Search
Contact
Login
Berry Appleman & Leiden LLP, together with its affiliated entities, participates in and complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (together, the “Frameworks”), as administered by the U.S. Department of Commerce. The following Data Privacy Framework Principles set out the way that Berry Appleman & Leiden LLP (BAL) will collect, use, store, share, transmit, delete or otherwise process (collectively process) your personal data, in the course of providing our immigration and related services in connection with our Cobalt® application, communications channels (e.g., portals or platforms available online) and other online and offline means (e.g., via fax, physical mail, or courier). Personal data means any information that relates to an identified or identifiable individual. BAL adheres to the Data Privacy Framework Principles when handling personal data received from the European Union, United Kingdom, and Switzerland under these Frameworks. This commitment is subject to oversight and enforcement by the U.S. Federal Trade Commission (FTC). In these Principles, “you” and “your” means any individual customer or employee of BAL and any other individual whose personal data we process and “we”, “us”, “our” means BAL.
Additional details about the Data Privacy Framework program, including our certification status, are available at: https://www.dataprivacyframework.gov/list.
This Notice is intended to complement BAL’s general Privacy Policy and should be read alongside it. It focuses specifically on personal data transferred to the United States under the Frameworks.
Applicability
This Notice applies to personal data originating from individuals in the European Union, United Kingdom and Switzerland that BAL processes in the United States under the Frameworks.
Notice
Our Consent Agreement and Privacy Policy will outline the personal data we collect, how it is used, and the categories of third parties with whom it may be shared. We will process your personal data lawfully and only for those purposes we have told you, for purposes permitted by you or as permitted by applicable law. In addition, you may object to certain types of processing as expressly permitted by applicable law.
We provide clients with the option to choose how their personal data is used and shared. Please refer to the Marketing and your choices section of our Privacy policy for more information regarding this. In addition, we provide individuals with the opportunity to opt out of (i) the disclosure of their personal data to third parties (other than service providers acting on our behalf), and (ii) the use of their personal data for purposes that are materially different from the purposes for which it was originally collected or subsequently authorized. Where we process sensitive personal data, we will obtain your consent (opt in) before disclosing such data to third parties.
Accountability for Onward Transfer
We may transfer personal data to third-party service providers and partners who perform services on our behalf. Such transfers are limited to specific and defined purposes consistent with this Notice. We require all third parties receiving personal data to provide at least the same level of protection as required under the Data Privacy Framework Principles. This is ensured through contractual obligations that limit processing to specified purposes and require appropriate safeguards. Where we act as a data processor, we transfer personal data only in accordance with our clients’ instructions and applicable agreements. If a third party is no longer able to meet its obligations to provide the required level of protection, we will take reasonable steps to stop and remediate any unauthorized processing. BAL remains responsible for personal data transferred to third parties under the Data Privacy Framework Principles, unless we can demonstrate that we are not responsible for the event giving rise to the damage.
Security
We will keep your personal data confidential and limit access to your personal data to those who specifically need it to conduct their business activities, except as otherwise permitted by applicable law. We refer to industry standards and use reasonable administrative, technical and physical security measures to protect your personal data from unauthorized access, destruction, use, modification or disclosure. These measures are proportionate to the nature, sensitivity, and risks associated with the personal data we process. We require industry standard data security measures from those third parties who are authorized by us to process your personal data on our behalf.
Data Integrity and Purpose Limitation
Personal data is processed only for the purposes for which it was collected or as otherwise authorized, and only to the extent relevant for those purposes. BAL takes reasonable steps to ensure that data remains accurate, complete, relevant, and up to date. Personal data is not processed in a manner that is incompatible with the purposes for which it was collected, except as permitted or required by law. Data is retained only for as long as necessary to fulfill its purpose or to meet legal obligations.
You may request access to your personal data and information about how it is processed. You will be provided access as required by applicable law, regardless of the location of processing. If data is inaccurate or incomplete, you may request correction or amendment. In certain limited circumstances, access may be restricted where providing access would be disproportionate to the risks to the individual’s privacy or would violate the rights of others.
Recourse, Enforcement and Liability
Dispute Resolution
BAL is committed to addressing complaints related to personal data processed under the Frameworks.
Binding Arbitration
If your dispute or complaint related to your Personal Data that we received in reliance on the Data Privacy Framework cannot be resolved by us, nor through the dispute resolution mechanism mentioned above, you may have the right to require that we enter into binding arbitration with you under the Data Privacy Framework “Recourse, Enforcement and Liability” Principle and Annex I of the Data Privacy Framework.
Updates to This Notice
BAL may revise this Notice from time to time. The “Last Reviewed” date will reflect the most recent changes, and periodic review is encouraged.
Relationship to BAL Privacy Policy
This Notice should be read together with BAL’s general Privacy Policy, which provides broader information about data handling practices.
Contact us
If you have questions or comments about this Notice, please fill in a Privacy Request Form, call us toll free at +1-877-757-7108, send us an email or write to us at:
Global Privacy team BAL 2400 N. Glenville Dr. Richardson, TX 75082