or other legal request we may need to inspect the Personal Data we store to determine how to respond. | complying with our legal obligations |
| Type of the Personal Data | Purposes | Legal Basis |
|---|---|---|
| 3.2.1. the Clients’/ Employees’ Data | 3.2.1.1. to create and maintain your
account; 3.2.1.2. to ensure that only you may access your account; 3.2.1.3. to provide you with the Service features | contract performance if you are the Client |
| 3.2.2. the Clients’/ Employees’ Data | Same to clause 3.2.1 | your consent if you are not the Client |
| 3.2.3. the Key Personnel Data, the Represent atives’ Data | 3.2.3.1. to create and maintain the
Client’s account; 3.2.3.2. to ensure that only authorized users may access the Client’s account; 3.2.3.3. to provide the Client with the Service features | your consent |
| 3.2.4. the Usage Data, the Third-Party Data | 3.2.4.1. to prevent fraud, deception
and other illegal activities; 3.2.4.2. to improve our counter-fraud practices; legitimate interest which is to ensure that the Service is safe and comfortable to use3.2.4.3. to keep the Service and the Website safe and secure; 3.2.4.4. to analyze how the Service works, to evaluate and improve it; 3.2.4.5. to detect, prevent and address technical issues of the Website and of the Service; 3.2.4.6. to administer the Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; 3.2.4.7. tto ensure that we present the content of the Website to our users in the most effective manner | legitimate interest which is to ensure that the Service is safe and comfortable to use |
| 3.2.5. the Usage Data | 3.2.5.1. to optimize advertising based
on your use of the Website; 3.2.5.2. to optimize and serve advertising for you based on your past use of Google, Facebook, Linkedin, Twitter | your consent |
| 3.2.6. All types | 3.2.6.1. to respond in the course of
legal, regulatory, arbitration
procedures; 3.2.6.2. to respond the mandatory requests for information issued by public authorities or other third parties; 3.2.6.3. prevent harm as legally required.If we receive a subpoena or other legal request we may need to inspect the Personal Data we store to determine how to respond. | complying with our legal obligations |
4. When We Disclose Personal Data to Third Parties
4.1. We only share the Personal Data:
4.1.1. to comply with laws;
4.1.2. to fulfill the business obligations (for example, if it is necessary to fill in the Personal Data to apply to the Home
Office for the immigration sponsor licence);
4.1.3. if you agreed that we may do so.
4.2. We may disclose the Personal Data only:
4.2.1. to comply with laws. We may disclose the Personal Data where we are legally required to do so to comply with
the applicable law, governmental requests, a judicial proceeding, court order, or legal process. For example, we may
disclose the information in response to a court order, a subpoena, a public authorities’ request to meet national
security or law enforcement requirements. We may also disclose your information when we conduct or cooperate in
investigations of fraud or other illegal activity, to prevent and detect fraud or crime;
4.2.2. to allow third parties to render the services. We may share your data with our business partners, service
providers, contractors or agents performing the services for us or on our behalf and require access to such
information to perform their obligations. The examples of such third parties’ services are payment processing, data
analysis, email delivery, hosting, customer service, providing us with access to anti-fraud databases, screening. We
may allow selected third parties to use tracking technology on the Website, which will enable them to collect the data
about how you interact with the Website over time;
4.2.3. to transfer our business. We may share or transfer the Personal Data in connection with, or during negotiations
of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another
company. We will provide you with the notice before your Personal Data are transferred and become subject to a
different privacy policy;
4.2.4. if you agreed. We may disclose the Personal Data for other purposes if you granted us consent to do so.
5. Cookies
We use cookies as specified in our Cookie Policy.
6. With Whom We Share Personal Data
6.1. We may share (1) the Clients’/Employees’ Data; (2) the Key Personnel Data; (3) the Representative’s first and last
name, email address, phone number, position at the Client’s company to comply with the agreement with you (if you
are the Client) or with the Client to make available features of the Service:
6.2. We may share your cookies and the Usage Data for analytics purposes and to personalize the content of the
Service: for example, to offer you not all our services but the ones in which you might be interested:
| With whom we share the information | Where can you read the privacy policy (if any) |
|---|---|
| 6.1.1. PrimeVisa Ltd, a company registered in England and Wales with company number 09604107 and its registered office address at 10 Margaret Street, London, United Kingdom, W1W 8RL (“PrimeVisa”) | |
| 6.1.2. the Home Office | https://www.gov.uk/help/privacy-notice |
| 6.1.3. Office of the Immigration Service Commissioner (OISC) | https://www.gov.uk/help/privacy-notice |
| With whom we share the information | Where can you read the privacy policy (if any) |
|---|---|
| 6.1.1. PrimeVisa Ltd, a company registered in England and Wales with company number 09604107 and its registered office address at 10 Margaret Street, London, United Kingdom, W1W 8RL (“PrimeVisa”) | |
| 6.1.2. the Home Office | https://www.gov .uk/help/privacy-notice |
| 6.1.3. Office of the Immigration Service Commissioner (OISC) | https://www.gov .uk/help/privacy-notice |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.2.1. Google Analytics operated by Google: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA | https://policies.google.com/privacy | by installing the add-on for your browser https://chrome.google.com/web store/detail/google-analytics-opt -out/fllaojicojecljbmefodhfapmk ghcbnh?hl=en |
| 6.2.2. Google Ads operated by Google | https://policies.google.com/privacy | as described at https://policies.google.com/tech nologies/ads, in the section How you can control advertising cookies |
| 6.2.3. Facebook Ads operated by Facebook: (1) Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA, if you live outside the EU; or (2) Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, if you live in the EU | https://www.facebook.com/about/privacy/ | via your Facebook account settings |
| 6.2.4. Hotjar operated by Hotjar: Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julians STJ 3141, Malta | https://www.hotjar.com/privacy/ | as described at https://www.hotjar.com/legal/po licies/do-not-track/ |
| 6.2.5. Hubspot operated by Hubspot, HubSpot, Inc., 25 First Street, 2nd Floor. Cambridge, Massachusetts 02141 | https://legal.hubspot.com/privacy -policy?_ga=2.264354376.639788 336.1614076925-89810856.1614 076925 | as described at https://legal.hubspot.com/privac y-policy, in the section How to Access & Control Your Personal Data |
| 6.2.6. Linkedin operated by Linkedin: (1) LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA if you live outside the EU, EEA, and Switzerland, or (2) LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland if you live in the EU, EEA or Switzerland | https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy | as described at https://www.linkedin.com/help/li nkedin/answer/62931?trk=micro sites-frontend_legal_privacy-poli cy&lang=en |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.2.1. Google Analytics operated by Google: Google Inc., 1600 Amphithe atre Parkway, Mountain View, CA 94043, USA | https://poli cie s.google. com/priv acy | by installing the add-on for your browser https://chr ome.goog le.com/web store/det ail/googl e-analy tics-opt -out/flla ojicojeclj bmefodhfa pmk ghcbnh?hl=en |
| 6.2.2. Google Ads operated by Google | https://poli cies.goog le.com/pr ivacy | as described at https://poli cies.google .com/tech nologies /ads, in the section How you can control advertising cookies |
| 6.2.3. Facebook Ads operated by Facebook: (1) Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA, if you live outside the EU; or (2) Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, if you live in the EU | https://www .facebo ok.com/ about/p rivacy/ | via your Facebook account settings |
| 6.2.4. Hotjar operated by Hotjar: Hotjar Ltd, Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julians STJ 3141, Malta | https:// www.hotjar .com/ privacy/ | as described at https: //www. hotjar .com/ legal/po licies/do-not-track/ |
| 6.2.5. Hubspot operated by Hubspot, HubSpot, Inc., 25 First Street, 2nd Floor. Cambridge, Massachu setts 02141 | https :// legal. hubspot. com/ privacy -policy? _ga=2.264 354 376.6397 88 336.1 614076 925-8981 0856.1614 076925 | as described at https: //legal. hubspot .com/ privac y-policy, in the section How to Access & Control Your Personal Data |
| 6.2.6. Linkedin operated by Linkedin: (1) LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA if you live outside the EU, EEA, and Switzerland, or (2) LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland if you live in the EU, EEA or Switzerland | https:// www. linkedin. com /legal /privacy -policy ?trk =homepag e-basic_ footer- privacy -policy | as described at https: //www. linkedin .com/help /li nkedin /answer /62931? trk=micro sites-fronten d_legal_ privacy-poli cy&lang= en |
6.3. We may share your cookies, the Usage Data (clauses 6.3.1, 6.3.2), and sometimes unique device identifiers
(clause 6.3.3) for advertising purposes: for example, to optimize advertising based on your use of the Website:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.3.1. Microsoft Advertising operated by Microsoft: Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052-6399 | https://privacy.microsoft.com/en-GB/privacystatement | as described at https://privacy.microsoft.com/pr ivacystatement, in the section Cookies and similar technologies |
| 6.3.2. Google AdSense operated by Google | https://policies.google.com/privacy | by installing the add-on for your browser https://chrome.google.com/web store/detail/iba-opt-out-by-googl e/gbiekjoijknlhijdjbaadobpkdhm oebb |
| 6.3.3. Facebook Audience Network operated by Facebook | https://www.facebook.com/about /privacy/ | via your Facebook account settings |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.3.1. Microsoft Advertising operated by Microsoft: Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052-6399 | https: //privacy .microsoft .com/ en-GB/privacy statement | as described at https:// privacy. microsoft .com/ pr ivacystat ement, in the section Cookies and similar technolo gies |
| 6.3.2. Google AdSense operated by Google | https:/ /policies .google .com /privacy | by installing the add-on for your browser https:/ /chrome .google .com/ web store /detail/ iba-opt-out-by-googl e/gbiekjoijknlhijd jbaadobpkdhm oebb |
| 6.3.3. Facebook Audience Network operated by Facebook | https: //www. facebook .com/ about /privacy/ | via your Facebook account settings |
6.4. We may share your cookies and the Usage Data to test content performance and features (A/B testing): for
example, to analyze how your web-traffic or behavior changes in response to changes of the structure, text, or any
other component of the Website:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.4.1. Google Optimize operated by Google | https://policies.google.com/privacy | as described at https://support.google.com/acc ounts/answer/61416?co=GENIE. Platform%3DDesktop&hl=en |
| 6.4.2. Sentry operated by Functional Software, Inc., dba Sentry, 45 Fremont Street, 8th Floor, San Francisco, CA 94105 | https://sentry.io/privacy/ | as described at https://sentry.io/privacy/, in the section Do we use cookies? |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.4.1. Google Optimize operated by Google | https: //policies. google. com/ privacy | as described at https:// support .google. com/ acc ounts/ answer/ 61416?co=GENIE. Platform %3DDesk top&hl =en |
| 6.4.2. Sentry operated by Functional Software, Inc., dba Sentry, 45 Fremont Street, 8th Floor, San Francisco, CA 94105 | https: //sentry. io/privacy/ | as described at https:// sentry.io /privacy/ , in the section Do we use cookies? |
6.5. We may share your cookies and the Usage Data to display content from external platforms:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| Google Enterprise Search operated by Google | https://policies.google.com/privacy | as described at https://support.google.com/acc ounts/answer/61416?co=GENIE. Platform%3DDesktop&hl=en |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| Google Enterprise Search operated by Google | https:// policies. google. com/privacy | as described at https://support .google.com/acc ounts/ans wer/61416? co=GENIE. Platform% 3DDesktop& hl=en |
6.6. We may share the Personal Data specified in Stripe’s privacy policy to handle payments: for example, to process
payments by credit card, bank transfer or other means:
| With whom we share the information | Where can you read the privacy policy |
|---|---|
| Stripe operated by Stripe, Inc., 510 Townsend Street San Francisco, CA 94103 United States | https://stripe.com/gb/privacy |
| With whom we share the information | Where can you read the privacy policy |
|---|---|
| Stripe operated by Stripe, Inc., 510 Townsend Street San Francisco, CA 94103 United States | https:// stripe.com/ gb/privacy |
6.7. We may share your cookies, Usage Data and the Personal Data specified in Hotjar’s privacy policy to create heat
maps which represents data using colours and to record sessions, for example: to understand the areas of Service
you interact with most frequently:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| Hotjar Heat Maps & Recordings operated by Hotjar | https://www.hotjar.com/legal/poli cies/privacy/ | as described at https://www.hotjar.com/legal/po licies/do-not-track/ |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| Hotjar Heat Maps & Recordings operated by Hotjar | https:// www. hotjar. com/ legal/ poli cies/ privacy/ | as described at https:/ /www. hotjar. com/ legal /po licies/ do-not-track/ |
6.8. We may share the Personal Data specified in Stripe’s privacy policy to handle payments: for example, to process
payments by credit card, bank transfer or other means:
| With whom we share the information | Where can you read the privacy policy |
|---|---|
| 6.8.1. Amazon Web Services operated by Amazon Web Services Inc., 410 Terry Avenue North Seattle WA 98109. United States or its affiliates | https://aws.amazon.com/ru/privacy/ |
| 6.8.2. Heroku operated by Salesforce.com, Inc., 650 7th Street San Francisco, CA 94103 United States | https://www.salesforce.com/company/privacy/full_privacy/ |
| With whom we share the information | Where can you read the privacy policy |
|---|---|
| 6.8.1. Amazon Web Services operated by Amazon Web Services Inc., 410 Terry Avenue North Seattle WA 98109. United States or its affiliates | https: //aws. amazon .com/ ru/privacy/ |
| 6.8.2. Heroku operated by Salesforce.com, Inc., 650 7th Street San Francisco, CA 94103 United States | https: //www. salesforce. com/ company/ privacy/ full_privacy/ |
6.9. We may share your cookies, Usage Data and the Personal Data specified in Hotjar’s privacy policy to ensure your
interaction with us via online survey platforms, for example, to conduct surveys among users of the Service and
receive their feedback:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| Hotjar Poll & Survey widgets, operated by Hotjar | https://www.hotjar.com/legal/policies/privacy/ | as described at https://www.hotjar.com/legal/po licies/do-not-track/ |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| Hotjar Poll & Survey widgets, operated by Hotjar | https:/ /www. hotjar .com/ legal/ policies /privacy/ | as described at https:/ /www. hotjar. com/ legal/ po licies /do-not-track/ |
6.10. We may share the Usage Data, email address and the Personal Data specified in Wix’s privacy policy to manage
landing and invitation pages, for example to create, publish and use webpages for some of our services:
| With whom we share the information | Where can you read the privacy policy |
|---|---|
| Wix Landing Page, operated by Wix, Wix.com, Inc., 500 Terry A Francois Boulevard Sixth Floor San Francisco, CA 94158 USA | https://www.wix.com/about/privacy |
| With whom we share the information | Where can you read the privacy policy |
|---|---|
| Wix Landing Page, operated by Wix, Wix.com, Inc., 500 Terry A Francois Boulevard Sixth Floor San Francisco, CA 94158 USA | https: //www. wix. com/ about /privacy |
6.11. We may share your cookies and the Usage Data (for the services specified in clauses 6.11.1 6.11.5), as well as
cookies and email address (for the services specified in clauses 6.11.6 6.11.7) to optimize and serve advertising for
you based on your past use of these services:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.11.1. Google Ads Remarketing operated by Google | https://policies.google.com/privacy | as described at https://policies.google.com/tech nologies/ads, in the section How you can control advertising cookies |
| 6.11.2. Remarketing with Google Analytics operated by Google | https://policies.google.com/privacy | by installing the add-on for your browser: https://chrome.google.com/web store/detail/google-analytics-opt -out/fllaojicojecljbmefodhfapmk ghcbnh?hl=en |
| 6.11.3. Facebook Remarketing operated by Facebook | https://www.facebook.com/about/privacy/ | via your Facebook account settings |
| 6.11.4. Linkedin operated by Linkedin | https://www.linkedin.com/legal/pr ivacy-policy?trk=homepage-basic_ footer-privacy-policy | as described at https://www.linkedin.com/help/lin kedin/answer/62931?trk=microsit es-frontend_legal_privacy-policy&l ang=en |
| 6.11.5. Twitter Remarketing, operated by Twitter: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 USA | https://privacy.twitter.com/en | via your Twitter account settings |
| 6.11.6. Twitter Tailored Audiences, operated by Twitter | https://privacy.twitter.com/en | via your Twitter account settings |
| 6.11.5. Twitter Remarketing, operated by Twitter: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 USA | https://privacy.twitter.com/en | via your Twitter account settings |
| Facebook Custom Audience, operated by Facebook | https://www.facebook.com/about/privacy/ | via your Facebook account settings |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.11.1. Google Ads Remarke ting operated by Google | https: //policies .google .com/ privacy | as described at https:/ /policies .google. com/ tech nologies /ads, in the section How you can control advertising cookies |
| 6.11.2. Remarketing with Google Analytics operated by Google | https ://policies .google. com/ privacy | by installing the add-on for your browser: https:/ /chrome .google. com/web store /detail /google- analytics-opt -out/fllao jicojecljbm efodhfapmk ghcbnh?hl=en |
| 6.11.3. Facebook Remarketing operated by Facebook | https://www.facebook.com/about/privacy/ | via your Facebook account settings |
| 6.11.4. Linkedin operated by Linkedin | https: //www. linkedin .com/ legal /pr ivacy-po licy?trk=h omepage-basic_ footer-pri vacy-policy | as described at https:/ /www. linkedin .com/ help/ lin kedin/ answer /62931? trk=microsit es-front end_lega l_privac y-policy&l ang=en |
| 6.11.5. Twitter Remarketing, operated by Twitter: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 USA | https ://privacy .twitter .com/ en | via your Twitter account settings |
| 6.11.6. Twitter Tailored Audiences, operated by Twitter | https: //privacy .twitter. com/en | via your Twitter account settings |
| 6.11.5. Twitter Remarketing, operated by Twitter: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 USA | https: //privacy .twitter .com /en | via your Twitter account settings |
| Facebook Custom Audience, operated by Facebook | https: //www. facebook .com/about /privacy/ | via your Facebook account settings |
6.12. We may share your cookies and the Usage Data (for Twilio Segment, clause 6.12.1), or the Usage Data only (for
Google Tag Manager, clause 6.12.2) to manage tags we use in the Service:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.12.1. Twilio Segment operated by Segment.io, Inc. 100 California Street, Suite 700 San Francisco, CA 94111 USA | https://segment.com/legal/privacy/ | as described at https://segment.com/legal/priva cy/, in the section Advertising Choices |
| 6.12.2. Google Tag Manager operated by Google | https://policies.google.com/priva cy | Not applicable |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.12.1. Twilio Segment operated by Segment.io, Inc. 100 California Street, Suite 700 San Francisco, CA 94111 USA | https :// segment. com/legal /privacy/ | as described at https://segment.com/legal/priva cy/, in the section Advertising Choices |
| 6.12.2. Google Tag Manager operated by Google | https :// policies .google. com/priva cy | Not applicable |
6.13. We may share your email address, phone number and the Personal Data specified in Hubspot’s or Intercom’s
privacy policy to manage user database, for example, to build, manage and analyze your profiles we create based on
the Personal Data you provide us with:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.13.1. THubSpot Lead Management, operated by HubSpot | https://legal.hubspot.com/privacy -policy | as described at https://legal.hubspot.com/privac y-policy, in the section How to Access & Control Your Personal Data |
| 6.13.2. HubSpot CRM, operated by HubSpot | https://legal.hubspot.com/privacy -policy | as described at https://legal.hubspot.com/privac y-policy, in the section How to Access & Control Your Personal Data |
| 6.13.3. Intercom, operated by Intercom: (1) R&D Unlimited Company, 2nd Floor, Stephen Court, 18-21 Saint Stephens Green, Dublin 2; (2) Intercom, Inc., 55 2nd Street, 4th Fl., San Francisco, CA 94105, USA | https://www.intercom.com/legal/privacy | as described at https://www.intercom.com/legal /privacy, in the section Your privacy rights and choices |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.13.1. THubSpot Lead Management, operated by HubSpot | https: //legal .hubspot .com /privacy -policy | as described at https:// legal. hubspot .com/ privac y-policy, in the section How to Access & Control Your Personal Data |
| 6.13.2. HubSpot CRM, operated by HubSpot | https: //legal .hubspot .com/ privacy -policy | as described at https:// legal. hubspot.com /privac y-policy, in the section How to Access & Control Your Personal Data |
| 6.13.3. Intercom, operated by Intercom: (1) R&D Unlimited Company, 2nd Floor, Stephen Court, 18-21 Saint Stephens Green, Dublin 2; (2) Intercom, Inc., 55 2nd Street, 4th Fl., San Francisco, CA 94105, USA | https: //www. intercom .com/ legal /privacy | as described at https: //www. intercom .com/legal /privacy , in the section Your privacy rights and choices |
6.14. We may share your cookies and the Personal Data specified in clauses 6.14.1 6.14.2 to ensure your interaction
with us via live chat platforms:
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.14.1. Facebook Messenger Customer Chat operated by Facebook | https://www.facebook.com/about/privacy/ | via your Facebook account settings |
| 6.14.2. Intercom operated by Intercom | https://www.intercom.com/legal/privacy | as described at https://www.intercom.com/legal /privacy, in the section Your privacy rights and choices. |
| With whom we share the information | Where can you read the privacy policy | How can you opt out transmitting and processing the data generated by third party provider’s cookies |
|---|---|---|
| 6.14.1. Facebook Messenger Customer Chat operated by Facebook | https:/ /www. facebook .com /about/ privacy/ | via your Facebook account settings |
| 6.14.2. Intercom operated by Intercom | https: //www. intercom. com/ legal /privacy | as described at https://www.intercom.com/legal /privacy, in the section Your privacy rights and choices. |
6.15. To ensure you can communicate with us:
6.15.1. via Facebook Messenger Customer Chat, we may share the data at your About Me page in Facebook, data
communicated while using the Service, and the Usage Data;
6.15.2. via Intercom, we may share your email address, the Usage Data, the Personal Data specified in Intercom’s
privacy policy.
7. Transfer of Personal Data
7.1. The countries to which we or the third parties we engage transfer the Personal Data may not have the same data
protection laws as your jurisdiction. In these cases, we take reasonable security measures which the applicable laws
prescribe to ensure that the Personal Data are properly protected when they are transferred outside your jurisdiction.
7.2. You agree to such transfers pursuant to the consent for processing of the Personal Data you grant. If you do not
agree to such transfers, you will no longer be able to use the Service. When we make such transfers, we: (1) comply
with our legal and regulatory obligations; (2) estimate if the country to which we intend to transfer the Personal Data
provides for sufficient level of data protection; (3) implement the appropriate safeguards such as executing standard
data protection clauses. We will take all the steps to ensure that your data are treated securely and in accordance with
the Policy.
7.3. The Policy applies regardless of the location in which we store or process the Personal Data.
8. Retention Of Personal Data
8.1. We retain the Personal Data as long as we provide you with the Service. We retain the Personal Data after we
cease directly or indirectly providing you with Service:
8.1.1. if it is reasonably necessary to comply with our legal and regulatory obligations. Legal and regulatory
obligations may include, without limitation, handling your complaint or a potential litigation with you;
8.1.2. a longer retention period is required or permitted by law. For example, if PrimeVisa represents you in front of the
Home Office we retain the Personal Data within 6 years after your case is closed.
8.2. In any other circumstances, we will retain the Personal Data for no longer than necessary, taking into account the
following:
8.2.1. the purpose(s) and use of the Personal Data both now and in the future (such as whether it is necessary to
continue to store the Personal Data in order to continue to perform our obligations under a contract with you or to
contact you in the future);
8.2.2. whether we have any legal obligation to continue to process the Personal Data (such as any record-keeping
obligations imposed by relevant law or regulation);
8.2.3. whether we have any legal basis to continue to process the Personal Data (such as your consent);
8.2.4. how valuable the Personal Data is (both now and in the future);
8.2.5. any relevant agreed industry practices on how long the Personal Data should be retained;
8.2.6. the levels of risk, cost and liability involved with us continuing to hold the Personal Data;
8.2.7. how hard it is to ensure that the Personal Data can be kept up to date and accurate;
8.2.8. any relevant surrounding circumstances (such as the nature and status of our relationship with you).
8.3. After the retention period ends, we will either delete, or anonymize the Personal Data. If we anonymize it, we may
use such anonymized data for research or statistical purposes or to improve the Service. We may use it indefinitely
without further notice to you.
9. Use by Minors
9.1. The Service is not directed to individuals under the age of 18 years old. Please, do not provide us with your
Personal Data if you are younger.
9.2. If you provide us with the Personal Data from minors via the Service (e.g., in relation to dependants), you
undertake to provide us with such Personal Data:
9.2.1. only if a parent or a guardian consented to such transfer and further processing of this information by us. You
also undertake to notify us immediately if a parent or a guardian withdraws his/her consent or limits the processing to
which he or she consents;
9.2.2. you received documents confirming a minor’s emancipation.
9.3. We collect, process, store and disclose the minors’ data as described in the Policy.
10. Security of Personal Data
10.1. Where we have given you (or where you have chosen) a password, which enables you to access our Website, you
are responsible for keeping this password confidential. Please, do not share a password with anyone.
10.2. We adopt appropriate physical, electronic, management and technical measures to protect security of the
Personal Data we process. However, please also remember that we cannot ensure or warrant security of the Personal
Data which you transmit to the Service. Although we will do our best to protect the Personal Data, their transmission to
and from our Service is at your own risk. Please, access the Service only in a secure environment: for example, use
firewalls, choose the provider which encrypts the traffic, etc. After we receive the Personal Data, we use strict
procedures and security features to try to prevent unauthorized access. However, we will not be liable for any
damages which relate to unauthorized access to the Personal Data.
10.3. The Personal Data we collect is only accessible by a limited number of employees. Any of them have special
access rights to the systems where we store the Personal Data. They are all bound by obligations of confidentiality. If
we use subcontractors to store the Personal Data, we will ensure the same level of data protection as if we stored
them on our own.
10.4. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that
security of your account has been compromised), please contact us immediately as specified in clause 11.3.
10.5. You may restrict access of your employer (if any) to your Service account.
11. Your Data Protection Rights
11.1. We are your data controller, and we are responsible for your Personal Data. We are registered as a data controller
with the Information Commissioner’s Office (ICO) with the registration number ZA795311 and determine the purposes
and methods of the processing of your Personal Data, including the security measures concerning the operation and
use of the Service
11.2. Your data protection rights are:
11.2.1. to access the Personal Data which means you may obtain a confirmation if we process your Personal Data,
and / or to access your Personal Data and the information, how we use your Personal Data
11.2.2. to rectify inaccurate Personal Data which means you may request that we correct any incomplete or inaccurate
Personal Data about you;
11.2.3. to object to processing which means that you may object to processing your Personal Data if we process them
based on the legitimate interests (please, see the examples of our legitimate interests in clause 3.2.4), use them for
statistical purposes;
11.2.4. to make your Personal Data portable which means that you may request that in certain circumstances we
provide you with a copy of your Personal Data in structured, commonly used and machine-readable format. If you wish
to have a copy of your Personal Data, we will aim to provide you with them within 14 days;
11.2.5. to have your Personal Data erased which means that you may request that we delete your Personal Data in
some circumstances: for example, we no longer need them, or you withdraw your consent which was the basis for
processing;
11.2.6. to withdraw consent to processing your Personal Data which means that you may withdraw your consent for
processing your Personal Data. Such withdrawal will only affect processing of your Personal Data after it is given;
11.2.7. to restrict processing which means that you may ask us to restrict or stop collection, use, processing and/or
disclosure of your Personal Data;
11.2.8. to be informed about the safeguards which we arrange to transfer your Personal Data transfer to a third
country or an international organization which means that you may ask us about these safeguards;
11.2.9. to file complaints which means that you may complain to a data protection authority (ICO) about our collection
and use of your Personal Data.
11.3. If you wish to exercise any of the rights specified in clause 11.2, or have any questions concerning the Policy and
/ or your Personal Data, please contact our Data Protection Officer (“DPO”), who is responsible for overseeing this
Privacy Policy, at [email protected]. DPO will review your request and offer a resolution or help to begin a
dialogue to find a way out.
11.4. If you would like to file a complaint to a data protection authority (clause 11.2.9), please contact the data
protection authority (ICO) at www.ico.org.uk. Anyway, we will always aim to help you if you wish to exercise your rights,
so, we would appreciate you contact us first.
11.5. Please keep in mind that there may be exceptions to these rights under the English data protection law, with
which we must comply, or under the legislation, with which a data processor we engage must comply. Thus, we may
reject the request about execution of your rights where permitted or required by these laws.
11.6. If we reject your request, we will describe the grounds for it in our response. In any case, you may file a complaint
for our refusal to the supervisory authority.
11.7. Please, note that we may ask you to verify your identity before we respond to the request and, in certain
circumstances, charge a fee to cover our costs. Our time limit to respond is one month after we receive the request. If
it takes longer to process your request, we will notify you. In any case, we cannot extend the response timeframe for
more than two months after the first month for response passes.
12. Automated Decision Making
We do not apply automated decision making based only on automated Personal Data processing, including creating
user profiles.
13. Third Party Links
We may post links to our partners’ websites from time to time. Please note that we are not liable for data protection at
such websites; please refer to privacy policies of these websites to understand how the Personal Data are processed
there.
14. Changes to Policy
Although most changes are likely to be minor, we may modify the Policy at any time. If we make material changes to
the Policy, we may notify you via the Service or email. We will also change the version number and issue date at the
beginning of the Policy. Any changes we make to the Policy are effective on or after the issue date and replace any
prior versions of the Policy. We encourage you to review the Policy frequently to be informed of how we protect your
Personal Data.