This Privacy Policy applies to The Global Sky, our subsidiaries and affiliates, and any Services that link directly to this Privacy Policy (collectively, “we”, “our”, or “us”). We are committed to providing our applicants with excellent service. As part of this commitment, we take the trust our applicant and site visitors place in us very seriously. We recognize that it is our responsibility to inform you of our personal information collection practices through our Privacy Policy.

We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices.

In some instances, we are engaged directly by travel partners, corporations and business groups, which results in our processing of personal information on the behalf of such travel partners, corporations, or business groups. In these circumstances, you should address any concerns regarding the processing of your personal information directly with the party with whom you have a primary relationship, where applicable.

1. The Personal Information We Collect

Our suite of services include travel protection and insurance services; passport, travel visa and document assistance; background checks and clearance forms; immigration services; and travel information.

Personal Information We Collect Directly.

By using our websites, apps, and/or our services (“Services”), we may collect and request information, including personal information, which includes your name, address, telephone number, date of birth, marital status, government IDs such as birth certificate, driver’s license or passport images or numbers, employment history, educational background, tax status, employee number, job title and function, expatriate status and e-mail address. We may collect this information from you directly or with your consent when permitted by applicable law. Where required for the Services, we collect certain personal documents such as passport copies, educational documents, CVs, visa copies, birth certificates, and other documents.

Personal Information We Collect Automatically. Other information we collect automatically from your device, which may be considered personal information in your jurisdiction, or from third parties may include the following, such as:

    Unique IDs such as a cookie placed on a computer;

    Internet Protocol address (“IP address”);

    Information about devices such as information contained in HTTP headers or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings, and information about or from the presence or use of “apps” on mobile devices; or

    Publicly available information about you.

Sensitive Personal Information. If, for instance, we are handling your visa or immigration matter, additional information may be requested by the application forms of the destination country. These additional items can include items such as your personal and family information, educational background, employment history, travel history, and financial records. If required by relevant visa or governmental authorities, additional sensitive information can include ethnicity, race, religion, trade union membership, health related information, and information about criminal history where permitted by law.

2. How Personal Information Is Used

We may use your personal information in the following ways and for the following purposes based on the specific Services and/or your interaction with us, including, for example, to:

                Communicate with You: We collect personal information about you when subscribe to newsletters or when you otherwise communicate with us. This includes your name, contact information, and scope of your inquiry. We may also use your email address to send you reminders of expiring visas, passports, or immigration status. If you would like to discontinue receiving this information. Calls to our call center may be recorded for quality assurance, security, and training purposes.

                Interact at Events: We collect personal information from you that you choose to provide to us at virtual or in person events (e.g., to our employees or other representatives). We collect the personal information that you choose to provide to us, which may include, for example, your contact information and information about Services you may be interested in obtaining.

                Administration: for administrative purposes, including to manage our inventory; to help us better understand how our Applicant access and use our Services, including the pages viewed, or other Services activity; to maintain security and operability of our Services (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you, others and us; to enforce this Privacy Policy, our Terms of Use, and other policies.

                Research and Development/Analytical Purposes: for research and development purposes, including to improve our Services and applicant experience; to understand what parts of our Services are most popular or to improve upon our Services; to understand our applicants demographics; and for other research and analytical purposes.

                Legal compliance: to comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.

                Protection of you, us and others: where we believe it is necessary to protect you, us and others, including, without limitation to detect, prevent, and respond to fraud, security incidents, or other issues where we believe it is appropriate to protect us and others.

                Work with our Trip Providers: For example, we may partner with an airline, hotel, school, association, corporation, travel agency or credit card company to provide Services to their members or frequent travelers. Please review our partner’s privacy policy for their privacy practices.

                Follow-Up Services: In many instances such as visa extensions, permanent residency, and other cases related to changes in employment, the Services we provide require follow-up services. If such follow-up is required, the information we have collected previously is used to provide the additional related Services for which we have been engaged.

3. How We May Disclose and Transfer Personal Information

We may disclose and transfer personal information we collect for the purposes described above, and to service providers and third parties as follows:

                Affiliates and Subsidiaries. To support and provide the Services including, as applicable, to process trip and booking requests, complete your visa, document legalization, or immigration process request as necessary to provide visa and immigration services to you. This may include providing sensitive data required for immigration process request to visa application centers, logistics companies, and/or translators/solicitors. We may also disclose certain information to improve our services, provide superior applicant service, and identify market opportunities.

                Vendors and Service Providers. To our service providers, processors and others who perform functions on our behalf. These may include, for example, IT service providers, help desk, chatbots, analytics providers, and consultants. Additionally, we may share images you have uploaded with image review vendors to enable more efficient processing of your images for visa and travel purposes.

                Trip Providers. To support and provide the Services, including to help you book accommodation, travel, and to enable or facilitate entry requirements as may be required, including invitation providers to secure official invitations related to visa applications or entry requirements, and background check providers as required by the destination country.

    Partners and Third Parties, Including Third-Party Platforms, Providers, and Networks. To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve our Services and operations, to develop services and features, and for internal quality control and training purposes. We also share information to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also (and, where required by applicable law, with your consent) make certain information (such as browsing information) available to third parties in support of our campaign management.

                Travel Companions (e.g., Friends and Family). To support and provide the Services, including if you or your friend/family member organize group trips.

                Government Entities. To support and provide the Services, including as necessary for visa applications, immigration services, and logistics purposes. Sensitive data may be disclosed as necessary.

                Applicant and Companies. To support and provide the Services, including if we are providing services on behalf of a business.

    To Others As Required by Law. We may also disclose personal data to third parties to the extent permitted by applicable law and legal obligations. This may include regulators, government entities, and law enforcement as required by law or legal process, subject at all times to obligations under relevant laws. In addition, it may include certain disclosures that we are required to make, such as the names of sweepstakes and contest winners.

We may also disclose your personal information in the following circumstances:

                Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.

                Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and act in response to violations of our Terms of Use. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

                Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may, to the extent permitted by applicable law, use, disclose, and otherwise process aggregate and deidentified information related to our Services with third parties for quality control, analytics, research, development, and other purposes.

    Other Disclosures. We may disclose personal information in other ways not described above, including as required or permitted by applicable law. If necessary, we will notify you and, if necessary, obtain your consent.

4. Cookies and Tracking Technologies

We and our providers use cookies, pixel tags, and other similar tracking mechanisms to automatically collect personal information about browsing activity, type of device, and similar information within our Services. We use this personal information to, for example, analyze and understand how you access, use, and interact with us through our Services; to identify and resolve bugs and errors in our Services; to assess, secure, protect, optimize, and improve the performance of our Services; for advertising, measurement and analytics purposes; and to personalize content in our Services. We may also aggregate personal information to analyze trends, administer our Services, and gather broad demographic information.

Cookies. “Cookies” are alphanumeric identifiers we transfer to your device’s hard drive through your web browser for tracking purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within the Services.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.

Third Party Analytics. We use third party tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Services. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Services to provide us with reports and metrics that help us evaluate usage and improve our Services and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to manage how your personal information is used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Tracking. We and our providers may use the personal information we collect about you within our Services and on other third-party websites and services to help us and other third parties identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Services.

Do Not Track. Currently, our Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed below (e.g., by disabling cookies).

Development of new and improvement of existing technologies. We process the necessary data as part of the development of new technologies and the improvement of existing technologies in order to improve our services and set new standards in the area of data protection and information security. This includes in particular the areas of machine learning, artificial intelligence, and deep learning. In doing so we only use pseudonymized or aggregated data as far as technically possible.

Notice of Collection and Use of Personal Information

We may collect and use the following categories of personal information about you as described below.

    Personal Identifiers such as a real name, alias, postal address, images of your face, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. We may obtain this information from (1) you, when you use our website and social media platforms or otherwise communicate with us; (2) publicly available databases; (3) event sponsors, when they share the information with us; and (4) referral sources. We may share this information with vendors who provide services on our behalf, such as to provide services to you and manage our relationship with you.

                Internet and other electronic network and app activity information such as browsing history, search history, and information regarding your interaction with an internet website, application or advertisement. We may obtain this information from you and through the use of website or app cookies and web beacons. We may obtain this information from you and share it with vendors who provide services on our behalf.

                Geolocation information. We may obtain this information from you and your devices through various location technologies (such as GPS) and share this information with vendors who provide services on our behalf.

                Professional, employment-related, and educational information. We may obtain this information from you, employment recruiters and referral sources when you apply for a job with us or become employed by us. We may use and share this information with vendors who provide services on our behalf.

                Sensitive Personal Information. Additional sensitive information can include driver’s license number, passport number or other similar identifiers, ethnicity, race, religion, trade union membership, health related information, biometrics, government identifiers, precise geolocation, and information about criminal history.

                Inferences drawn from any of the categories of personal information listed above to create a profile about you regarding your preferences, characteristics, psychological trends, predispositions, behavior attitudes, intelligence, abilities and aptitudes. We may develop these inferences internally or obtain this information from vendors who provide services on our behalf.

Sensitive Personal Information. We do not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about applicants, or in any way that would require Zoom to provide a right to limit under the CCPA.