Privacy Policy

Nomadic USA LLC, and our related affiliates and subsidiaries (collectively, “Nomadic” or "we") want to ensure that our clients, their employees, and any affected data subjects ("you") are informed about the security and use of the personal data that we receive and process on your behalf. This privacy policy will explain how our organization processes the personal data we collect from you when you use our website and associated media platforms, sign up to our newsletter or purchase a product or service.

If you are accessing Nomadic under an agreement with your employer, Nomadic will be a processor of your data, not a controller and your employer will be the data controller. Where Nomadic determines the reasons for which we use your personal data and the means of processing your personal data, it is the controller and is responsible for your personal data.

CONTACT US

If you have any questions about this privacy policy or our privacy practices, please contact Jack Stokes in the following ways:

Full name of legal entity: Nomadic USA LLC

Email address: compliance@gonomadic.com

Postal address: 550 Broad Street, Suite 1006, Newark, NJ, 07102, USA

Telephone number: +1 (848) 244-0652

Topics:

• Information we collect
• Disclosures of your personal data
• International transfers
• How we collect your personal data
• How we store your personal data
• How we protect your personal data
• Your data protection rights
• Marketing
• Cookies
• Privacy policies of other websites
• Changes to our privacy policy
• How to contact the appropriate authority

INFORMATION WE COLLECT

Nomadic collects certain personal data about you and, if required, your family members and employer for the purposes of providing services. We will not be able to provide the services requested if we are not provided with all relevant personal data. In all instances we will not request more information than is necessary to provide the service requested. Set forth below are examples of the types of information that we may be required to collect:

• Identity Data: this includes name, date of birth, marital status, passport number, birth certificates and gender.
• Immigration-related Data: this includes your citizenship(s), your country of birth, visas you held or currently hold, as well as digital copies of visas and passports
• Contact Data: this includes address, email address and telephone numbers.
• Employment Data: this includes employment history, educational background, CV/resume, tax status, employee number, job title and function, expatriate status, etc.)
• Transaction Data: this includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical data: this includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and other media platforms.
• Profile Data: this includes your username and password, purchases or orders made by you, feedback and survey responses.
• Usage Data: this includes information about how you use our website, products and services.
• Marketing and Communications Data: this includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Category Personal Data

We may also collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health, and genetic and biometric data). We may also collect Criminal Convictions Data about you (this includes details of any offenses and/or criminal convictions).

Governments worldwide require the collection and processing of a wide variety of personal data from foreign nationals seeking to enter the country. Governments require this information for reasons such as the protection of borders, health, sovereignty, national security, and the regulation of the local employment market. Certain categories of personal data may be considered “sensitive” or “special category” and are subject to a higher level of data protection.

In the context of the services we provide, Nomadic collects special category personal data when the submission of such data is necessary to comply with the legal obligations of the country in which you are seeking a visa or work permit. In addition, Nomadic may need to inquire about certain special category personal data in order to provide consultative advice as to your eligibility to travel to or obtain an immigration benefit from a specific country. For instance, we may need to ask whether you have been previously convicted of any criminal offenses, have certain political affiliations, or other personal matters when the local applicable immigration laws would require such data for purposes of preparing an application or petition on your behalf or evaluating whether certain personal data would bar you from entering the country.

DISCLOSURES OF YOUR PERSONAL DATA

We will not sell, share, transfer, rent, use, or distribute your personal data for purposes other than those set out in the table below unless required by law. We may share your personal data with the parties set out below for the purposes set out in the table below:-

• Internal third parties: other companies in the Nomadic group who are based in the United Kingdom and the United Arab Emirates and provide administration or advisory services.
• External third parties:
  • Service providers acting as processors based in various countries such as translators, couriers or education evaluation services.
  • Profession advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide services to Nomadic.
  • Government agencies and immigration authorities.
  • Regulators and other authorities who require reporting of processing activities.
  • Your employer or any third party appointed by them such as a relocation provider.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the EEA due to the nature of the services we provide and so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring an adequate safeguards in place including (i) only transferring your personal data to countries that have been deemed to provide an adequate level of protection; and (ii) the use of specific contractual clauses that have been approved.

HOW WE COLLECT YOUR PERSONAL DATA

You directly provide Nomadic with most of the data we collect. We collect and process data when you:

• Create or update your profile on our online portal or mobile applications.
• Purchase our products or services.
• Voluntarily complete online questionnaires or forms.
• Consult with us by email, phone, videoconference, or in person.
• Use or view our website via your browser’s cookies.

Nomadic will also automatically collect Technical Data about your equipment, browsing actions and patterns when you use or interact with our website. We collect this personal data using cookies, server logs and other similar technologies. Please see our cookie policy below for further details.

Nomadic may also receive your personal data from third-party sources, such as:

• Credit reference agencies (when we process an order, we may use resulting information from credit reference agencies to prevent fraudulent purchases).
• Former employers, educational institutions you attended, travel management companies, relocation companies, and your current or prospective employer.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data where the law allows us to. Nomadic uses your personal data in the following circumstances:

• Where we need to perform the contract that we are about to enter into or have entered into with you or your employer including;
• Where is it necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests including:
• Where we need to comply with a legal obligation including record-keeping requirements.

Generally, we do not rely on consent as a legal basis for processing your personal data. However, we do rely on your explicit consent to store or use special categories of personal data and data relating to criminal convictions. You are entitled to withdraw your consent at any time. You may do so by contacting us once an order has been placed.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the way we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Purpose/activity	Type of data	Lawful basis for processing
To respond to information requests from you	Identity Contact Profile	Performance of a contract with you
To register you as a new customer	Identity Contact Profile	Performance of a contract with you
To process your order	Identity Immigration-related Contact Financial Employment Special Category Criminal Convictions	Performance of a contract with you Necessary for our legitimate interests (to recover payments due to us) Explicit consent (in respect of Special Category Data and Criminal Convictions Data only)
To complete, process and submit immigration, visa and related filings, consular services and obtain immigration-related documentation	Identity Immigration-related Contact Financial Employment Special Category Criminal Convictions	Performance of a contract with you Explicit consent (in respect of Special Category Data and Criminal Convictions Data only)
In our Visa assessment tool	Identity Immigration-related	Performance of a contract with you
To analyze immigration trends	Identity Immigration-related	[Necessary for our legitimate interests (to look at processing times and government approval rates)]
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To conduct checks to identify you and verify your identity	Identity Contact	To comply with our legal and regulatory obligations
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identify Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation

HOW WE STORE YOUR PERSONAL DATA

Nomadic securely stores your personal data at a Microsoft hosting center in Ireland.

Nomadic will keep your personal data for only as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirement. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

HOW WE PROTECT YOUR PERSONAL DATA

We seek to ensure that any personal data that we hold about you is accurate, complete, current and otherwise reliable based on data you or an employer provide in order to provide the immigration consulting and legal services. We seek to collect only that personal data that is adequate, relevant and not excessive for these purposes.

We maintain appropriate administrative, technical, organizational, and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of personal data, as required by law and client contract, where applicable.

We educate our employees and strive to maintain appropriate standards of conduct with regard to the protection of personal data.

We take steps to require that third parties who assist in our provision of services abide by all applicable privacy and data protection laws and prohibit them from using your information other than in connection with the services they have been engaged to provide.

YOUR DATA PROTECTION RIGHTS

Nomadic would like to make sure you are fully aware of all of your data protection rights. If European Union (EU) or United Kingdom (UK) data protection law applies to the processing by us of your information, you have the following rights:

The right to access

You have the right to request Nomadic for copies of your personal data. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

The right to rectification

You have the right to request that Nomadic correct any information you believe is inaccurate. You also have the right to request that Nomadic complete information you believe is incomplete.

The right to erasure

You have the right to request that Nomadic erase your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

The right to restrict processing

You have the right to request that Nomadic restrict the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

If your request is approved, we will halt further processing of the information but may continue to store it in our systems. If you request that your data be deleted, it will be subject to approval review as described above and will be deleted wherever possible and permissible by law.

The right to object to processing

You have the right to object to Nomadic’s processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

In some cases, we may be entitled to reject the request if we can show that we have compelling legitimate grounds for the processing that outweigh your data privacy freedoms, interests, and rights.

If your objection request is approved, we may continue to store the personal data at issue for as long as needed to comply with applicable law but will ensure that it will no longer be processed in any other way.

The right to data portability

You have the right to request that Nomadic transfer the information we have collected to another organization, or directly to you, as long as:

1. We hold the information electronically;
2. You provided us with the information; and
3. We collected or used the information on the basis of your consent or a contract you entered into with us

The right to withdraw consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

Please note:

If you make a request, we will try to respond to all legitimate requests within one calendar month to respond. If the request is complex or you have made a number of requests, it may take us longer than a month, but we will provide you with an explanation of why we need more time within one month and will keep you updated. We are under no obligation to comply with the request if it is manifestly unfounded or excessive.

If you would like to make a request, please contact us:

Call us at: +1 (848) 244-0652

Or write to us: compliance@gonomadic.com

MARKETING

Nomadic would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies. We will only send you marketing materials when you have opted in to receive them.

You have the right at any time to stop Nomadic from contacting you for marketing purposes by following the opt-out links on any marketing message sent to you or by contacting us at any time.

COOKIES

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our website or mobile applications, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

Nomadic uses cookies in a range of ways to improve your experience on our website or mobile applications, including:

• Keeping you signed in
• Understanding how you use our website or mobile applications

What types of cookies do we use?

There are several different types of cookies, but our website and mobile applications use:

• Functionality Cookies. Nomadic uses these cookies so that we recognize you on our website or mobile applications and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising Cookies. Nomadic uses these cookies to collect information about your visit to our website or mobile applications, the content you viewed, the links you followed and information about your browser, device, and your IP address. Nomadic sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website or mobile applications.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website and mobile application features may not function as a result.

Privacy policies of other websites

The Nomadic website and mobile applications contain links to other third-party websites. on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Changes to our privacy policy and your duty to inform us of changes

Nomadic keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated 29 December 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Nomadic has not addressed your concern in a satisfactory manner, you may contact the appropriate regulatory authority. In the UK, the regulatory authority is the Information Commissioner’s Office.