Privacy Policy

Revised on 4/6/2020

FGI PRIVACY POLICY

As professionals engaged in the provision of legal services to clients, Fakhoury Global Immigration, PC (the “Firm” or “FGI”), is committed to protecting the privacy of confidential and personal information, including personal data relating to individuals who may be clients, staff, agents, lawyers, law students, job applicants, or others inside or outside the Firm. The policy of the FGI is to comply with the rules of professional conduct which impose a duty to preserve and protect confidential client information upon lawyers and their associated personnel.

This Privacy Statement is intended to summarize the FGI’s data protection practices generally, and to advise its clients, interested law students, job applicants, website visitors, and other third parties about the Firm’s privacy policies that may be applicable to them.

​This Privacy Statement is specifically addressed to parties outside the Firm who: (1) provide personal information, including but not limited to information that identifies you as an individual or relates to an identifiable person, such as name, postal address, telephone number, email address, etc. (“Personal Information”) to the Firm; or (2) who visit or use the Firm’s website at www.employmentimmigration.com (“Website”).

Our Collection of Personal Information

FGI only collects Personal Information that is voluntarily provided.  Any Personal Information that we collect is provided to us by you, or by a third-party who you have authorized to provide us with your Personal Information to facilitate immigration legal services.

Providing Personal Information about Others

If you provide FGI with Personal Information about third parties, you warrant to the Firm that any Personal Information that you provide to the Firm about any third parties was obtained by you with full consent, and that the individual has not communicated to you that they wish to opt out of receiving communication from the Firm or having the Firm collect information about him or her.

Consent and Opt-Out

Your provision of Personal Information through any of our registration forms and case-related questionnaires on our sites, including INSZoom, constitutes your affirmative consent that we may contact you by email to provide you with information and notices relating to your legal matters.

You may choose to opt out of receiving future email messages from us by emailing us at GDPRoptout@employmentimmigration.com and submitting your opt-out request.

Website Hosting

The Website is hosted and operated in the United States (“U.S.”).  By using the Website, you acknowledge that any Personal Information about you, regardless of whether provided by you or obtained from a third party, is being provided to the Firm in the U.S. and will be hosted in the U.S.

Use and Disclosure of Personal Information

If you do provide Personal Information to the FGI, the Firm may use that Personal Information to:

  • Provide you with legal services, if you are or become a client of the Firm, and/or respond to any requests or inquiries you may have;
  • Invite you to seminars, panel events, conferences and other business engagements;
  • Contact you (unless you tell us that you prefer us not to) regarding legal or law firm developments that may be of interest to you;
  • Carry out, monitor and analyze our business or Website operations;
  • Collect anonymous traffic data and geographic location, derived from your IP address, and perform web analytics by using software and cookies;
  • Enter int or carry out contracts of various kinds; and
  • Comply with any applicable laws or regulations.

We do not disclose any Personal Information to unrelated parties outside of the Firm, except to our agents or data processors or other contractors acting on our behalf and at our direction, subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party; where we believe it necessary to provide a service which you have requested; as permitted or required by law; or as otherwise authorized or directed by you.

We reserve the right to disclose Personal Information that we believe to be necessary or appropriate in the following circumstances:

  • As required by law, such as to comply with a subpoena, or similar legal process;
  • When we believe in good faith that disclosure is necessary to protect the Firm’s rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • To enforce the Firm’s Terms of Service, Legal Agreement, Master Services Agreement, or other contract, to the extent any is applicable; and
  • To allow the Firm to pursue available remedies or limit the damage it may sustain.

Confidentiality of Client Information

Consistent with its professional obligations, FGI’s policy is to exercise the utmost discretion regarding the information our clients entrust to us. The Firm accepts and processes client information in a manner that is always subject to the client’s direction and control, and the Firm maintains reasonable and appropriate, although not infallible, security precautions. It never purposefully trades, sells or shares your information with any unrelated parties except as necessary or appropriate to conduct the Firm’s legal and business activities; subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party; to further your interests; or as permitted or required by law, or as authorized or directed by you. Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to the attorney who is handling your matter or info@employmentimmigration.com.

Client Credit Card Information

If you are a client of the Firm, you may pay via wire, cash, check or credit card.  If you opt to pay via credit card, the Firm may direct you to the website of our third-party payment processor, Intuit Inc. (“QuickBooks”), to process your payment.  By agreeing to process your payment vis a vis our third-party payment processor, Intuit, you expressly agree to its privacy policy, which may be found at https://quickbooks.intuit.com/global/privacy/. You may contact Intuit directly regarding any questions or concerns you have about your Personal Information submitted through their website by submitting written correspondence to Intuit on its Contact Us page.

Legitimate Business Interest under the GDPR

The processing of Personal Information shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Firm.  European Union (EU) data subjects are informed, by means of this Privacy Policy, of the rights to which they are entitled.

Specifically, for EU data subjects requesting legal services or visiting our Website, we collect your Personal Information in furtherance of our legitimate interest to carry out our business in favor of the well-being of the Firm.  ​Our use of your Personal Information is based on the legitimate grounds that:

  • The use is necessary in order to fulfill our commitments to you under our Terms of Service or applicable client fee agreements;
  • The use is necessary for compliance with a legal obligation;
  • The use is necessary in order to protect your vital interests or those of another person or entity;
  • We have a legitimate interest in using your information – for example, to provide and update our Website or Services, to improve our Website or Services so that we can offer you an even better user experience, to safeguard our Website or Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; and/or
  • You have given us your consent.

Your Privacy Rights under the GDPR

The GDPR includes the following rights for EU data subjects who provide their information to the Firm in connection with our provision of legal services or when visiting our Website:

  • The right to be informed about how we store, use, or share your data;
  • The right to access your data;
  • The right to rectify your data;
  • The right to have us erase your data;
  • The right to prevent us from processing your data;
  • The right to request copies of your data from us in a commonly used and machine-readable format, free of charge, for the purposes of transfer to a third party, where technically feasible;
  • The right to object to use or sharing of your data; and
  • The right not to be subject to automated decision-making, including profiling.

If you have any questions about these rights, you may contact us at info@employmentimmigration.com.

Data Controller and Data Processor

Data Controller. FGI is the “data controller,” as defined under the GDPR, or the legal entity which determines the purposes and means of the processing of personal data of the clients of the Firm and visitors to its Website.  The Firm is responsible for collecting your consent, managing consent-revoking, enabling right to access, etc. If you wish to revoke consent for us to store, use, or share your personal data, you may contact us at GDPRoptout@employmentimmigration.com.

Data Processor.   The Firm is the “data processor,” as defined under the GDPR, or the legal entity which processes your personal data.  The Firm maintains records of any processing activities it performs and is able to show how the Firm complies with data protection principles under the GDPR.  It has effective policies and procedures in place.

Cookies

A cookie is a text file sent by a web server and placed on your computer by your web browser. The Firm’s extranet sites use cookies to track logins and to filter data that a logged-in user has access to. This cookie also identifies users that have changed their initially assigned default password. The Firm uses this information to help customize the user’s experience on the site, to provide security, and for the other purposes specified herein.

You may reset your browser to refuse all cookies or to allow your browser to alert you when a cookie is set. However, if you select these settings you may be unable to access certain parts of the Website. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you log on to the Website. For more information about how to manage your cookies preferences, you should use the ‘help’ menu of your web browser or explore the customer support sections of your web browser.

Social Media Features and Widgets

The Website includes social media features such as the Facebook “Like” button, and widgets, such as the Twitter “Share This” button that run on our Website.  These features may collect your IP address, which page you are visiting on our 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 our Website.  Your interactions with these features are governed by the privacy policy of the company providing it.

Facebook Integration

On this Website, the Firm has integrated components of the enterprise, Facebook.

Facebook is a social network.  A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component.  An overview of all the Facebook Plug-ins may be accessed here.  During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our Website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g. the Facebook blocker of the provider Webgraph. These applications may be used by the data subject to eliminate a data transmission to Facebook.

Twitter Integration

On this Website, the Firm has integrated components of Twitter.

Twitter messages (tweets) are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, United States.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available here. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our Website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.

The applicable data protection provisions of Twitter may be accessed here.

Links to Other Websites

This Privacy Policy applies only to this Website and not to any third-party sites.  However, we may include links to other websites on this Website. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties or their websites.  The inclusion of a link on this Website does not imply endorsement of the linked site or its services by the Firm.

Do Not Track Signals

“Do Not Track” signals are options available on your browser to tell operators of websites that you do not wish to have your online activity tracked.  The Firm’s Website may not respond to “Do Not Track” signals or other mechanisms from a visitor’s browser. If, in the future, the Firm creates a program or protocol to respond to a web browser’s “Do Not Track” signals, the Firm will inform you of the details of that protocol in this Privacy Policy.

Children’s Privacy and GDPR Exception

The Firm does not knowingly collect, maintain or process Personal Information submitted online by anyone under the age of 18.  If you are under 18, please do not attempt to send any Personal Data about yourself to us.  If we learn that we have collected Personal Data from a child under age 18, we will delete that information as quickly as possible.  If you believe that a child under 18 may have provided us Personal Data, please contact us at info@employmentimmigration.com.

If you provide FGI with Personal Information about your minor dependents under age 16 , you warrant to FGI that any Personal Information that you provide is done so with your full consent and the full consent on behalf of your minor dependent(s), and that you do not wish to opt out of receiving communication from FGI or having FGI collect information about your minor dependent(s).

Our websites are not directed at children. However, under GDPR, children at least16 years of age may provide personal information to become registered users of any of our sites.  In this regard, FGI does not collect or maintain information at our sites from those we know are under 16, and we do not permit children under 16 years of age to become registered users of our sites. By using any of our sites, you represent that you are not under 16 years of age. If you are a parent or guardian and you believe that your child under age 16 may have provided personally identifiable

information through any of our websites, please contact us at GDPRoptout@employmentimmigration.com

Security

The Firm maintains reasonable and appropriate physical, electronic and procedural safeguards intended to maintain the confidentiality of Personal Information provided by our clients as well as visitors to this Website. The Firm does not guarantee that these safeguards will always work or that its security measures are infallible.

Breach

The Firm has internal policies and procedures in place to effectively detect, report, and investigate a data breach.  The GDPR defines a personal data breach as “a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.”  The Firm will notify you of a personal data breach where the personal data breaches are likely to present a risk to data subjects to data protection authorities (“DPAs”) without undue delay, and within 72 hours if feasible, after becoming aware of the breach; and communicate high-risk breaches to affected data subjects without undue delay.  The Firm will provide you with: (i) contact details of the Data Protection Officer (DPO) or other contact person, (ii) a description of the nature of the breach, (iii) likely consequences of the breach, (iv) measures the organization has taken or proposes to take to address the breach, and (v) advice on steps that EU data subjects can take to protect themselves.

Data Protection Officer

FGI is required to designate a Data Protection Officer (“DPO”) because it is: an organization that carries out large scale processing of special categories of data, such as health information or information about criminal convictions.  In this regard, the Firm elects to appoint Brandi N. Knox, Director of Technology & Legal Processes as the DPO for this Firm. Ms. Knox is responsible for data protection compliance and can answer any questions you may have about your Personal Information. She may be reached at info@employmentimmigration.com.

Data Retention/Erasure

We will retain your Personal Information for the period indicated in your client fee agreement, or if you are not a client, for a period of one (1) year.  If, at any time after agreeing to this Privacy Policy, you: (1) change your mind about receiving information from us; (2) wish to revoke permission for us to retain and use your Personal Information; (3) wish to object to processing of your Personal Information; or (4)  wish for us to erase a copy of your data, please make a request to the Firm at GDPRoptout@employmentimmigration.com. If you request erasure of your data, we may retain some of your Personal Information only for legitimate business interests, such as fraud detection, prevention, and enhancing the safety of our Website; and to comply with our legal obligations, specifically our tax, legal reporting, and auditing obligations.

Our Response to Your Requests

If you make any requests regarding your Personal Information, we will not charge you for compliance with the request.  The Firm will respond and comply within one month. The Firm reserves the right to refuse or charge for requests that are manifestly unfounded or excessive.  If we refuse your request, we will tell you why we are refusing your request.  You have the right to complain to the relevant supervisory authority and to a judicial remedy, but you must do so within one month of our refusal.

Complaints.  Without prejudice to any other administrative or judicial remedy, every EU data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement of the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

Data Protection Impact Assessment (DPIA)

FGI is required to undergo a DPIA because the data processing related to the services that we provide is likely to result in a high risk to data subjects, such as in cases where: (1) new technology is being deployed; (2) profiling operations may significantly affect individuals; or (3) processing is on a large scale and involves special categories of data.  In this regard, the Firm has developed a robust process to help identify and assess risks relating to personal data processing activities.  These assessments are carried out when FGI processes personal information that is likely to result in a high risk to data subjects’ rights and freedoms, as well as when the Firm introduces new data processing processes, systems or technologies.

Notice to California Residents

The California Consumer Privacy Act (“CCPA”) provides California residents with certain rights regarding their Personal Information. These rights and the methods for exercising them are described in more detail below. Please note that this section applies only to and the rights described in it can only be exercised by residents of California.

Description of Rights

  •  Right to Opt-Out of Sale
    •  FGI does not sell your information to third parties.
  • Right to Know
    •  You have the right to request that we disclose that Personal Information about you that FGI collects, uses, and discloses. Once we receive and confirm your verifiable consumer request, we will disclose to you:
      • The categories of information we have collected about you.
      • The categories of sources for the Personal Information we have collected about you.
      • Our business purpose for collecting that Personal Information.
      • The categories of third parties with whom we share that Personal Information.
    • FGI’s response to requests to know (either the categories or specific pieces of Personal Information) will only cover the 12-month period preceding the request.
  • Right to Delete
    • You have the right to request that FGI delete any Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct service providers to delete) your Personal Information from our records.
      • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or to prosecute those responsible for that activity.
      • Debug to identify and repair errors that impair existing functionality.
      • Exercise free speech ensure the right of another consumer to exercise his or her free speech, or exercise another right provided for by law.
      • Comply with the California Electronic Communications Privacy Act.
      • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest, if the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
      • Enable solely uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
      • Comply with a legal obligation.
      • Otherwise use the consumer’s Personal Information, internally, in a manner that is compatible with the context in which the consumer provider the information.
  • Right to Non-Discrimination
    • FGI will not discriminate against a consumer for exercising any of their privacy rights under the CCPA by doing any of the following:
      • Denying goods or services.
      • Charging different prices or rates for goods or services, including applying discounts or imposing penalties.
      • Providing a different level or quality of goods or services.
      • Suggesting that a consumer will receive a different price or rate for goods or services or a different level or quality of goods and services.

Exercising Your Rights

  •  How to Exercise Your Rights
    • To exercise any of your rights described above, please submit a request to FGI by emailing us at GDPRoptout@employmentimmigration.com.
    • Only you, or a person registered with the California Secretary of State that you have authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may, however, make a verifiable consumer request on behalf of your child.
    • FGI cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. All requests must:
      • Provide enough information for us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. The amount of information necessary will depend on the request but we will only use Personal Information provided with a request to verify your identity and authority to make the request.
    • If you have any questions or concerns regarding the exercise of your rights or FGI’s privacy policies and practices, please let us know. You can contact us by using the “Contact Information” details below.
  • Exercising Rights for Someone Else
    • Only you, or a person registered with the California Secretary of State that you have authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may, however, make a verifiable consumer request on behalf of your child.
  • Response Timing and Format
    • We will make our best effort to respond to a verifiable consumer request within 45 days of its receipt. Within ten (10) days of receiving the request, FGI will confirm receipt and provide information about its verification and processing of the request. If we require more time, we will inform you of the reason and an extension period in writing. For requests that seek the disclosure of specific pieces of information about the consumer, we will select a format that is readily useable and should allow consumers to transmit the information from one entity to another entity without hindrance. We do not charge a free to process requests, unless they are manifestly unfounded or excessive. FGI will maintain records of consumer requests made pursuant to CCPA as well as our response to said requests for a period of at least twenty-four (24) months.

Notice to Residents of Certain States

Some state laws permit residents who provide us with Personal Information to request certain information regarding our disclosure of such information to third parties for their direct marketing purposes. We do not, currently, disclose such information to third parties for their direct marketing purposes. If we change this policy, we will update this provision and provide instructions on how you may make a request for details.

Consultants, Suppliers and Vendors

In order to support its provision of legal services to its clients, from time to time, the Firm may maintain business information about prospective or ongoing consultants, suppliers, and vendors.  The Firm uses this information for internal purposes and does not share this data with unrelated third parties.  The Firm requires consultants, suppliers, and vendors to maintain data protections consistent with reasonable and appropriate obligations of data processors.  Any prospective consultants, suppliers, or vendors with questions about our policies and expectations should contact info@employmentimmigration.com.

Changes

 The Firm reserves the right to change this Privacy Statement at any time without advance notice. Should any new policy go into effect, the Firm will post it on this Website.  The Firm encourages visitors to frequently check this page for any changes to its Privacy Policy.

Contact Us

If you change your mind about receiving information from us or have any questions or concerns about the use of information volunteered by you, please send us a request specifying your new choice.  Please contact us at info@employmentimmigration.com.

​Additionally, you may reach us by postal mail at:

Fakhoury Global Immigration

5250 Corporate Drive, Suite #300

Troy, MI 48098

(248) 643-4900