The data gathered by VISARIGHT can be divided primarily into two categories:
- All data required for the processing, preparation and performance of an agreement with VISARIGHT. If other service provides are involved in the performance of the agreement, e.g. visa authorities, optimization services or hosts, your data will be forwarded to them to the extent required.
- When you access our Services, some information is exchanged between your device and our server, or the server of the services we use. This may include personal information. One of the ways in which the information gathered in this way will used is to further improve our Service.
Under the GDPR, you have various rights
that you can assert with us. These include the right to selectively object
to the use of data, particularly for advertising purposes. The option to object
is highlighted in print. Further information on your rights can be found in the additional section below and in the individual descriptions of the respective data uses.
Our Services are only available to users who are 18 years of age or older. If you are not at least 18 years old, you may only use our Services if your parents have given their consent herein, and you have provided sufficient proof of this consent.
. 2. Name and Contact Information for the Company Responsible for Data Processing
. The company may be reached at the aforementioned address or by email at email@example.com
. 3. Purposes of Data Collection, Legal Basis and Legitimate Interests Pursued by Us or a Third Party, and Categories of Recipients 3.1. Accessing our Service
If you access our Services, especially by visiting our website, the browser used on your device automatically sends information to our server and temporarily stores it in a log file. The following information
is collected without your intervention and stored until it is automatically or manually deleted in the log file:
- Your device's IP address
- Date and time of access
- The name and URL of the retrieved file, the website from which access was made (referrer URL)
- Your browser's unique identifier
- The name of your Internet provider
The processing of the aforementioned data
is based on Article 6(1) f) of the GDPR. Our legitimate interest arises from the uses listed below. At this point, we note that we are unable and do not attempt to draw any conclusions about your identity from the data collected. Your device's IP address and the other information listed above are used by us for the following purposes:
- To ensure that a trouble-free connection can be established
- To ensure the convenient use of our Services
- To evaluate system security and stability
- Other administrative purposes
In order to carry out our services, namely, to process our customers' visa application, we process to information required on basis of Art. 6(1) b) and Art. 9(2) a). This includes:
- E-mail address
- First and last name
- Residential address
- Date and place of birth
- Marital status
- Information you enter yourself
The information provided will be transmitted to the competent authority in order to file the visa application. Unless we use your contact information for customer support or customer service (see below), the information required to process your application is stored until it is no longer needed for this purpose. Subsequently, we retain the required personal information for the periods established by law. During this retention period (usually six to 10 years after conclusion of the agreement), the information is used only in the case of an audit by the tax authority. 3.3. Simplified Scheduling
In order to simplify the scheduling of a customer and consultation call, on the basis of Art. 6 (1) b) GDPR, we use the services of Calendly LLC, 1315 Peachtree St NE, Atlanta, GA 30309, USA ("Calendly"). Calendly offers an external platform in order to arrange and schedule appointments. If you choose the function "Schedule a call", we store the information provided as well as collected during this process on Calendlys servers. This includes:
- The email address you provide
- Your name
- Your IP address
- Your given phone number
- The time of the appointment
- The agreed date
- The agreed time.
. You can object this data processing at any time with effect for the future and free of charge. Therefore, it is sufficient to give us a short notice by e-mail to firstname.lastname@example.org
. 3.4. Data Processing for Customer Support or Customer Service
3.4.1. Informational purposes
If you have signed up for our Services, we manage you as an existing customer. In this case, we process your contact information in order to send you information about your application process and related information. 3.4.2. Newsletter
One of our Services is to offer prospective customers the opportunity to sign up for our newsletter. We use the double opt-in process to confirm that the email address entered actually corresponds to the prospective customer. After the email address is entered, we send you a confirmation link. Your email address will only be included on our mailing list after you click on this confirmation link. We store the information collected during this process only for purposes of documentation and proof. This includes:
- The email address you provide
- Your IP address
- The date and time of registration
- Form of address
- The date, content and time of the confirmation email
- The IP address of the device used for the confirmation
- The date and time of your confirmation
The legal basis for this is Art. 6(1) a) GDPR. We store this information until the contract relationship ends as proof of the legality of sending the newsletter. After the contract relationship ends, we retain the required personal information for the period specified by law. During this period (usually 10 years from the conclusion of the agreement), the data will only be processed again in the event of a tax audit. You can revoke
your consent at any time with effect for the future. Simply click on the unsubscribe button in the respective e-mail or send a short note by e-mail. Please use the options to contact the company's data privacy officer for this purpose. 3.4.3. Mailchimp
In order to manage our customers and our marketing and newsletter campaigns, we use the services of MailChimp's newsletter delivery service, operated by Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA ("Mailchimp"), on the basis of Art. 6 (1) a) GDPR and Art. 6 (1) b) GDPR. Specifically, we use Mailchimp's analysis module to compile our individual e-mail newsletter, which evaluates both your use of our newsletter and our website. Mailchimp offers us the possibility to check whether and how the sent newsletters are opened and used, e.g. to how many users an e-mail was sent, whether e-mails were rejected and whether users unsubscribed from the list after receiving an e-mail. For this purpose, we transmit to Mailchimp in particular the following personal data of the affected users:
- E-mail address
- Name, first name
- Company's name
- Your given Phone number
- Verification status of the customer account
- Account status
- Opt-ins to contact us
- First registration date
- Customer number
- Regional segment
- Affiliate ID if applicable
The "web-beacon" contained in the newsletter is retrieved from the MailChimp server when the newsletter is opened. Within the scope of this retrieval, information about the browser, your system, your IP address and the time of retrieval is collected. In addition, information is collected on whether the newsletter is opened, when it is opened and which links are clicked. For technical reasons, this information can be assigned to you as the recipient. However, it is not our intention to observe you as an individual user. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to all users or to send different content according to the interests of our users.
The collection of this data is necessary so that we can trace the processes in the event of misuse of the e-mail address and therefore serves our legal protection. MailChimp uses this information to send and evaluate the newsletter. The evaluation takes place on our behalf, but MailChimp can also use the data for quality assurance and quality improvement of its own services.
Your data will be stored on the servers of MailChimp in the USA. The USA is an insecure third country. MailChimp is certified according to the "Privacy Shield Framework"
and in the further explanations
on the GDPR. If you have any questions, you can also contact MailChimp's data protection officer directly: email@example.com.
You can revoke your consent to the storage and use of your personal data to receive the newsletter and the statistical survey described above at any time with effect for the future and free of charge. For the purpose of revoking your consent, you can use the link provided for this purpose in the newsletter. Your data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Your e-mail address will therefore be stored as long as the newsletter subscription is active.3.4.4. Intercom
We use the messaging and customer service tool offered by Intercom Inc., 55 2nd St, 4th Fl., San Francisco, CA, 94105, USA and Intercom R&D Unlimited Company, 2nd floor, Stephen court, 18-21 St. Stephen's green, Dublin 2, Ireland at https://www.intercom.com
(„Intercom"). When using the Intercom tool within our Service, your data, such as your name, email address, used operating system, browser version, IP address, referrer URL as well as the content of your message(s) will be transferred to Intercom and stored on Intercom's servers in the US. Intercom will then use this data to provide its services vis-à-vis VISARIGHT (as set forth in their terms of service: https://docs.intercom.com/pricing-privacy-and-terms/intercom-terms-of-service
) in order to answer your questions and customer inquiries related to our Services.
. 3.4.5. Right to withdraw of revoke You may object to the use of your data for the aforementioned purposes at any time free of charge for each communication channel and with effect for the future. An email or a letter sent using the contact information shown under Section 2 is sufficient for this purpose.
Once you submit your objection, we will block the relevant contact address for future advertising data processing. We will process your objection as soon as possible and implement the appropriate blocking measures immediately after it is confirmed. Please note that in some exceptional cases the relevant information or product recommendations may still be received even after receipt of your objection. This is simply due to technical reasons and does not mean your objection has not been processed. Thank you very much for your understanding. 4. Data Processing for the Provision of our Services
In this section, we inform you about the data processing necessary for the provision of our Services: 4.1. Online Presence and Website Optimization
We will not sell or lease your information to third parties for their marketing purposes without your explicit consent. We only disclose certain information to third parties from time to time to be able to offer the best possible product to our customers, improve the quality of our Services and protect the interests of our customers. However, this disclosure will always be subject to strict limitations, which are described in more detail below. 4.1.1. Cookies – General Information
to track your use of the individual pages of our website or when you have logged on to your customer account. When you use our Services again at a later time, the cookie automatically recognizes your previous visit to the website, as well as your input and settings, so that you do not have to enter them again. To make the site more user friendly, we also use temporary cookies
, which are stored on your device for a predetermined period of time. These cookies are automatically deleted when you log off.
If you already have a customer account and are logged on, the information stored in the cookies are associated with that account.
on the use of our Services and evaluate them in order to optimize your experience and to display information tailored to you. These cookies allow us to automatically recognize that you have visited our site before. The cookies are automatically deleted after a predefined period. Most browsers accept cookies automatically. However, you can disable cookies on your browser or choose to be notified when a new cookie is created. However, disabling cookies completely may mean that not all features of our Services will be available to you. The storage period of cookies depends on their purpose and may vary. 4.1.2. Google Tag Manager
For the custom design and continuous improvement of our Services, in compliance with Art. 6(1) f) of the GDPR, we use the web analytics service of Google Analytics of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter "Google"). Using cookies, Google creates pseudonymised user profiles
. The information generated by the cookies for users includes:
- Browser type/version
- Operating system
- Referrer URL (previously visited page)
- Host name of the accessing computer (IP address)
- Time of the server request
This information is sent to a Google server in the U.S. and stored there. The information is used to evaluate the use of our Services, to compile reports on the activities, and to provide other related services for purposes of market research and customized design. This information may also be sent to third parties if required by law or if third parties process this data on behalf of Google. Under no circumstances will your IP address be merged with any other Google data. The IP addresses are anonymised so that assignment is not possible
You can prevent
the installation of the cookies in advance by configuring your browser software accordingly or object
to the continued processing of your data with the cookies by clicking on the opt-out link. Please note that if you disable cookies, it will not be possible to fully take advantage of all of the features of our Services. You can also prevent Google from collecting and processing the data generated by the cookies and related to your usage (including your IP address) by downloading and installing this browser add-on
. On mobile devices, we recommend using private mode. You can find more information on protecting your privacy in relation to Google Analytics on the Google Analytics
website. 4.1.4. Facebook Pixel
To set up, continuously improve, and track the conversion of our Facebook campaigns as required, in compliance with Art. 6(1) f) of the GDPR, we use the individual visitor action pixel of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter "Facebook"). This pixel is integrated into our website's code. This helps us ensure that the Facebook ads we initiate are only displayed to Facebook users who have shown interest in our Services. In this way we know that our Facebook ads correspond to the potential interest of the respective users and not bothering them. It also allows us to track the actions of Facebook users after they have viewed or clicked on one of our Facebook ads. At the same time, it helps us track the conversion of the respective campaign for statistical, market-research and billing purposes. The following information is collected during its use:
- Time stamp
- Campaign-related information (particularly impression, form field and activated button specifications)
Information collected in this way is anonymous to us and therefore does not provide us with any information about the identity of the respective user. Such processing for behavioural and interest-based advertising purposes is recognized as in our legitimate interest under Recital 47 of the GDPR. The data is stored in accordance with the legally established retention periods and then automatically deleted.
You should be aware that when you log on after placing the pixel on your Facebook account, or you visit our website while logged on, Facebook may store and process this information. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook's data policy: https://www.facebook.com/about/privacy/
. You can find more information about the Facebook pixel here
. You can enable Facebook and its partners to display ads on and off Facebook. You can object to this special data processing at any time by changing your Facebook settings accordingly or by simply informing us that you no longer want this processing in the future. Please use the contact options for our company's data privacy officer for this purpose. Please be aware that the objection only applies to the device being used in each case. For further information, see the Facebook
To optimize targeting and track the conversion of our Facebook campaigns, in compliance with Art. 6(1) f) of the GDPR, we use the option of developing Facebook lookalike audiences offered to us by Facebook. You can find more information about the Facebook Lookalike Audiences at: https://www.facebook.com/business/help/365463786964246
The data processing for advertising on the basis of behavior and interests is recognized as in our legitimate interest under Recital 47 of the GDPR. If you belong to the Facebook Lookalike Audience, we send your email address and your device's ID to Facebook. You can object to this special data processing at any time by changing your Facebook settings at https://www.facebook.com/settings/?tab=ads
or simply inform us that you no longer want this processing in the future. Alternatively, it is sufficient to give us a short notice by e-mail to firstname.lastname@example.org
. 5. Recipients outside the EU
As indicated above under 3.3 and 3.4, data may also be sent to recipients located outside the European Union or the European Economic Area. This applies in particular to the aforementioned processing of analysis and/or targeting technologies, which can result in data transmission to the servers of the service providers. Other recipients may be affiliated service providers that we need in order to provide our services, e.g. hosts, CRM tools, analytical service providers. These servers may be outside the EU, especially in the US. We make absolutely sure that these service providers guarantee data protection standards equivalent to those of the GDPR and that they comply with the applicable directives. Therefore, we only work with those service providers who are certified by the EU-US Privacy Shield Framework
. In case number C(2016) 4176)
, the European Commission established the suitability of this data protection level for certification in compliance with Art. 45 of the GDPR. The use of these certified service providers thus meets European standards for lawful data processing. In addition, we have obtained suitable contractual guarantees from all service providers based in other EU countries that they are in compliance with these EU standards and protect the rights of affected persons, for example by using the standard contractual clauses
of the European Commission. 6. Your Rights
In addition to the right at any time to withdraw
any consent you have given us, you are also entitled to the following if the respective legal conditions are met:
6.2. Right to Object Under the provisions of Art. 21(1) GDPR, the data subject has the right to object, on grounds relating to his or her particular situation, at any time to the processing of personal data.
- The right to be informed about your personal data that is stored with us, pursuant to Art. 15 of the GDPR
- In the event of transmissions covered by Art. 46, 47 or 49(1) 2) of the GDPR, the right to information, or references to suitable or appropriate guarantees that a copy of them can be obtained, or where they are available
- The right to correct inaccurate or incomplete data, pursuant to Art. 16 of the GDPR
- The right to the deletion of your personal information that is stored with us, pursuant to Art. 17 GDPR
- The right to limit the processing of your data, pursuant to Art. 18 of the GDPR
- The right to data portability, pursuant to Art. 20 of the GDPR.
We apply the highest standards to data security for our infrastructure and the processing of your data. For example, we use protection mechanisms for computers such as firewalls and data encryption. Our buildings and data are subject to physical access controls. Access to the personal information of our customers is only possible for those employees who need them to carry out their activities.
All personal data sent by you, including your payment information, is also transmitted using the generally accepted and secure SSL (Secure Socket Layer) standard. SSL is a secure and proven standard, e.g. it is also used for online banking. You will recognize a secure SSL connection with the placement of an "s" at the end of http (i.e. https: // …) in the address bar of your browser, or with the lock icon at the bottom of the browser.
We also apply suitable technical and organizational security measures to protect your personal data stored with us against manipulation, partial or complete loss, and against unauthorized access by third parties. Our security measures are continuously monitored using the latest technology, and regularly adapted to the relevant risk, and improved if necessary.
Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 is allowed to provide any personal information to or on the Services. In the event that we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at email@example.com
. 9. Notification Procedures
of May 2019.