Privacy Policy and Consent to Process Information

We greatly value and respect your privacy. We realize that you may be sharing a great deal of
personal and confidential information with us. The following policy describes how we
collect, protect and process your data.


What Information Do We Collect?


We collect only information that is necessary to carry out representations we have been hired
to perform. With regard to our Travel Assessment Tool, this means that we collect the
information necessary to provide a basic, preliminary assessment of what visa type you may
need for your planned travel. More broadly, if we are engaged to assist with your specific
matter, this means we collect the information necessary to obtain the visa, permit or other
document as we are engaged to obtain by you and, if applicable, your employer. We collect
this information from you and your employer, and may sometimes also gather information
from government or private databases, or information that is publicly available online. Some
of this information may be special category data, such as your race, ethnic origin, politics,
religion, trade union membership, genetics, biometrics, health, sex life or sexual orientation,
as such information frequently required by destination country governments in order to
secure applicable visas, permits and other documents.


How Do We Protect Your Data?


We do our utmost to ensure the privacy of the data that clients share with us, including
encryption of email, encryption of data stored in the databases we utilize, and safeguards to
protect unauthorized access to servers where data is stored. As of the date of this consent, we
store client data on Citrix’s ShareFile service (more information is available at
https://www.sharefile.com/). However, we reserve the right to change data storage or backup
providers in the future based on business need without further notice so long as the new
provider offers the same or higher level of data security. We comply with all applicable rules
of professional conduct regarding maintaining the confidentiality of our clients’ information.
However, no physical or technological data storage system is 100% secure from all possible
intrusions, so we cannot absolutely guarantee the security of your data. In addition, we cannot
guarantee the security of information that you transmit to us via unsecure means, such as
unencrypted email.


Who We Share Your Data With?


Authorized third parties we may share your information with in order to obtain the visa,
permit or other document you have retained us to obtain for you include the following (note
that the “destination country” is the country you are traveling/moving to, or otherwise have
asked us to assist with procuring documents from):
1. The government of the destination country (including the consulate with jurisdiction
over your place of residence and domestic immigration/employment/labor agencies
involved in the adjudication of your application);
2. Representatives appointment by the government of the destination country (including
outsourced visa agents appointed by a government, i.e. VFS Global);
3. Our local counsel or agent in the destination country;

4. Translators, if your documents need to be translated to be accepted in the destination
country;
5. Academic credentials evaluators, if your credentials need to be evaluated to be
accepted in the destination country;
6. Couriers (i.e. FedEx, UPS, DHL, postal service, private couriers) engaged to deliver
documents. Note that all documents will be sent in sealed envelopes or packages via
traceable means whenever available.


How Do We Retain and Destroy Your Data?


The firm operates as paperless office. We scan and store client files in electronic PDF format
and destroy hard-copy files given to or received by us immediately after scanning, with the
exception of original vital records or other original government documents. We retain all
relevant client files for a period of five (5) years following termination of the matter, or other
period as required by applicable law, and may thereafter destroy same without further notice.
At any time during this period the client may request copies of PDF files, which will be
provided in electronic format. Given government regulations and the rules of professional
responsibility applicable to us as lawyers, we may not be able to legally honor a request to
delete your data in advance of this period.


Withdrawing Consent + Other Concerns or Questions


If at any time you would like to withdraw your consent for our processing of your data, you
may write to us at info@lustgartenglobal.com or phone us at 231-252-0303 and we will
promptly respond to your request. Likewise, if you have any questions or concerns regarding
the processing of your data please do not hesitate to reach out to us. Note that based on
government regulations and the rules of professional responsibility applicable to us as
lawyers, we may not be able to legally honor a request to delete your data but will
immediately cease processing of it upon a request from you. By providing your data to us you
authorize us to collect and process your data in this manner.