MELTZER HELLRUNG PRIVACY POLICY

Effective Date: May 1, 2022

Meltzer Hellrung LLC, together with its affiliates and subsidiaries (“Meltzer Hellrung”, “we”, “us” or “our”) respects your privacy and takes the responsibility of protecting the Personal Information (defined below) that we collect, receive, store and process about you seriously. This privacy policy (the “Policy”) describes the ways that we collect, process and otherwise use your Personal Information in connection with the immigration consulting services that we provide, and/or through your use of our website, https://meltzerhellrung.com, as well as any other website(s) that we may operate (collectively and together with any subdomains and the content and services therein, the “Site”). For purposes of this Policy, the Site and any services that we offer are individually and collectively referred to herein as the “Services.”

This Policy explains what Personal Information may be collected in connection with the use of our Services, the purposes for which we may use that Personal Information, and under what circumstances we may disclose Personal Information to third parties. As used herein, “Personal Information” means any information that can be used, alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, email address, or a personal profile. In some cases, IP addresses may also be considered Personal Information.

This Policy also describes your rights, where applicable, and how to exercise them in the event you wish to object to the processing of certain aspects of your Personal Information in accordance with applicable laws, and/or access, correct, or delete your Personal Information, among other rights. You may contact us at any time with questions related to our Policy and the processing of Personal Information and privacy more generally at voyager.help@meltzerhellrung.com.

In certain instances we are engaged directly by a corporate entity and may process employee information at their request and direction. Any reference to “employer” below is in connection with such an engagement. If we collect or process your Personal Information at the direction of your employer, you may also at any time address any concern you have in connection therewith directly with your employer.

 

Consent and Modification

We encourage you to review this Policy periodically, as your use of our Services constitutes consent to this Policy. We will periodically update this Policy, and any changes will be reflected here. If the changes are significant, we may provide a more prominent notice, and at our discretion

may contact you directly with information on the same. If you do not agree with the practices described in this Policy, you should not use our Services or otherwise interact with us.

 

What Personal Information We Collect and How We Collect It

We collect certain Personal Information about you and, if required, your family members and employer, for the purposes of providing our Services, notably our immigration consulting and legal services. While the extent and specific types of Personal Information will vary from case to case, we will not be able to adequately provide our Services if we are not provided with all Personal Information which is relevant to your matter. If in the course of our engagement, you and/or your employer request additional or different Services then we may be required to collect additional types of Personal Information to provide the same.

In order to provide our Services we collect, from time to time, Personal Information that includes: first and last name, address, telephone number, email, date of birth, marital status, passport number, bank account number and status, job title and function, employment history and/or employee number, educational history, tax status, race, religious affiliation, and expatriate status. We may collect such Personal Information through our online platform, Voyager, or directly from you, your agent(s) (e.g. lawyer, consultant, employee, or similar) or from your employer. As necessary to provide the Services, we may also collect official documents, including, but not limited to, copies of your passport(s) and/or visa(s), educational records, birth certificates, CV or resume, and similar.

As necessary, we may obtain certain Personal Information from third-party sources, including, but not limited to, your current and/or former employer(s), educational institution(s), and/or governmental agencies, as applicable. We do so at all times with your authorization.

 

Sensitive Personal Information

From time to time we may be required to collect certain categories of Personal Information that are considered “sensitive” and which are subject to higher levels of data protection and use authorization. These categories of Personal Information may include race or ethnic origin, political opinions, religious or philosophical beliefs, sex life and/or sexual orientation, trade union membership, criminal history and/or records, physical and/or mental health records, and biometric data such as fingerprints, retina scans and voiceprints, among others, which can be used to uniquely identify you. Certain governments require such sensitive Personal Information from foreign nationals seeking to enter the country for residency and/or employment authorization.

We will only collect such sensitive Personal Information from you where it is strictly necessary. Unless such transfer is required by law to provide the Services – such as the laws of the European

Union – we will always ask for your express consent before transferring sensitive Personal Information in connection with our Services.

 

Information Collected by Automatic Means

We also collect certain data about you automatically when you visit our Site or use our Services. This data may include your IP address, the time and date of your visit, your location, the pages and other content that you access, and the number of times you return to the Site. Collection may be performed either by Meltzer Hellrung’s own software and tools or through our integrations with technology provided by third parties. We collect this information by using technologies such as:

Log Files: A log file is a text file which resides on our servers, and which records pertinent information about your interactions with our Services at the time of access. Log file data is used primarily for diagnostic and auditing purposes.

Cookies: A cookie is a small data file which resides on your device, and which allows us to recognize you as a user when you return using the same device or web browser. Cookie data is used to customize your experience when you use our Site. You can configure your web browser to warn you each time a cookie is being sent or to refuse cookies completely. However, if you opt to refuse cookies created by our Site, you accept that your ability to use our Services may be impaired or limited, up to and including loss of access to certain Services, until such time as you accept these cookies.

Embedded Scripts: An embedded script is programming code (particularly JavaScript) that collects information about your interactions with our Site. The code is temporarily downloaded onto your device, from our server or a third-party service provider, and is deactivated or deleted when you disconnect from our Site. You can configure your web browser to disable the use of embedded scripts. However, if you opt to disable embedded scripts which we incorporate into our Site, you accept that your ability to use our Services may be impaired or limited, up to and including loss of access to certain Services, until such time as you enable these embedded scripts.

We may also use other technologies that collect similar information for security and fraud detection purposes.

More generally, we have collected the following categories of Personal Information from users of the Services within the last twelve (12) months:

 

Category Examples Collected
Identifiers. A real name, postal address, unique personal identifier, online identifier, telephone number, Internet Protocol address, username and password, YES

  email address, payment information, account name; information you include in open field boxes or via the Voyager platform.  
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other

financial information, medical information, or health insurance information.

 YES
Protected   classification characteristics. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
Commercial information. Records of personal property, products or services

purchased,   obtained,   or    considered,   or    other purchasing or consuming histories or tendencies.

 NO
Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face, voice, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. YES
Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application,

or advertisement.

 NO
Geolocation data. Physical location or movements. YES
Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
Professional                 or employment-related information. Current   or    past   job    history    or    performance evaluations. YES
Non-public      education information. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification

codes, student financial information, or student disciplinary records.

 YES

Inferences drawn from other                  Personal Information. Profile reflecting a person’s preferences, characteristics,             psychological             trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

 

If you provide any additional Personal Information beyond what we require, such as in your communications with us, doing so is entirely your choice. We will retain the Personal Information that you choose to provide in those instances.

If you are granted access to Meltzer Hellrung’s Services through an employer, we do not require any Personal Information other than as set forth herein. If you have any questions or concerns about the ability of any corporate entity to access your Personal Information or furnish your Personal Information to us, you should direct those questions to the administrator of that corporate entity.

 

How We Use Personal Information

We use Personal Information primarily to provide our Services to you in manners including, but not limited to, processing and filing immigration requests, responding to inquiries, either from you directly or from various governmental agencies, providing customer service, and sending administrative information. We may use Personal Information to provide access to our online platform, Voyager, if you have registered to use Voyager. In certain cases, we may use Personal Information to contact you in the future to tell you about new or expanded service offerings, opportunities, or other general information about Meltzer Hellrung or our Services that we think you might be interested in.

Where we are engaged directly by an employer, we may use Personal Information in connection with such engagement, including to advise on compliance with immigration requirements and processes, tracking visa expiration, and similar. We may use Personal Information in the aggregate to analyze immigration trends, and similar. In any such instance, we will only use or process Personal Information when there is a legitimate interest to do so that is not overridden by any data protection rights required by law.

We also use the Personal Information we collect to improve our Site. We review information to learn about how our Site is used and accessed, and to analyze user behavior as a measure of interest in and use of our Site. We may disclose such analyses to third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user. We may also use certain subsets of the same information to investigate and prosecute potential breaches of Meltzer Hellrung license agreements and security policies. We also may share pertinent Personal Information with our contractors, vendors, and other affiliates and partners for the purposes of processing data for marketing, research, analytics, customer support and account management.

If you provide any information, whether or not it is Personal Information, via any interactive features of the Services, or through any social media platform that Meltzer Hellrung links to, you should be aware that the information you provide could be available to others, whether immediately or at some future point. If you contact us by email, please be aware that we cannot guarantee total security of email transmissions, and that what you email to us could possibly be viewed by a third party while in transit. When caused by errors, by the unauthorized acts of third parties during transmission, or by interaction with a website other than Meltzer Hellrung’s, we have no liability for disclosure of any information.

In addition to the provision of our Services, we also process Personal Information in order to comply with legal and regulatory obligations which are applicable to us, including certain record- keeping requirements. Though it is not often necessary, we reserve the right to disclose Personal Information to third parties to protect the rights, property, or safety of Meltzer Hellrung, our employees, or others.

 

Transfers of Personal Information

In order to provide the Services, it is necessary in certain instances that we transfer Personal Information to certain third parties. For instance, we routinely transfer Personal Information to and between governmental agencies, including governmental agencies other than those of your current country of citizenship (or residence, as applicable). In connection therewith, we may also provide Personal Information to local service providers, such as translators and similar. When engaged by an employer, we may share Personal Information across offices as necessary to administer and manage the Services. In such instances, Personal Information may be processed in or accessed from jurisdictions that have data protection laws which differ in material part from those in your country of residence. We may also share or transfer Personal Information with your employer.

Additionally, it may be necessary from time to time for us to share Personal Information with our own third party service providers in order to adequately provide the Services. Any such disclosure will be subject to contractual obligations imposed upon such service providers which are consistent with the policies and protections set forth herein.

 

Other Disclosures of Personal Information

We do not sell, trade, share, or rent your Personal Information to unaffiliated third parties.

We will not disclose your Personal Information to any third party except as necessary for a legitimate use as described in this Policy, in connection with a bona fide legal dispute (where the information is relevant and in response to a valid, compulsory legal process), or as otherwise required by law.

In the event of a merger, acquisition, bankruptcy, or other sale or disposition of all or a portion of Meltzer Hellrung’s assets, we may disclose Personal Information to the acquiring party(s). In that case, the successor’s use of your Personal Information will continue to be subject to this Policy unless a court orders otherwise or the successor notifies you that your Personal Information will be subject to their own privacy policy. If the successor sends you such a notification, it will include an opportunity for you to opt out. If you submit any Personal Information after such a transfer, that information will be subject to the successor’s privacy policy.

 

Your Choices & Accuracy of Your Personal Information

You always have the choice whether or not to provide Personal Information to Meltzer Hellrung. As indicated above, our Services generally require that you provide Personal Information for processing and transfer, but doing so is entirely at your discretion. If you choose not to provide required Personal Information, you can still use any portion of our Services that do not require Personal Information.

If you do provide us with Personal Information, we want to make sure it remains accurate and up to date. You can use the tools that we make available through our Services to modify or remove certain Personal Information. If you need to correct or update any other part(s) of your Personal Information, you can submit a change request directly to Meltzer Hellrung by emailing us at voyager.help@meltzerhellrung.com. Please be sure to include sufficient details to allow us to make the necessary changes.

 

Information Security and Protection of Personal Information

Meltzer Hellrung uses commercially reasonable security and backup measures to protect the information submitted to us. No method of transmission over the Internet or method of electronic storage and security is 100% secure, though. While we always strive to protect your Personal Information, we cannot guarantee its absolute security. We encourage all our users to retain copies of all uploaded information on their own systems, to adhere to all corporate security policies or guidelines pertinent to your situation, and to practice personal habits of digital security.

In the unfortunate event that your Personal Information is compromised, we may notify you at the email address you have provided to us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation.

 

Third Party Links

Our Services may offer or contain links to third party websites or services that are not under our control. Any such links are offered as a convenience only and we are not responsible for the privacy practices employed by any such third party website or services. We encourage you to note when you leave our Site and to read the privacy statements of any third party website before submitting any of your Personal Information.

 

Children’s Privacy

The Site is not directed to children under the age of 13 and we do not knowingly collect any Personal Information from children under the age of 13 without parental consent. If we learn that a child under the age of 13 has provided us with Personal Information, or that such Personal Information has otherwise been inadvertently collected, we will delete it in accordance with applicable law.

 

California Privacy

California residents have additional rights regarding the privacy and disclosure of Personal Information, including, but not limited to a right to request that Meltzer Hellrung not sell their Personal Information, as well as a right to be informed about our other uses and disclosures of their Personal Information.

Meltzer Hellrung does not sell your Personal Information, and we use and disclose Personal Information solely in accordance with this Policy. If you are a California resident and would like additional information about our use of your Personal Information, please contact us as indicated below. If we ever decide to sell Personal Information, we will update this Policy and include a link entitled “Do Not Sell My Personal Information” in order to provide you with an opportunity to opt out of any sales of your Personal Information.

 

California Do Not Track Notice

California law requires websites to disclose whether they and/or any third party(s) collect Personal Information about their users’ online activities over time and across different sites. California law also requires that we disclose how we respond to “do not track” signals and similar mechanisms.

We do not track you over time or across third-party websites. As such, we do not respond to “do not track” signals. If you would like to learn more about browser tracking signals and “do not track” generally, please visit https://allaboutdnt.org.

 

Nevada Privacy

If you are a Nevada resident, you may ask us to add you to our opt-out list for possible future sales of certain information that we have collected or will collect about you. To submit such a request, please contact us as indicated below.

 

European Union Privacy

Meltzer Hellrung complies with the provisions of the European Union’s General Data Protection Regulation (“GDPR”) as to the Personal Information in its possession of E.U.-based persons (“data subjects”). We only process Personal Information on data subjects where we have a lawful basis to do so, which may include the consent of the person (as in the case of Site visitors who provide their information), compliance with a legal obligation, or the legitimate interest of the controller or a third party.

Under GDPR, E.U. data subjects are afforded specific rights with respect to their Personal Information.

Any Personal Information we collect from you is processed in the legitimate interest of our business and providing our Services to you as the lawful means of such processing. As applicable, Meltzer Hellrung may operate as a data controller or a data processor from time to time. You may withdraw your consent to our processing of your Personal Information at any time as described below. We will only retain your Personal Information for the time necessary to provide you the Services to which you have consented, to comply with the law and in accordance with your rights below. As an E.U. data subject, you can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

  • Access. You may email us at help@meltzerhellrung.com to request a copy of the Personal Information about you which we currently maintain.
  • Automated Processing and Decision-Making. You may email us at help@meltzerhellrung.com to request that we stop using your Personal Information for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your Personal Information. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your Personal Information.
  • Correction or Rectification. You can correct what Personal Information we maintain by accessing your Voyager account directly (as applicable), or by emailing us at help@meltzerhellrung.com to request that we correct or rectify our files. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
  • Restrict Processing. When applicable, you may restrict the processing of your Personal Information by submitting a request via email to help@meltzerhellrung.com. In your email, please explain how you wish us to restrict processing of your Personal Information. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your Personal Information. Where applicable, we will ensure such changes are shared with trusted third parties.
  • Object to Processing. When applicable, you have the right to object to the processing of your Personal Information by submitting a request via email to help@meltzerhellrung.com. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your Personal Information. Where applicable, we will ensure such changes are shared with trusted third parties.
  • Portability. Upon request and when possible, we can provide you with copies of your Personal Information. You may submit a request via email to help@meltzerhellrung.com. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.
  • Deletion. If you should wish to cease use of our Services and have your Personal Information deleted, then you may submit a request by emailing us at help@meltzerhellrung.com. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

 

Consent to Transfer

Meltzer Hellrung is operated in the United States. If you are outside of the United States, please be aware that any information we collect will be transferred to and processed in the United States. By using our Services, or otherwise providing us with Personal Information, you understand and consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as, or conflict with, those in the country where you reside and/or are a citizen.

 

Questions or Comments

If you have any questions or comments about this Policy, the practices, or use of the Site or Services, please feel free to contact us by email at voyager.help@meltzerhellrung.com, or by mail at the following address: Meltzer Hellrung LLC, 211 S. Clark Street, Suite 735, Chicago, IL 60690, Attn: Data Privacy.