What are cookies?
Cookies are small text files that may be placed on your computer by websites you visit. There are a number or ways they may be used such as, to provide information on the use of the website, to add additional functionality and services or to help manage content.

How we use cookies
We use a third-party tool (Google Analytics) to collect and store certain information when you use, access, or interact with this website. The type of information we gather may include the location of your IP address, the number of visit made, the pages visited, the duration of the visit, the type of device used and how you interact with the site content. This information is anonymous and is only used by us to help improve our digital services and user experience.

Opting in or out
Cookies are not gathered without your consent and choosing to opt out of cookies on this site or Google Analytics will not affect the use of our site.

Consent is granted to us when you select ‘Allow Cookies’ button on the cookie notification banner. Alternatively, consent can be declined by selecting ‘Decline cookies’ on the cookie notification banner.

Cookies will not be gathered if you have chosen to opt out of Google Analytics. Further information on opting out of Google Analytics can be found on this page.

Laura Devine Immigration, and our business in the United States, Laura Devine Attorneys are committed to compliance with relevant UK and European data protection laws and will responsibly protect the information you provide to us and the information we collect in the course of operating our business.

This Privacy Policy describes how the firms, as data controllers, may collect, use, and share information, particularly in association with the operation of our website (www.lauradevine.com) and all of our HTML-formatted email communications that link to this Privacy Policy (collectively, “Digital Services”).

This Privacy Policy describes:

• The types of information we collect
• How we use the information
• How we share the information
• Third-party services and content
• Protection and storage of the information
• Your choices and rights
• How to contact us
• Changes to this Privacy Policy

The types of information we collect
We collect your personal information when you provide it to us. Personal information is any information that can be used to identify you or that we can link to you. We may automatically collect certain information when you use, access, or interact with our Digital Services. And we may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content.

Information you provide to us
You generally can use our Digital Services without providing us with personal information.

We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you sign up for or request that we send you newsletters, alerts, or other materials; when you submit an application for a position with us; when you sign up for a webinar or event; and when you respond to our communications or requests for information. The information you provide may include your name, contact information, title, and information about the organisation with which you are affiliated. Some of our Digital Services may require that you enter a password or other information in order to access certain features, and we collect such credentials when you enter them.

Information we may collect automatically
We use a third party service, Google Analytics, and similar technologies (collectively, ‘Cookies’) to collect and store certain information when you use, access, or interact with our Digital Services. We may, for example, collect information about the type of device you use to access the Digital Services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on the Digital Services, the web pages you view immediately before and after you access the Digital Services, whether and how you interact with content available on the Digital Services, and the search terms you enter on the Digital Services. For information about how we use Cookies and the choices you may have, please see our Cookie Policy.

To opt out of being tracked by Google Analytics across all websites visit Google Analytics Opt-out Browser Add-on

Please note that we do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Privacy Policy.

Information we collect from other sources
We may receive information about you from other sources, including third parties that help us: update, expand, and analyse our records; identify new clients; or prevent or detect fraud. We may also receive information about you from social media platforms including but not limited to when you interact with us on those platforms or access our social media content. The information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable social media platform, and we encourage you to review them.

How we use the information
We may use the information we collect:

• To respond to your enquiries;
• To provide you with legal and other services that you request;
• To operate, troubleshoot, and improve the Digital Services;
• To send you newsletters, legal news, marketing communications, and other information or materials that may interest you;
• To maintain our database;
• To understand how people use our Digital Services, including by generating and analysing statistics;
• For the firms’ business purposes, including data analysis; submitting invoices; detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
• To assess the effectiveness of our events, promotional campaigns, and publications;
• To evaluate, recruit, and hire personnel; and
• As we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protector your, our, or others’ rights.

How we share the information
The firms are a provider of legal services. Our offices share information with each other for business purposes such as internal administration, billing, promoting our events and services, and providing you or your organisation with services.

We do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your prior permission. We may share information that does not reasonably identify you or your organisation as permitted by applicable law.

We may also disclose information we collect:

• To our third-party service providers that perform services on our behalf, such as web-hosting companies, mailing vendors, analytics providers, event hosting services, and information technology providers. We use Constant Contact to send marketing communications and manage preferences on our behalf.
• To law enforcement, other government authorities or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us; as provided for under contract; for immigration requirements or as we deem reasonably necessary to provide legal services. In these circumstances, we take reasonable efforts to notify you before we disclose information that may reasonably identify you or your organisation, unless prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances.
• To service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

In connection with any proposed incorporation, purchase, merger or acquisition of any part of our business; we inform the potential buyer (and its agents and advisers) that it must use your personal information only for the purposes disclosed in this Privacy Policy.

Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:

• Performance of a contract – We may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us. For example, when you use our Digital Services we will use your personal information to respond to your requests and provide you with such services.
• Consent – Where required by applicable laws, we will rely on your consent for direct marketing and to collect information from your device or computer. We may use location information as described in this Privacy Policy. You may be able to disable the sharing of location information in your browser or mobile application settings.
• Legitimate interests – We may use your personal information for our legitimate interests to improve our products and services and the content on our Digital Services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Privacy Policy and use personal information for our marketing purposes.

Third-party services and content
Our Digital Services may include integrated content or links to content provided by third parties (such as video materials). This Privacy Policy does not address the privacy, security, or other practices of the third parties that provide such content.

We engage third parties that support the operation of our Digital Services, such as our web-hosting, public relations and analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see our Cookie Policy for more information.

Protection and storage of the information
We deploy administrative, technical, and physical safeguards designed to comply with applicable legal requirements and safeguard the information that we collect. This includes, when required or appropriate and feasible, obtaining written assurances from third parties that may access your data that they will protect the data with safeguards designed to provide a level of protection equivalent to that adopted by the firms.

However, no information system can be 100% secure. So, we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks.

The Digital Services are controlled and operated by the firms from the UK. We may transfer information to countries outside of your country of residence, including the United States, which may have data protection laws and regulations that differ from those in your country.

If we do this, we will comply with the rules in the General Data Protection Regulation. Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it, either by making our own assessment of adequacy, or using one of the standard mechanisms available to us. These may include:

• Transfer to countries or organisations that have officially been deemed to provide an adequate level of protection for personal data by the European Commission (a list of which is available here).
• Using specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.

We retain the information we collect no longer than as reasonably necessary to fulfil the purposes for which we collect the information and to comply with our legal obligations.

Your choices and rights
If you no longer wish to receive marketing communications from us, you can let us know by sending us an email via our Contact page. And the electronic marketing communications we send you will contain opt-out mechanisms that allow you to register your marketing preferences.

Subject to applicable laws, you may have certain rights regarding information that we have collected and that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate. You can also ask us to see what personal information we hold about you, to erase your personal information and you may tell us if you object to our use of your personal information. In the UK, you have a right to complain to the Information Commissioner’s Office (ICO). If you would like to discuss or exercise the rights you may have, send us an email via our Contact page.

For information about the choices you may have in regard to our use of Cookies, please see our Cookie Policy.

How to contact us
If you would like to contact us with questions about our privacy or data protection practices, please send us an email via our Contact page.

We welcome enquiries and comments. But please note that if you are not a client, we may not be able to treat the information you send us as confidential or privileged.

Changes to this privacy policy
We may update this Privacy Policy from time to time. The effective date of the current Privacy Policy is 1 August 2019. We encourage you to periodically review this page. If we make any material changes in the way we collect, use, and/or share the personal information that you have provided, we will notify you by posting notice of the changes in a clear and conspicuous manner on the firms’ website.

Laura Devine Immigration, and our business in the United States, Laura Devine Attorneys are committed to compliance with relevant UK and European data protection laws and will responsibly protect the information you provide to us and the information we collect in the course of operating our business. This Client Privacy Policy (Privacy Policy) describes how the businesses, as data controllers, may collect, use, and share information about you and your rights in relation to that information.

Your provision of information to us constitutes your acceptance of the terms of this Privacy Policy. Please do not send us any information about you which you do not want to be used in the ways described in this Privacy Policy.

Scope of this Privacy Policy
This Privacy Policy applies to your use of our services, including when you request information from us; when you engage our legal services; and as a result of your relationship with one of our clients.

Privacy information about your use of our online services and how we market to you can be found in our Digital Privacy Policy.

This Privacy Policy describes:

• The types of information we process
• How we use the information
• How long we retain information
• How we share the information
• Protection and storage of the information
• You and your rights
• How to contact us
• Data controller
• Changes to this Privacy Policy

When we use personal information about you or others in connection with providing our legal services to clients we do so as a data controller.

The types of information we process
We will process personal information we receive directly from you, on your behalf, other organisations with whom you have dealings, government agencies, publicly available records and the third parties described in ‘How we share the information’ below.

We may collect current and historical personal information including/relating to: your name, contact details, identification, ethnic origin, marital status, employment/business, finances, academic history and criminal offences/convictions (this is non-exhaustive which depends on the circumstances).

How we use the information
We may use your personal information if:

• it is necessary for the performance of a contract with you or our client on your behalf (e.g. when we are providing our services to you as envisaged by our engagement letter);
• it is necessary in connection with a legal obligation (eg when we are carrying out anti-money laundering and conflict checks);
• you have provided your consent to such use (eg you have approved the use of a specific third party to assist on your matter);
• we consider such use of your information as not detrimental to you, within your reasonable expectations, having a minimal impact on your privacy, and necessary to fulfil our legitimate interests (eg to manage and attend at Home Office or consular appointments on your behalf, to manage fees and invoicing, or to recover money owed to us); or
• we are otherwise required or authorised by law.

Special categories of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using it.

Depending on the nature of our instructions, we may collect, store and use any of the following special categories of information about clients, prospective clients and/or about related parties to a matter:

• physical or mental health, including any medical condition or disability
• race or ethnicity
• political opinions
• religious or philosophical beliefs
• trade union membership
• sexual orientation or sex life
• genetic information and biometric data

Depending on the nature of our instructions from you, we process this type of information where it is necessary to establish, exercise or defend your immigration status (including legal claims), where you have made the information public, or by asking for explicit consent. If we seek your consent, you may withdraw consent at any time as described in ‘Your choices and rights’ below.

We use your information to:

• provide and improve our services to you;
• maintain and develop our relationship with you;
• facilitate our internal business operations;
• fulfil our legal requirements (including in relation to anti-money laundering) and professional obligations;
• monitor and analyse our business.

We may not be able to do these things without your personal information.

How long we retain information
We recognise that it is important to only retain your personal information for as long as is required by law (which is currently 6 years) or we consider reasonably necessary, after which we will destroy it. Due to the nature of immigration services, a full record of information obtained from you, third parties and advice provided by us shall not be retained longer than 15 years unless you request that it be erased. This is because we consider that it is in your best interests that we retain a full history of data which may be relevant to future matters you instruct us to deal with. Such data can also be relevant to your immigration position should there be any dispute with the authorities or for us to be able to provide you with a record should you misplace important immigration documents/information. If you would like us to rectify or erase your data please refer to the section on ‘Your choices and rights’ below.

How we share the information
We may share your information with third parties where:

• you have consented for us to do so;
• we are under a legal, regulatory or professional obligation to do so (for example, in order to comply with anti-money laundering requirements);
• it is necessary for the purpose of, or in connection with, legal proceedings, or to exercise or defend legal rights;
• it is required or will assist us in providing our services, which includes: UK and overseas government and related independent organisations, representatives for submission of applications to the immigration authorities, reference/qualification checking, translators, UK and international couriers, research, archiving, professional advisory (including legal, accounting, financial and business consulting), banking, payment, debt collection, insurance, marketing and information security services.
• if, in the future, we re-organise or transfer all or part of our business, we may need to transfer your information to new entities from which our business will be carried out.

In connection with any proposed incorporation, purchase, merger or acquisition of any part of our business; we inform the potential buyer (and its agents and advisers) that it must use your personal information only for the purposes disclosed in this Privacy Policy.

Where we transfer your information internationally we will take reasonable steps to ensure that your information is treated securely and the means of transfer provides adequate safeguards. Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it, either by making our own assessment of adequacy, or using one of the standard mechanisms available to us. These may include:

• Transfer to countries or organisations that have officially been deemed to provide an adequate level of protection for personal data by the European Commission (a list of which is available here).
• Using specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.

Please be aware that your personal information may be processed by Laura Devine Immigration in the UK or Laura Devine Attorneys, in the United States.

Personal information shared between our offices will be subject to the contractual obligations imposed by the EU model contract clauses.

If you have any questions in relation to the transfer of your personal information please contact us.

Protection and storage of the information
We take steps to hold information securely in electronic or physical form and to prevent unauthorised access, modification or disclosure. Our information security practices are supported by a number of security safeguards, processes and procedures. We store information in access controlled premises or in password protected electronic form. We require our third party IT providers to comply with appropriate information security obligations. All staff and third party providers with access to confidential information are subject to confidentiality obligations. However, the transmission of information via the internet is at your own risk as it is not completely secure. We cannot guarantee the security of your data transmitted to us but can offer a secure portal for the exchange of electronic information. We are regularly reviewing ways to improve our security offering as technology develops.

You and your rights
Subject to applicable laws, you may have certain rights regarding information that we have collected and that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate. You can also ask us to see what personal information we hold about you, to erase your personal information and you may tell us if you object to our use of your personal information. If you would like to discuss or exercise the rights you may have, please contact us. In the UK, you have a right to complain to the Information Commissioner’s Office (ICO), but we would prefer you to contact us first. We should be able to resolve any matter quickly and to your satisfaction.

How to contact us
If you would like to contact us with questions about our privacy practices, please send us an email via our Contact page or contact our Data Protection Manager, Natasha Chell at natasha.chell@lauradevine.com.

If you are a data controller or a data processor
If you are a data controller or a data processor in your own right, and you provide personal data to us, you confirm to us that you have a lawful basis for doing so under data protection law and all necessary consents, where required.

Changes to this privacy policy
We may update this Privacy Policy from time to time. The effective date of the current Privacy Policy is 1 August 2019. We encourage you to periodically review this policy. If we make any material changes in the way we collect, use, and/or share the personal information that you have provided, we will notify you by posting notice of the changes in a clear and conspicuous manner on the firms’ website.