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PRIVACY POLICY

Effective Date: August 11, 2023.

This Privacy Policy applies to CIBT Inc., CIBTVisas, Entriva, Newland Chase,
Blair Counselor, 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 customers with excellent service. As part of this
commitment, we take the trust our customers 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. Our
Privacy Policy outlines:

PRIVACY POLICY

 1.   The Personal Information We Collect
 2.   How Personal Information Is Used
 3.   How We May Disclose and Transfer Personal Information
 4.   Cookies and Tracking Technologies
 5.   Your Choice
 6.   Privacy Notice for California Consumers
 7.   Other State Privacy Rights
 8.   Security
 9.   Data Retention
 10.  How to Opt-Out of Further Communication
 11.  Links to Other Websites
 12.  Personal Information from Children
 13.  Additional Information for Individuals Located in the EEA/UK
 14.  How to Contact Us
 15.  China Addendum
 16.  Canada Addendum

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. We will note the effective date of the latest version of our Privacy
Policy at the beginning of this Privacy Policy.

In some instances, we are engaged directly by travel partners, corporations, or
business groups, including your employer, 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.

If you are a resident of California, certain U.S. States, China, or Canada, you
may have certain specific rights in connection with your personal information:
please refer to the section or addendum relevant to your jurisdiction of
residence for further information.

We have designated a Privacy Officer who is responsible for our compliance with
this Privacy Policy. The Privacy ‎‎Officer may be contacted as described below
in section 14.‎


1. THE PERSONAL INFORMATION WE COLLECT

Our suite of services includes travel, tour, flight, and hotel bookings; travel
protection and insurance services; passport, travel visa, driving permit 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, e-mail address and payment and transaction information. We may collect
this information from you directly (e.g., form consumer surveys), or, with your
consent or when permitted by applicable law, other parties such as your travel
agent; family, friends, or travel companions; government agencies; trip
providers (e.g., accommodations and transportation services, attractions and
tour providers, travel insurance companies, or other booking companies); and/or
your employer. 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 or advertising IDs;
 * Internet Protocol address (“IP address”);
 * Information about a device 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 or your agents’ interaction
with us, including, for example, to:

 * Create an Account: You may create an account on certain of our Services
   including on our websites and apps. The type of personal information that we
   collect from you varies, but includes, at a minimum, your name and contact
   information.
 * Providing our Services, Including Visa Services: When you or your agent
   obtains Services or makes a purchase from us, including requesting visa
   services, we will collect your name, billing and shipping addresses, email,
   phone number, payment card information (which is processed through our
   payment processor), and items or Services purchased. When we assist you with
   obtaining a visa, our collection and use of your personal information is
   dependent on the requirements of the country issuing the visa so our
   practices may vary.
 * When you Book with us: You can book a variety of vacation or holiday services
   and accommodations as well as additional specific services. If you enquire
   about a booking, by telephone, email, chat or in any other way, we process
   the necessary personal information to be able to provide you with suitable
   offers and Services. If you book through our properties, we collect and
   process the necessary personal information for the conclusion of the
   contract, the implementation of your booking and for additional support. This
   also includes the transfer of your personal information to the respective
   providers of the booked services.
 * When you Upload Photos. When using our Services to apply for or obtain a visa
   or for other travel purposes, we may need to collect an image of you. We use
   these images to provide our Services.
 * Sign Up for Information or Marketing: We collect your name and contact
   information if you sign up receive information or marketing from us.
 * Post to our Services or Our Social Media Pages: You may post, or grant us
   permission to post, your photos, reviews, ideas or other content to our
   Services, as indicated, and on our social media pages.
 * 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, see the How to Opt-out of Further Communication section
   below. Calls to our call center may be recorded for quality assurance,
   security, and training purposes.
 * Participate in Promotions: If you participate in a promotion or sweepstakes,
   then we will collect the personal information that you submit as part of your
   entry. We may offer promotions or sweepstakes in connection with other
   entities, and, in some cases, our promotions or sweepstakes will be governed
   by additional or different privacy notices. We will notify you at the time of
   collection if your personal information will be subject to an additional or
   different policy. Some jurisdictions require us to post personal information
   of winners.
 * 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 customers access and use our
   Services, including the pages viewed, ad impressions clicked, 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, products, and customer
   experience; to understand what parts of our Services are most popular or to
   improve upon our products and Services; to understand our customer
   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.
 * Other uses: that we notify you of or that you may consent to.


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 and your family. 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 products and services,
   provide superior customer 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, tourist attractions, tours, 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.
 * Business Partners and Third Parties, Including Third-Party Platforms,
   Providers, and Networks. To better understand how users access and use the
   Services, and our other products and offerings, and for other research and
   analytical purposes, such as to evaluate and improve our Services and
   business 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 marketing,
   advertising, and 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.
 * Customers and Clients. 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:

 * In Support of Business Transfers – If we or our affiliates are or may be
   acquired by, merged with, or invested in by another company, or if any of our
   assets are or may be transferred to another company, whether as part of a
   bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer
   the personal information we have collected from you with or to the other
   company. We may also disclose certain personal information as necessary prior
   to the completion of such a transaction or other corporate transaction such
   as a financing or restructuring, to lenders, auditors, and third-party
   advisors, including attorneys and consultants.
 * 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
   business and the 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 marketing, 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.

Third-Party Advertising. We work with third-party ad networks, analytics,
marketing partners, and others (“third-party ad companies”) to personalize
content and display advertising within our Services as well as to manage our
advertising on third-party sites. We and these third-party ad companies may use
cookies, pixels tags, and other tools to collect browsing and activity
information within our Services (as well as on third-party sites and services),
as well as IP address, unique ID, cookie and advertising IDs, and other online
identifiers. We and these third-party ad companies use this personal information
to provide you more relevant ads and content within our Services and on
third-party sites, and to evaluate the success of such ads and content.

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.


5. YOUR CHOICES

You have certain choices regarding the personal information we collect about
you. For example, you may:

 * Opt Out of Promotional Email Communications. You may opt out of promotional
   emails by clicking on the unsubscribe link in the email. To opt-out of
   further communications, contact us by email at dpo@cibt.com.
 * Opt Out of Interest-Based Advertising. We use third party providers to help
   us provide advertisements to you that are tailored to you based on interests
   that you have expressed on our Services or elsewhere ('Interest-Based Ads').
   Any tracking done by third parties ad partners through cookies and other
   mechanisms are subject to those parties own privacy policies. You may manage
   Google cookies by clicking on:
   www.google.com/settings/ads/onweb/optout?hl=en.
   
   You also may opt out of receiving Interest-Based Ads from many third-party ad
   networks, such as those provided by members of the Network Advertising
   Initiative ('NAI') and the Digital Advertising Alliance ('DAA'). For more
   information regarding Interest-Based Ads by NAI members and DAA members,
   including how to opt out of Interest-Based Ads provided by NAI and DAA
   members, please visit their respective websites:
   optout.networkadvertising.org and optout.aboutads.info. You must opt out on
   each browser and on each device.
 * Industry ad choice programs. You can also control how participating
   third-party ad companies use the information that they collect about your
   visits to our websites and use of our mobile applications, and those of third
   parties, in order to display more relevant targeted advertising to you.
 * U.S. Users: you can obtain more information and opt out of receiving targeted
   ads from participating third-party ad networks at
   aboutads.info/choices (Digital Advertising Alliance). You may also download
   the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to
   help control interest-based advertising on apps on your mobile device.
 * EU Users: youronlinechoices.eu (European Interactive Digital Advertising
   Alliance)
 * Canada Users: youradchoices.ca/choices/ (Digital Advertising Alliance of
   Canada)
 * Japan: http://www.ddai.info/optout (Data Driven Advertising Initiative in
   Japan)

Please note that opting out of participating ad networks does not mean that you
will not see advertisements at all, and you will continue to receive
advertisements on other websites and from companies that do not participate in
the above programs. Even if you opt out of interest-based ads, you may still see
ads based on factors such as your general location derived from your IP address,
your browser type and recent, previous searches related to your current search.

Please note that even if you opt out of receiving marketing communications from
us, we may still send you communications about your account or any products or
services you have purchased from us and we will still respond to your inquiries
and requests for information.

Mobile Device Settings. In addition to the above, some of our apps may include
third-party advertising and analytics. For iOS devices, you can turn off 'Allow
Apps to Request to Track' setting (go to Settings>Privacy> Tracking). For
Android devices, turn on 'Opt out of Ads Personalization' setting (go to
Settings>Privacy>Tracking and select/toggle on Opt out of Ads Personalization).
In addition, our apps may include analytics and related personalization that you
can opt out of through an in-app settings for that app (you can access this
setting from the main menu).


6. PRIVACY NOTICE FOR CALIFORNIA CONSUMERS

Last Updated: May 26, 2023.

This Privacy Notice for California consumers supplements our Privacy Policy and
applies solely to California consumers.

This Privacy Notice uses certain terms that have the meanings given to them in
the California Consumer Privacy Act of 2018, as amended by the California
Privacy Rights Act of 2020, and its implementing regulations (the “CCPA”).
Consumers with disabilities may access this Statement in an alternative format
by sending an email to dpo@cibt.com.

NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We may collect and use (and have collected in the previous 12 months) 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) joint marketing partners and 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 our products and services to you and manage our relationship with
   you.
 * Information necessary to provide our products and services to you such as
   order information and payment, credit and transaction information for billing
   purposes. We may obtain this information from you and share it with vendors
   who provide services on our behalf, such as to provide our products and
   services to you and manage our relationship with you.
 * Commercial information including products or services purchased, obtained or
   considered; and other purchase histories or tendencies. We may obtain this
   information from you and share it with vendors who provide services on our
   behalf, such as to provide our products and 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, such as to provide our products and
   services to you and manage our relationship with you.
 * 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, such as to
   provide products and services to you based on your geographic location.
 * 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, such as to
   manage our human resources activities or perform background checks.
 * Sensitive Personal Information. Additional sensitive information can include
   social security number, 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, such as to us with our business.

Sale and Sharing of Personal Information. Additionally, the CCPA defines 'sale'
as disclosing or making available to a third-party personal information in
exchange for monetary or other valuable consideration, and “sharing” means
disclosing or making available Personal Information to a third party for
purposes of cross-contextual behavioral advertising. While we do not disclose
Personal Information to third parties in exchange for monetary compensation, we
may disclose the following categories of Personal Information: identifiers,
profiles and inferences, and internet or other electric network activity
information to third-party advertising networks, analytics providers, and social
networks for purposes of marketing and advertising. We do not knowingly sell or
share any Personal Information about individuals who we know are under sixteen
(16) years old.

Sources of Personal Information. We collect personal information from the
following sources: directly from you; advertising networks; data analytics
providers; social networks; internet service providers; operating systems and
platforms; your friends; affiliated entities; partners (e.g., if we offer a
joint promotion); and government entities.

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

Purposes for Collecting and Disclosing Personal Information. We may use the
categories of personal information listed above for the purposes described in
our Privacy Policy in Section 3. In addition, we may use these categories of
personal information for certain business purposes specified in the CCPA, as
described below:

 * Performing services, including maintaining or servicing accounts, providing
   customer service, processing or fulfilling orders and transactions,
   processing images to verify usability, verifying customer information,
   processing payments, providing advertising or marketing services, providing
   analytics services, providing storage or providing similar services.
 * Auditing related to counting ad impressions to unique visitors, verifying
   positioning and quality of ad impressions, and auditing compliance with this
   specification and other standards.
 * Helping to ensure security and integrity to the extent the use of the
   consumer’s personal information is reasonably necessary and proportionate for
   these purposes.
 * Debugging to identify and repair errors that impair existing intended
   functionality. Short-term, transient use,
 * Short-term, transient use,
 * Providing advertising and marketing services.
 * Undertaking internal research for technological development and
   demonstration.
 * Undertaking activities to verify or maintain the quality or safety of a
   service and to improve, upgrade, or enhance the service.

CALIFORNIA CONSUMER PRIVACY RIGHTS

The CCPA provides you with certain rights regarding your personal information.
This section describes those rights and how to exercise them. Please note that
these rights are subject to certain conditions and exceptions. As noted above,
we provide Services to other businesses, which may mean that you need to contact
the business with whom you have a primary relationship to exercise these rights.
Where we believe this is the case, we will notify you.

Right to Know/Request Access. You have the right to know:

 * The categories of personal information we collected about you;
 * The categories of sources from which we collected your personal information;
 * The business or commercial purposes for collecting, selling, or sharing your
   personal information;
 * The categories of third parties to whom we have disclosed your personal
   information; and
 * The specific pieces of your personal information we have collected.

Right to Delete. Subject to certain conditions and exceptions, you have the
right to request we delete your personal information.

Right to Correct. Subject to certain conditions and exceptions, you have the
right to request that we correct inaccuracies in your personal information.

Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales”
and “sharing” of your personal information, as those terms are defined under the
CCPA, including using an opt-out preference signal. While we do not “sell”
personal information in the traditional sense (i.e., for money), our use of
third-party analytics and advertising cookies may be considered “selling” and
“sharing” under CCPA.

To exercise your right to opt-out of the “sale” or “sharing” of your personal
information, please click here or use the Do Not Sell or Share My Personal
Information link in the footer of our website.

We honor your right to opt out of “sales” or “sharing” as signaled by a
universal opt out signal or Global Privacy Control (“GPC”). To learn more about
GPC, you can visit the Global Privacy Control page at
https://globalprivacycontrol.org. If you download a supported browser or
extension and exercise your privacy rights with GPC, third-party advertising
cookies on our website will be blocked once our website detects a GPC signal. If
you visit our Services from a different device or from a different browser on
the same device, you will need to opt-out, or use an opt-out preference signal,
for that browser and/or device.

Right to Non-Discrimination. We will not discriminate against you for exercising
any of the rights described in this section.

Authorized Agents. You may designate someone as an authorized agent to submit
requests and act on your behalf.

To submit a request, please do so by emailing dpo@cibt.com or calling us at:
1-800-929-2428.

To help protect your privacy and maintain the security of your personal
information, we will take steps to verify your identity. If you request access
to your personal information, we may require you to log into your account or
provide any of the following information: contact information, one-time
password, information about your interactions with us or information that you
have submitted.

If you designate an authorized agent to make a request, we will require your
authorized agent to provide us with your written authorization permitting the
authorized agent to request access to your personal information on your behalf,
and we also will require you to verify your own identity directly with us.

In connection with your request, you must:

 * Provide sufficient information that allows us to reasonably verify you are
   the person about whom we collected personal information or an authorized
   agent.
 * Describe your request with sufficient detail that allows us to properly
   understand, evaluate, and respond to it.

FINANCIAL INCENTIVES

A business may offer “financial incentives” (as defined by the CCPA) for the
collection, sale or deletion of California consumers' personal information,
provided the incentive is not unjust, unreasonable, coercive or usurious, and is
made available in compliance with applicable transparency, informed consent, and
opt-out requirements. California consumers have the right to be notified of any
financial incentive offers and their material terms, the right to opt-out of
such incentives at any time and may not be included in such incentives without
their prior informed opt-in consent. From time to time, we may offer free
shipping or other incentives (such as a discount if you sign up for email
marketing from us). We will notify you of the incentive at the time of offer.


7. OTHER STATE PRIVACY RIGHTS

Residents of certain U.S. states may have additional rights under applicable
privacy laws, subject to certain limitations and exceptions. These rights may
include:

 * Right to Access/Know. To confirm whether we are processing your personal data
   and to access such personal data and obtain a copy of the personal data in a
   portable and, to the extent technically feasible, readily usable format.
 * Right to Correct. To correct inaccuracies in your personal data.
 * Right to Delete. To delete personal data provided to or obtained about you.
 * Rights to Opt-Out/Respond to GPC. To opt out of certain types of processing,
   including:
   * if applicable, to opt out of the sale of their personal information.
   * to opt out of our use of their personal information for purposes of
     targeted advertising.
   * If applicable, to opt out of our processing of personal information for
     purposes of making decisions that produce legal or similarly significant
     effects.
 * Right to Appeal. If we deny your request, you may appeal our decision by
   contacting us at dpo@cibt.com or (ii) calling us at: 1-800-929-2428.

You may submit a request to exercise your applicable state privacy rights by
contacting us at dpo@cibt.com or calling us at: 1-800-929-2428.


8. SECURITY

We have implemented safeguards that are intended to protect the personal
information that we collect from loss, misuse, and unauthorized access,
disclosure, alteration, and destruction. Please be aware that despite our
efforts, no data security measures can guarantee security.
There are also certain steps you can take to better protect against unauthorized
access to your personal information. For example, you should choose a strong
password that is unique to the Services (and do not reuse passwords across
multiple sites and services or share your password with others). If you believe
that your password or account has been compromised, please reset your password,
and promptly notify us at dpo@cibt.com.


9. DATA RETENTION

We will retain and use your personal information as long as is necessary for the
purposes described above or otherwise disclosed to you at the time of
collection, to comply with our legal obligations, government auditing
requirements, resolve disputes, and enforce our agreements (including those
agreed with our clients).


10. HOW TO OPT-OUT OF FURTHER COMMUNICATION

We provide users the opportunity to opt-out of receiving marketing
communications from us at their request. To opt-out of marketing communications,
contact us by email at dpo@cibt.com or click on the unsubscribe link at the
bottom of the email.


11. LINKS TO OTHER WEBSITES

This site may contain links to other sites. We are not responsible for the
privacy practices or the content of such sites. We encourage you to read the
privacy policies of these sites before transmitting any personal information to
third parties.

The website may include social media features, such as the Facebook Like button
and widgets, such as the “Share this” button or interactive mini-programs that
run on the website. These features may collect your IP address, which page you
are visiting on the website, and may set a cookie to enable the feature to
function properly. Social media features and widgets are either hosted by a
third party or hosted directly on the website. Your interactions with these
features are governed by the privacy policy of the company providing it.


12. PERSONAL INFORMATION FROM CHILDREN

We do not knowingly collect personal information from children. As a parent or
legal guardian, please do not to allow your children to submit personal
information without your permission. If we learn we have inadvertently received
personal information from a child, we will delete such information from our
records. If you are a parent of a child and believe we have collected your
child’s information, contact us at dpo@cibt.com.


13. ADDITIONAL INFORMATION FOR INDIVIDUALS LOCATED IN THE EEA/UK

Lawful Basis for Collecting Personal Information: We collect and process
personal information in order to fulfill your visa, passport, document
legalization, or immigration process request and our contract with you. This
information is collected and processed in accordance with local laws including
GDPR regulations in the European Union, United Kingdom and Switzerland. For
those individuals to whom the GDPR applies, general personal information is
collected and processed on the basis of the contract formed or to be formed
between us, but any additional sensitive personal information is collected and
processed under the lawful basis of consent. By placing the order and, where
necessary and permissible, giving your consent, you are giving us the following
rights:

 * The right to collect your personal information
 * The right to process your personal information
 * The right to share your personal information with third party providers and
   government entities as needed, such as Government Authorities, Visa
   Application Centers, Logistics Companies, Invitation Providers and/or
   Translators/Solicitors relevant to your request for services.

You maintain the right to revoke consent at any time by emailing dpo@cibt.com.

The Right to Have Your Personal Information Corrected, Amended or Deleted: At
any time, you have the right to request that we request a correction or
amendment of your personal information. You also have a right to request that we
erase the personal information you have provided to us. We will erase any
personal information as long as it is legally allowed to according the laws and
regulations in the countries in which we operate. In lieu of emailing us, go to
this link, https://cibtvisas.com/right-to-erasure. The following will then
occur:

 * We will acknowledge your request.
 * We will review your specific request and the country of its origin, and
   determine if we are lawfully allowed to oblige the request.
 * We will then either:
   * inform you that your personal information has been removed from our
     systems; or
   * inform you as to the date that we are legally allowed to remove said
     personal information from our systems given the nature of the personal
     information and the country of its origin.

The Right to Access Your Personal Information: At any time, you have the right
to access a copy of your personal information held by us.

The Right to Restrict Your Personal Information: You have the right to request
that we restrict processing of your personal information, if you contest the
accuracy of your Personal Information or the lawfulness of how we process of
your personal information.

The Right to Portability of Your Personal Information: You have the right to
receive your personal information in a structured, commonly-used and
machine-readable format. You also have the right to transmit your personal
information to another organization.

The Right to Object to Processing of Your Personal Information: You have the
right to object, on grounds relating to your particular situation, to how we
process your personal information, unless we demonstrate compelling legitimate
grounds for continuing such processing. You also have the right to object to any
automated decision-making (such as user profiling).

The Right to Withdraw Consent to Processing of Your Personal Information: In
instances where you have provided your consent for us to use your personal
information, you can withdraw your consent at any time with future effect. You
can do so by contacting us directly at dpo@cibt.com.

These rights may be limited, for example, if fulfilling your request would
reveal personal information about another person, or if you ask us to delete
information which we are required by law or have compelling legitimate interests
to keep. If you have unresolved concerns, you have the right to complain to a
data protection authority where you reside, where you work or where you believe
there has been an infringement of data protection laws.

International Transfer of Your Personal Information: Your personal information
may be stored and processed in any country where we have facilities or in which
we engage service providers. By using our Services you understand that your
information will be transferred to countries outside of your country of
residence, including the United States, which may have data protection rules
that are different from those of your country.

Some of the non-European Economic Area countries are recognized by the European
Commission, the UK and Swiss data protection authorities as providing an
adequate level of data protection according to EEA, the UK or Swiss standards
(the full list of these countries is available here). For transfers from the
EEA, the UK or Switzerland to countries not considered adequate by the European
Commission, the UK or Switzerland, we have put in place adequate measures, such
as standard contractual clauses adopted by the European Commission or contracts
approved by the Swiss Commissioner, to protect your personal information.

COMPLAINT TO SUPERVISORY AUTHORITY:

UK: If you consider that we have breached your rights under UK GDPR you may
complain to the data protection authority in the country in which you reside or
to the lead supervisory authority at https://ico.org.uk/concerns/ or by phone at
+44 303 123 1113.

EU: If you wish to lodge a complaint about our data privacy practices with a
regulatory authority in your country, you can find details at this link:
https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

Switzerland Individuals in Switzerland should contact the Swiss Federal Data
Protection and Information Commissioner (the Swiss Commissioner) for resolution.
Information regarding the Swiss Commissioner is located at:
https://www.edoeb.admin.ch/edoeb/en/home.html.

PERSONAL INFORMATION WE DISCLOSE

We may share some of your personal information with our other offices or
affiliates to provide you with information that will be relevant to your
interests and to connect you with advisors who may be useful to you. For these
purposes, your personal information may be processed in, or accessed from,
jurisdictions that do not have equivalent data protection laws to those in your
country of residence.

We safeguard your data within our group of companies through the use of European
Commission-approved standard contractual data protection clauses.

Personal information will be shared with companies providing services under
contract to us for the purposes described in this Privacy Policy that may be
located in a different country than you. When transferring your personal
information, we rely on European Commission-approved standard contractual data
protection clauses with service providers or approved binding corporate rules
that protect your personal information.

If you have any questions about our information handling practices or if you
wish to access your personal information you should contact our Data Privacy
Office at: dpo@cibt.com.

YOU MAY HAVE OTHER RIGHTS WITHIN THE EU AND UK AS WELL AS OTHER LOCATIONS.

We will retain your personal information only for as long as we need it for the
purposes described in this Privacy Policy, after which we will take steps to
delete your personal information or hold it in a form that no longer identifies
you.

HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information from you in the following ways:

 * By asking: We may collect personal information from you by asking that you
   provide it to us. We will only collect personal information that is needed to
   help us provide the Service you request.
 * Cookies: We uses cookies to enhance your experience while using our website.
   Cookies are small text files that reside on your computer to identify you as
   a unique user. Cookies may also allow us to track your status or progress
   when requesting our Services or information. We employ third-party cookies to
   perform functions on our behalf such as data analysis and marketing
   assistance. This data is used for specific functions that require broad-based
   user statistics, which help to improve the overall customer experience. If
   you choose, you can set your browser to reject cookies or you can manually
   delete individual or all of the cookies on your computer by following your
   browser’s help file directions. However, if your browser is set to reject
   cookies or you manually delete cookies, you may have some trouble accessing
   and using some of the pages and features that are currently on the website,
   or that we may put on the website in the future. We do not respond to web
   browser ‘do not track’ signals, however we will continue to monitor relevant
   legislation and policy updates and adjust our ‘do not track’ strategy as
   required.
 * Web Beacons: A web beacon is an electronic file on a web page that allows us
   to count and recognize users who have visited that page. Among other things,
   a web beacon can be used in HTML-formatted email to determine responses to
   our communications and measure their effectiveness. For instance, if you get
   an email from us and click on a link in that email to go to the website. You
   can generally avoid web beacons in email by turning off HTML display and
   displaying only the text portion of your email.
 * Web Server Logs: Web server logs are records of activity created by the
   computer that delivers the webpages you request to your browser. For example,
   a web server log may record the search term you entered or the link you
   clicked to bring you the webpage. The web server log also may record
   information about your browser, such as your IP address and the cookies set
   on your web browser by the server.


14. HOW TO CONTACT US

If you have any questions about this Privacy Policy, contact the Data Protection
Officer dpo@cibt.com, CIBT, Inc., ATTN: Data Privacy Officer, 1600 International
Drive Suite 600, McLean, VA 22102, or 1-800-929-2428.


15. CHINA ADDENDUM

If you resident in the People’s Republic of China (for the purpose of this
Privacy Policy only, excluding Hong Kong, Macau and Taiwan) (“China”), the
following clauses apply to our processing of your Personal Information. In case
of any discrepancies between this Addendum and the main body of the Privacy
Policy, this Addendum shall prevail.

 1. Data controller. The data controller who determines the purposes and means
    of the processing of your Personal Information is: Bill Coquelin,
    dpo@cibt.com.
 2. Update. If we update this Privacy Policy and the processing activities
    related to the update require your consent by the applicable Chinese data
    protection laws, we will use proper mechanisms (e.g. pop up window) to
    obtain your consent.
 3. Sensitive Personal Information. Under the Chinese data protection law,
    Sensitive Personal Information refers to Personal Information that, once
    leaked or illegally used, will easily lead to infringement of the human
    dignity or harm to the personal or property safety of a natural person,
    including ID card number, biometric recognition, religious belief, specific
    identity, medical and health, financial account, personal location tracking
    and whereabout of a natural person, as well as any Personal Information of a
    minor under the age of 14.
 4. How We May Disclose Personal Information. Other than official government
    offices and recipients in the country to which you intend to travel, we do
    not disclose your Personal Information to third-parties for their
    independent purposes and means of processing when we collect your data
    within China.
 5. Your rights to your Personal Information. Subject to conditions and
    requirements provided by the applicable data protection law, you may have
    the following rights to your Personal Information:
    * Right to access and request a copy of your Personal Information;
    * Right to rectify or supplement your Personal Information where it is not
      accurate or complete, after necessary verification;
    * Right to request the deletion of your Personal Information if (i) the
      purpose of the processing has been achieved or cannot be achieved, (ii)
      the processing is based on your consent and you withdraw the consent; or
      (iii) the processing violates any legal requirements;
    * Right to request your Personal Information to be transferred to another
      data controller, provided that such a request satisfies certain conditions
      to be set by the data regulator;
    * Where your Personal Information is used for automated decision and we use
      the decisions to send marketing messages or promotions, right to refuse
      such processing or request non-customized messages or promotions; and
    * Where your Personal Information is used for automated decision and such
      decision may cause material impact on your rights or interests, right to
      refuse to accept any determination that is made merely relying on the
      automated decision.
 6. Personal Information from Children. We do not knowingly collect Personal
    Information from children under the age of 14. As a parent or legal
    guardian, please do not to allow your children to submit Personal
    Information without your permission.


16. CANADA ADDENDUM

If you are a resident of Canada, the following ‎clauses apply to our processing
of your Personal Information, in addition to those clauses in the main body of
the Privacy Policy which are not intended to apply only in specific
jurisdictions (i.e. sections 6, 7 and 13). In case of any ‎discrepancies between
this Addendum and the main body of the Privacy Policy, ‎this Addendum shall
prevail. You may have different rights depending on your province or territory
of residence within Canada: please consult the section below relevant to your
province or territory of residence.

Unless otherwise allowed by the laws applicable in your province or territory of
residence, we will only ‎collect, use, or communicate your personal information
with your consent.‎ You are generally not obliged to provide your personal
information, however please note that we may be unable to process an application
on your behalf or provide certain services to you if you refuse to disclose
certain personal ‎information.‎

You have certain rights in relation with your personal information, the
particulars of which may vary depending on your province or territory of
residence. These include:

 * The Right to Withdraw Consent to Processing of Your Personal Information: You
   have the right to revoke consent to use or communication of your personal
   information at any time by emailing dpo@cibt.com. Please note however that we
   may be unable to process an application on your behalf or offer you ‎certain
   services if you withdraw your consent. Withdrawing your consent will not
   affect the ‎lawfulness of any processing which happened before such
   withdrawal, nor does it create an ‎obligation for us to delete personal
   information which we are otherwise allowed or required to ‎retain under
   applicable law.;
 * The Right to Have Your Personal Information Corrected or Amended: At any
   time, you have the right to request that we make a correction or amendment of
   your personal information (if we do not correct or amend your information to
   your satisfaction, we ‎‎will annotate the personal information under our
   control with a note that the correction was requested ‎but ‎not made‎); and
 * The Right to Access Your Personal Information: At any time, you have the
   right to access a copy of your personal information held by us, and to
   receive information about the ways in which that information is being used
   and a description of the individuals and organizations to whom that
   information has been disclosed. In some situations, we may not be able to
   provide access to certain personal information; if we refuse an access
   request, we will notify you in writing, document the reasons for refusal and
   outline further steps which are available to you.

If you are a resident of the province of Québec, the following rights are
available to you, in addition to the rights identified above:

 * The Right to Portability of Your Personal Information: You have the right to
   receive your personal information in a structured, commonly-used and
   machine-readable format. You also have the right to request that we transmit
   your personal information to another organization; and
 * The right to de-indexation: You have the right to request, in certain
   circumstances, that we cease disseminating your personal information or to
   ‎de-‎index any hyperlink that allows access to that personal information by
   technological means, if ‎‎such dissemination contravenes applicable law or a
   court.

These rights may be limited, for example, if fulfilling your request would
reveal personal information about another person, or if you ask us to delete
information which we are required by law or have compelling legitimate interests
to keep. If you have unresolved concerns, you have the right to complain to a
data protection authority where you reside, where you work or where you believe
there has been an infringement of data protection or privacy laws.

INTERNATIONAL TRANSFER OF YOUR PERSONAL INFORMATION:

Your personal information may be communicated, stored and processed outside of
your province or territory of residence, in any other province, territory, or
country where we have facilities or in which we engage service providers. By
using our Services you understand that your information will be transferred to
provinces, territories, or countries outside of your place of residence,
including the United States, which may have data protection rules that are
different from those of your country. Such ‎transfers will only be made in full
compliance with all the requirements of applicable privacy laws, and we will
ensure that adequate safeguards are in place so that your personal information
will receive an adequate degree of protection.‎ However, you acknowledge that
your personal ‎information may be processed and stored in foreign ‎jurisdictions
and that governments, courts, law ‎enforcement or government or regulatory
agencies in the ‎USA, Canada and elsewhere may be able to ‎access or obtain
disclosure of your personal information ‎under a lawful order or otherwise
through the ‎laws of the foreign jurisdiction, irrespective of the ‎safeguards
we have put in place for the protection of ‎your personal information.

COMPLAINT TO SUPERVISORY AUTHORITY:

If you consider that your privacy rights have been breached and wish to lodge a
complaint about our privacy practices, you may raise a concern or file a formal
complaint with the Federal Office of the Privacy Commissioner at
‎https://www.priv.gc.ca/en.

If you are a resident of the province of British Columbia, you should contact
the Office of the Information & Privacy Commissioner for British Columbia at
https://www.oipc.bc.ca/.

If you are a resident of the province of Alberta, you should contact the Office
of the Information and Privacy Commissioner of Alberta at https://oipc.ab.ca/.

If you are a resident of the province of Québec, you should contact the Quebec
Commission d’accès à l’information at https://www.cai.gouv.qc.ca/.

If you have any questions about our privacy or information handling practices or
if you wish to access your personal information, you should contact our Data
Privacy Office at: dpo@cibt.com.







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