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Berry Appleman & Leiden LLP is a limited liability partnership organized under the laws of the State of California and has offices in Atlanta, GA; Los Angeles, CA; Austin, TX, Boston, MA, Richardson, TX, Houston, TX, Tysons, VA, San Francisco, CA, Santa Clara, CA, New York, NY, Chicago, IL, Denver, CO and Washington DC (together referred to as “BAL” or “we”, “our”, or “us”).
This privacy policy describes how we may collect, use, disclose and otherwise process your personal information 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). This privacy policy applies to personal information collected by BAL including, but not limited to questionnaires, www.bal.com and its secured access sites, including, but not limited to cobalt2.balglobal.com (collectively referred to as “sites”) that post a link to this privacy policy.
For the purposes of applicable data protection law, BAL acts as a data controller when it determines the purposes and means of processing personal data in connection with its professional services. In certain limited circumstances, BAL may act as a data processor on behalf of a client, where this is expressly set out in a written agreement.
BAL may responsibly use reputable, vetted AI tools with enterprise-grade security to support certain processes, subject to attorney oversight and appropriate safeguards. BAL will not disclose or input any client confidential information into any AI system that retains or uses data for training purposes. All AI use will comply with applicable ethical standards, confidentiality obligations, and data protection requirements.
Changes to this Privacy Policy We may change this privacy policy from time to time. If we make material changes to this privacy policy, we will post a notice on our sites before the changes go into effect or otherwise send a direct communication to you about the change.
Summary of Key Points
Global Privacy Team
Berry Appleman & Leiden LLP 2400 N. Glenville Dr., Bldg A
Richardson, TX 75082
What information we collect
Categories of personal information collected If required to support the provision of our services, we may collect the following categories of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household:
Identifiers and Contact Information
Sensitive Personal Information
Financial and Transaction Information
Internet and Electronic Activity
Employment and Professional Information
Education Information
Inferences Inferences drawn from the information described above create a profile reflecting preferences, characteristics, behavior, attitudes, abilities, or aptitudes.
Information About Family Members or Dependents If we provide services relating to your family members or dependents, we may collect similar categories of personal information about them as described above.
Personal information is collected, used, and disclosed for the purpose of providing the services to or in connection with the applicable data subject and their family members or dependents. Sensitive information is only collected, used, and disclosed for the purposes for which it is collected.
Categories of sources We may collect all categories of personal information listed above from the following categories of sources:
Source one: we collect personal information directly from you and/or your household that you provide us. Personal information is required to use certain features available on our sites, for example, to create a Cobalt online account, contact us via email, phone, or our “contact us” form (where we may retain your message content and our response), submit job application materials, receive or request data from us (e.g., via whitepapers, catalogs, and newsletters).
Source two: we collect personal information automatically when you access our sites. For example, we may collect information such as the pages you click on our sites, IP address, search requests, browser type, operating system, data and time you visit our sites, the amount of time spend on our sites, and the device you use to access our sites.
Source three: we collect personal information we get from third parties and public sources. If BAL is handling your visa or immigration matter, we may obtain personal information about you from your employer or immigration sponsor various governments (foreign and domestic) and from public sources. Such public sources may include, but are not limited to, social media sites such as LinkedIn, Facebook, Instagram, Google Scholar, and other internet searches.
California’s Do Not Track Signals Requirement. WE DO NOT ALTER OUR DATA COLLECTION AND USE PRACTICES IN RESPONSE TO DO NOT TRACK SIGNALS. WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.
How we use your information
When we process personal information about you, we do so as necessary to provide our services to you and your employer or immigration sponsor use, to operate our business, to meet our contractual and legal obligations, to protect the security of our services, systems and customers, or to fulfill other legitimate interests to provide the services that we have been engaged to provide, including our Cobalt site, described in this policy.
How and with whom we disclose your personal information
Your employer or immigration sponsor Our services to you are typically provided under the terms of our service agreements and legal engagement with your employer or immigration sponsor to provide you legal services. We disclose your information with them to allow them to manage their immigration needs and assure compliance with their policies. At the request of your employer or immigration sponsor, we may also disclose information with their vendors. In the event that our client wishes to engage alternative legal advisers, we may transfer your personal information to those advisors to ensure continuity of business.
With our business partners and partner network BAL will provide immigration services in the United States and will act as the primary provider of such services. If your immigration request takes you to countries serviced by one of our local network partners, we may disclose your personal information to those local network partners as necessary to provide you with the services you or your employer or immigration sponsor may request. Disclosure with these local partners is subject to written contracts that reflect BAL’s Data Protection Principles and applicable data protection requirements.
In connection, where services are required outside the United States, we may disclose information with Deloitte LLP as part of our service provider relationship with Deloitte LLP, subject to contractual data protection obligations. We collaborate with Deloitte to facilitate the provision of BAL services with respect to foreign governments. Information regarding the ways in which Deloitte LLP collects, uses and discloses personal information when providing immigration services to you outside of the United States can be found on Deloitte’s GlobalAdvantage Privacy Statement. Please note that we cannot and do not control Deloitte LLP’s privacy practices.
Immigration authorities in destination countries We disclose information with immigration authorities (for example consulates and other government or law enforcement agencies), and their vendors as necessary to provide immigration and related services to you and your employer.
Vendors and third-party providers We disclose information with vendors that perform functions on our behalf, such as vendors offering notarization, translation, authentication, legalization, visa and passport services and other third party providers and services partners to facilitate the provision of services with respect to foreign governments, software developers, and vendors who provide IT support, data hosting and marketing and communication services. These vendors process your information only as necessary to perform their functions in support of immigration services.
Our sites include Social Media features and integrations. These features and integrations may collect your IP address, which page you are visiting on the site, and may leverage tracking technologies to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing it. You should visit the company’s applicable privacy policy before using such feature or integration.
Business transfers for change in ownership In the event that we sell or buy any business or assets, we may transfer your personal information to the seller or buyer of such business or assets. If BAL assets are acquired by a third party, personal information may be one of the transferred assets.
As permitted or required by law We disclose personal information when we think it’s reasonably necessary to protect ourselves and the people who use our services, enforce agreements, respond to emergencies and comply with law, as well as subject to our ethical obligations applicable to the practice of law.
In exceptional circumstances, we may disclose personal information with government agencies other than immigration authorities and other third parties if we believe it is reasonable and necessary to comply with law, regulation, legal process or governmental request; to enforce our agreements, policies and terms; to protect the security of our services; to protect BAL or the public from harm or illegal activities; or to respond to an emergency.
We may also disclose personal information with other parties as directed by you or subject to your consent, which we may request from time to time.
We do not sell or share personal information. We do not sell or share information to third parties so that they can independently market their own products or services directly to you. To our knowledge, we do not sell or share personal information as defined by applicable data protection statutes. As a result, we have no knowledge that we sell or share information of a child under the age of 16.
Before disclosing your personal information to third parties, we will require the third party to maintain at least the same level of privacy and security for your personal information that we do. We remain liable for the protection of your personal information within the scope of our Data Protection Principles, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.
Marketing and your choices BAL would like to use your personal Information to communicate with you via email or direct mail to inform you about newsworthy topics and upcoming events that may be of interest to you. For example, BAL would like to use your email address to send you the firm’s Legal Update newsletter or to send you an announcement concerning an upcoming seminar. When collecting your personal information BAL will seek your consent to being contacted in this way and if you consent, we will send you such information. If you would like us to stop sending you these marketing messages, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us.
Although you may elect to unsubscribe to these types of communications, unsubscribing to these communications does not opt you out of transactional messages related to the services we provide. For example, we may communicate with you about questions we have in drafts relating to your immigration case, to service your account, to fulfil your requests or otherwise as required by law. Some of these services contain information presented to you as part of our service relationship with your employer or immigration sponsor (for example, messages that help you comply with their business policies). If you opt out of marketing messages, you will continue to receive these service messages.
International transfers For the purposes described here, it may be necessary to transfer your information to jurisdictions outside of your home country including to countries that may not provide the same level of data protection as your home country. As immigration services are inherently global, we may transfer data to those third parties referenced above, which may be in any jurisdiction in the world to where you may be traveling. To protect your information, transfers will be made as permitted by applicable law, including, where necessary, being subject to appropriate contractual clauses. Regardless of where we process your information, we protect it in the manner described in this privacy statement and in accordance with applicable law.
Other details
Data Retention BAL keeps personal information for as long as necessary (corporate retention period of 7 years) to provide our products and services, fulfil requested transactions, or for other essential purposes such as complying with our legal obligations, preventing fraud, resolving disputes and enforcing our agreements. Because retention periods can vary, for different data types in the context of different services, actual retention periods may differ. Here are some of the factors we have considered to set retention times:
Children’s Privacy Our sites are general audience sites not directed at children under the age of 16. We do not knowingly collect personal information directly from children under the age of 16. In the context of immigration services requested by a parent or legal guardian, we may process a child’s personal information where necessary to provide those services and only with appropriate authorization. If we obtain actual knowledge that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that information. If a parent or legal guardian learns that their child or minor dependent provided us with personal information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such personal information.
Your rights If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and make changes or corrections to your information. You may also have the right to be informed of whether we are processing your personal information and to access, transfer, correct, delete or object, upon request and free of charge, to our use of your information. Please note that we may need to retain certain information for record keeping, to complete any transactions you began before your request, or for other purposes permitted by law.
You may exercise the following rights regarding your personal information:
Right to request access. You have a right to access any of the following : (a) the categories of personal information we collected from you, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for collecting or selling your personal information, (d) the categories of third parties with whom we disclosed your personal information, and (e) the specific pieces of personal information we collected from you (i.e. “data portability”). You also have a right to access a list of categories of personal information we sold or disclosed for business purposes in the last 12 months.
Right to request deletion. You have the right to request that we delete personal information we collected from you.
Right to request correction. You have a right to request that we correct inaccuracies in your personal information.
Right to Opt Out. You have the right to opt out of the processing of the personal data for purposes of: (a) targeted advertising; (b) the sale of personal data; or (c) profiling in furtherance of a decision that produces a legal or similarly significant effect concerning the consumer.
Appeal. If you are not satisfied with our response to a privacy rights request, you may have the right to submit a complaint to the applicable data protection authority, supervisory authority, or state Attorney General, depending on your jurisdiction.
Lawfulness of processing Data protection laws in some countries require processing for personal data only where there is an approved basis under the law. We use the following legal bases for processing data under UK, EU and Swiss law, depending on the activity we undertake:
Performing a contract In most cases, the data we collect and the things we use it for are necessary for us to provide immigration services as requested by you or your employer or immigration sponsor as contemplated by GDPR Article 6(1)(b).
Meeting our legitimate interests We use personal data as necessary to meet our legitimate business interests under GDPR 6(1)(f). When we do, we make sure we understand and work to minimise its privacy impact. For example, we limit the data to what is necessary, control access to the data, and where we can, aggregate or de-identify the data.
Some examples of the data processing activities we undertake in our legitimate interests are:
With your consent In some cases, we process personal data with your specific and informed consent. We tell you in the service where you can make a choice or grant consent. If you have granted consent, you may withdraw it at any time to stop any further processing. To request this, please send an email to privacy@bal.com.
How to exercise your privacy rights To exercise your rights described in this policy, 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:
DPO – Global Privacy team BAL 2400 N. Glenville Dr. Richardson, TX 75082
Who may exercise these rights. You may only make a request to exercise your rights on behalf of yourself. A parent or legal guardian may make a request on behalf of their child. Only you or a person that you authorize to act on your behalf may make a request related to your personal information. We may verify your identity, the identity of your authorized agent, and require proof that your authorized agent acted on your behalf.
Verifiable consumer request. In order to verify your request, you must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information and you must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
How we will respond. We will respond to your request as required by applicable law. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Non-Discrimination You have a right to not receive discriminatory treatment for exercising any of your rights as mentioned in this section.
Contact us If you have any questions or complaints about BAL and privacy, or to exercise your rights, or to request an additional review of a declined rights request within 30 days of our response, please contact the data protection office, or 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
In most cases, we will ask that you put a complaint or request in writing. We will investigate your complaint or request and will generally respond to you in writing within 30 days of receipt. If any complaint or request remains unresolved or if you are otherwise dissatisfied with the response that you receive from us, you may have the right to lodge a complaint with your regulator or the U.S. Department of Commerce U.S. Federal Trade Commission.