Chin & Curtis respects your privacy, and we value our relationship with you.
Chin & Curtis complies with the U.S.-EU Privacy Shield Framework, including the Supplemental Principles, and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (collectively, the “Principles”). Chin & Curtis has certified that it adheres to the Principles with respect to its services and the collection, use, and retention of certain Personal Data (as defined below) transferred from the European Union (“EU”) and Switzerland to Chin & Curtis in the United States (“U.S.”). This Policy sets forth the standards under which Chin & Curtis will treat such Personal Data. To learn more about the Principles and to view Chin & Curtis’ certifications, please visit: https://www.privacyshield.gov/.
- Reference to “processing” or “processes” means any activity which involves the use of Data, whether in whole or in part by automated means or otherwise, such as collecting, recording, organizing, storing, modifying, using, disclosing, or deleting such Data.
How your data is processed
Data will be:
- relevant to and not excessive for the purposes for which it is collected;
- kept up-to-date, with necessary steps taken to rectify or delete information that is inaccurate or incomplete if Chin & Curtis becomes aware of such occurrences;
- kept only as long as is reasonably necessary for the purposes for which it was collected and processed or as otherwise required to comply with applicable laws;
- subject to appropriate technical and organizational measures to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage.
We will also disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Types of Data
The Data is comprised of the following categories of data and as appropriate may include Sensitive Personal Data including:
- Employment status;
- Employment details including without limitation work history/job data;
- Prior education and training details;
- Compensation and benefit information history (possibly including copies of pay stubs);
- Compensation and benefit payment details;
- Contact information including home address, home and cell phone numbers and email;
- Previous addresses or names;
- Immigration-related information (e.g., birth country, citizenship; passport number; visa status; criminal history; present and past membership in or affiliation with any organization, association, fund, foundation, party, club, society or similar group in the U.S. or abroad since sixteenth birthday);
- Immediate family information including relationship, contact information, work history, birth information, criminal history, and immigration information as listed above;
- Travel schedules;
- Social Security or National ID Number;
- Summaries of meetings, correspondence, actions, and progress relating to immigration; and
- Bank account details.
Special Categories of Data
Additional consent from a parent or guardian is required to collect personal data for children under the age of 18. This data is only collected if required for immigration purposes.
Security and Confidentiality
Equipment and Information Security
To safeguard against unauthorized access to Data by third-parties outside Chin & Curtis, all electronic Data held by Chin & Curtis is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding Data are “backed up” (i.e., recorded on separate media) on a regular basis in an effort to avoid any inadvertent erasure or destruction of Data. The servers are stored in facilities with appropriate security and fire detection and response systems.
Chin & Curtis limits access to the internal systems that hold Data to a select group of authorized users, each of whom is given access through the use of a unique identifier and password. Access to Data is limited to such individuals for the sole purpose of performing their job duties (for example: an attorney and legal assistant).
Sharing of Data with Government Agencies
Chin & Curtis will share the information you provide with government agencies as necessary to provide immigration services on your behalf.
Sharing of Data with Third-Parties & Liability
Chin & Curtis may also share Data with third-party service providers to perform services on your behalf in the U.S. and abroad. Chin & Curtis requires its third-party servicers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as Chin & Curtis when processing Data.
If a third party providing services on Chin & Curtis’ behalf processes personal data in a manner inconsistent with the Principles, Chin & Curtis will be liable, unless we can prove that we are not responsible for the event giving rise to the damage
Transfer, Storage, and Retention
Most Data will be held in the United States and stored on servers located in the United States. Chin & Curtis will maintain Data only for so long as it determines in its sole discretion to be required for business purposes or as required by law. In any case, Chin & Curtis destroys records seven years after the last action taken.
Chin & Curtis takes state of the art precautions to protect Personal Data covered by this Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. These precautions take into account the risks involved in the processing, the nature of the Personal Data, and best practices in the industry for security and data protection.
Chin & Curtis acknowledges the right of an individual to access the personal data we hold about you and the right to correct any mistakes or delete inaccurate information, in certain circumstances. To exercise these rights, or to request that we not contact you by email, telephone, or direct mail, please contact Chin & Curtis at the address listed below
Chin & Curtis’ commitments under the Privacy Shield, and compliance with the Principles, are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Inquiries and complaints relating to Chin & Curtis’ treatment of Personal Data and its compliance with the Principles may be directed to:
Chin & Curtis, LLP
Attention: Data Protection Officer
75 Federal Street, Suite 210
Boston, MA 02110
Chin & Curtis will respond to any such inquiries or complaints within forty-five (45) days.
In the event that you have an unresolved privacy or data use concern that we have not addressed satisfactorily, Chin & Curtis agrees to participate in the dispute resolution procedures of the panel established by the European Union data protection authorities (DPAs) and Swiss Federal Data Protection and Information Commissioner (FDPIC) to resolve disputes pursuant to the Privacy Shield Principles. If you have not been able to resolve your compliant by any other mechanism, you may, in certain circumstances, be able to seek resolution via binding arbitration. The EU DPAs may be contacted directly via the information provided at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. For additional information about the arbitration process, please visit the Privacy Shield website.
By using Chin & Curtis, LLP’s services, you understand and consent to the collection, processing, and use of information for the purpose and in the manner set forth under this Policy.