Privacy Policy

Effective Date: June 10, 2024

This Privacy Policy applies to CIBT Inc., CIBTVisas, Entriva, Newland Chase, Newland Chase Education, Blair Consular, our subsidiaries and affiliates, and any Services that link directly to this Privacy Policy (collectively, “CIBT”, “we”, “our”, or “us”). We are committed to providing our customers with excellent service. As part of this commitment, we take the trust our customers and site visitors place in us very seriously. We recognize that it is our responsibility to inform you of our personal information collection practices through our Privacy Policy. Our Privacy Policy outlines:

Privacy Policy

We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the beginning of this Privacy Policy.

In some instances, we are engaged directly by travel partners, corporations, or business groups, including your employer, which results in our processing of personal information on the behalf of such travel partners, corporations, or business groups. In these circumstances, you should address any concerns regarding the processing of your personal information directly with the party with whom you have a primary relationship, where applicable.

If you are a resident of California, certain U.S. States, China, or Canada, you may have certain specific rights in connection with your personal information: please refer to the section or addendum relevant to your jurisdiction of residence for further information.

We have designated a Privacy Officer who is responsible for our compliance with this Privacy Policy. The Privacy ‎‎Officer may be contacted as described below in section 14.‎

1. The Personal Information We Collect

Our suite of services includes travel, tour, flight, and hotel bookings; travel protection and insurance services; passport, travel visa, driving permit and document assistance; background checks and clearance forms; immigration services; and travel information.

Personal Information We Collect Directly. By using our websites, apps, and/or our services (“Services”), we may collect and request information, including personal information, which includes your name, address, telephone number, date of birth, marital status, government IDs such as birth certificate, driver’s license or passport images or numbers, employment history, educational background, tax status, employee number, job title and function, expatriate status, e-mail address and payment and transaction information. We may collect this information from you directly (e.g., form consumer surveys), or, with your consent or when permitted by applicable law, other parties such as your travel agent; family, friends, or travel companions; government agencies; trip providers (e.g., accommodations and transportation services, attractions and tour providers, travel insurance companies, or other booking companies); and/or your employer. Where required for the Services, we collect certain personal documents such as passport copies, educational documents, CVs, visa copies, birth certificates, and other documents.

Personal Information We Collect Automatically. Other information we collect automatically from your device, which may be considered personal information in your jurisdiction, or from third parties may include the following, such as:

Unique IDs such as a cookie placed on a computer or advertising IDs;
Internet Protocol address (“IP address”);
Information about a device such as information contained in HTTP headers or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings, and information about or from the presence or use of “apps” on mobile devices; or
Publicly available information about you.

Sensitive Personal Information. If, for instance, we are handling your visa or immigration matter, additional information may be requested by the application forms of the destination country. These additional items can include items such as your personal and family information, educational background, employment history, travel history, and financial records. If required by relevant visa or governmental authorities, additional sensitive information can include ethnicity, race, religion, trade union membership, health related information, and information about criminal history where permitted by law.

2. How Personal Information Is Used

We may use your personal information in the following ways and for the following purposes based on the specific Services and/or your or your agents’ interaction with us, including, for example, to:

Create an Account: You may create an account on certain of our Services including on our websites and apps. The type of personal information that we collect from you varies, but includes, at a minimum, your name and contact information.
Providing our Services, Including Visa Services: When you or your agent obtains Services or makes a purchase from us, including requesting visa services, we will collect your name, billing and shipping addresses, email, phone number, payment card information (which is processed through our payment processor), and items or Services purchased. When we assist you with obtaining a visa, our collection and use of your personal information is dependent on the requirements of the country issuing the visa so our practices may vary.
When you Book with us: You can book a variety of vacation or holiday services and accommodations as well as additional specific services. If you enquire about a booking, by telephone, email, chat or in any other way, we process the necessary personal information to be able to provide you with suitable offers and Services. If you book through our properties, we collect and process the necessary personal information for the conclusion of the contract, the implementation of your booking and for additional support. This also includes the transfer of your personal information to the respective providers of the booked services.
When you Upload Photos. When using our Services to apply for or obtain a visa or for other travel purposes, we may need to collect an image of you. We use these images to provide our Services.
Sign Up for Information or Marketing: We collect your name and contact information if you sign up receive information or marketing from us.
Post to our Services or Our Social Media Pages: You may post, or grant us permission to post, your photos, reviews, ideas or other content to our Services, as indicated, and on our social media pages.
Communicate with You: We collect personal information about you when subscribe to newsletters or when you otherwise communicate with us. This includes your name, contact information, and scope of your inquiry. We may also use your email address to send you reminders of expiring visas, passports, or immigration status. If you would like to discontinue receiving this information, see the How to Opt-out of Further Communication section below. Calls to our call center may be recorded for quality assurance, security, and training purposes.
Participate in Promotions: If you participate in a promotion or sweepstakes, then we will collect the personal information that you submit as part of your entry. We may offer promotions or sweepstakes in connection with other entities, and, in some cases, our promotions or sweepstakes will be governed by additional or different privacy notices. We will notify you at the time of collection if your personal information is subject to an additional or different policy. Some jurisdictions require us to post personal information of winners.
Interact at Events: We collect personal information from you that you choose to provide to us at virtual or in-person events (e.g., to our employees or other representatives). We collect the personal information that you choose to provide to us, which may include, for example, your contact information and information about Services you may be interested in obtaining.
Administration: for administrative purposes, including to manage our inventory; to help us better understand how our customers access and use our Services, including the pages viewed, ad impressions clicked, or other Services activity; to maintain security and operability of our Services (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you, others and us; to enforce this Privacy Policy, our Terms of Use, and other policies.
Research and Development/Analytical Purposes: for research and development purposes, including to improve our Services, products, and customer experience; to understand what parts of our Services are most popular or to improve upon our products and Services; to understand our customer demographics; and for other research and analytical purposes.
Legal compliance: to comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.
Protection of you, us and others: where we believe it is necessary to protect you, us and others, including, without limitation to detect, prevent, and respond to fraud, security incidents, or other issues where we believe it is appropriate to protect us and others.
Work with our Trip Providers: For example, we may partner with an airline, hotel, school, association, corporation, travel agency or credit card company to provide Services to their members or frequent travelers. Please review our partner’s privacy policy for their privacy practices.
Follow-Up Services: In many instances such as visa extensions, permanent residency, and other cases related to changes in employment, the Services we provide require follow-up services. If such follow-up is required, the information we have collected previously is used to provide the additional related Services for which we have been engaged.
Other uses: that we notify you of or that you may consent to.

3. How We May Disclose and Transfer Personal Information

We may disclose and transfer personal information we collect for the purposes described above, and to service providers and third parties as follows:

Affiliates and Subsidiaries. To support and provide the Services including, as applicable, to process trip and booking requests, complete your visa, document legalization, or immigration process request as necessary to provide visa and immigration services to you and your family. This may include providing sensitive data required for an immigration process request to visa application centers, logistics companies, and/or translators/solicitors. We may also disclose certain information to improve our products and services, provide superior customer service, and identify market opportunities.
Vendors and Service Providers. To our service providers, processors and others who perform functions on our behalf. These may include, for example, IT service providers, help desk, chatbots, analytics providers, and consultants. Additionally, we may share images you have uploaded with image review vendors to enable more efficient processing of your images for visa and travel purposes.
Trip Providers. To support and provide the Services, including to help you book accommodation, travel, tourist attractions, tours, and to enable or facilitate entry requirements as may be required, including invitation providers to secure official invitations related to visa applications or entry requirements, and background check providers as required by the destination country.
Business Partners and Third Parties, Including Third-Party Platforms, Providers, and Networks. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes. We also share information to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also (and, where required by applicable law, with your consent) make certain information (such as browsing information) available to third parties in support of our marketing, advertising, and campaign management.
Travel Companions (e.g., Friends and Family). To support and provide the Services, including if you or your friend/family member organize group trips.
Government Entities. To support and provide the Services, including as necessary for visa applications, immigration services, and logistics purposes. Sensitive data may be disclosed as necessary.
Customers and Clients. To support and provide the Services, including if we are providing services on behalf of a business.
To Others As Required by Law. We may also disclose personal data to third parties to the extent permitted by applicable law and legal obligations. This may include regulators, government entities, and law enforcement as required by law or legal process, subject at all times to obligations under relevant laws. In addition, it may include certain disclosures that we are required to make, such as the names of sweepstakes and contest winners.

We may also disclose your personal information in the following circumstances:

In Support of Business Transfers – If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and act in response to violations of our Terms of Use. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may, to the extent permitted by applicable law, use, disclose, and otherwise process aggregate and deidentified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes.
Other Disclosures. We may disclose personal information in other ways not described above, including as required or permitted by applicable law. If necessary, we will notify you and, if necessary, obtain your consent.

4. Compliance with the EU and Swiss Data Privacy Framework

CIBT Inc. (as well as the entities listed above) complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. CIBT has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. CIBT has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit: https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, CIBT commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, CIBT commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact CIBT at: [email protected].

Additional information in support of the Data Privacy Framework:

By complying with the Data Privacy Framework, CIBT is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
We may disclose information related to the transactions we perform for you to third parties. We contractually commit any third-party organizations that we engage with to the same level of protection as we follow. Your data is only used for the specified purpose. If for any reason it is determined that the third party cannot meet these obligations, then the contract is terminated. The current third parties, the reason for their use and the company information are listed in the following link: https://corporate.cibt.com/security-documentation/.
You may access your data by using the web site(s) with your credentials or make a request to [email protected].
You may restrict the use of your data for marketing purposes by sending an email to [email protected].
Under certain conditions, you may invoke binding arbitration. CIBT is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles. The International Centre for Dispute Resolution®-American Arbitration Association® (ICDR-AAA®) was selected by the U.S. Department of Commerce to administer arbitrations pursuant to the arbitral fund identified in Annex I of the DPF Principle, provided that you have invoked binding arbitration by delivering notice to CIBT and following the procedures and subject to conditions set forth in Annex I of Principles.
In the event of a lawful request from public authorities, you may be required to disclose personal information in response to that request to meet national security or law enforcement requirements.
We remain responsible for all the personal information we receive under the DPF and that we subsequently transfer to third parties acting as agents on our behalf if they process personal information in a manner inconsistent with the DPF principles.

5. Cookies and Tracking Technologies

We and our providers use cookies, pixel tags, and other similar tracking mechanisms to automatically collect personal information about browsing activity, type of device, and similar information within our Services. We use this personal information to, for example, analyze and understand how you access, use, and interact with us through our Services; to identify and resolve bugs and errors in our Services; to assess, secure, protect, optimize, and improve the performance of our Services; for marketing, advertising, measurement and analytics purposes; and to personalize content in our Services. We may also aggregate personal information to analyze trends, administer our Services, and gather broad demographic information.

Cookies. “Cookies” are alphanumeric identifiers we transfer to your device’s hard drive through your web browser for tracking purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within the Services.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.

Third Party Analytics. We use third party tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Services. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Services to provide us with reports and metrics that help us evaluate usage and improve our Services and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to manage how your personal information is used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Tracking. We and our providers may use the personal information we collect about you within our Services and on other third-party websites and services to help us and other third parties identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Services.

Third-Party Advertising. We work with third-party ad networks, analytics, marketing partners, and others (“third-party ad companies”) to personalize content and display advertising within our Services as well as to manage our advertising on third-party sites. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information within our Services (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other online identifiers. We and these third-party ad companies use this personal information to provide you more relevant ads and content within our Services and on third-party sites, and to evaluate the success of such ads and content.

Do Not Track. Currently, our Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed below (e.g., by disabling cookies).

Development of new and improvement of existing technologies. We process the necessary data as part of the development of new technologies and the improvement of existing technologies in order to improve our services and set new standards in the area of data protection and information security. This includes in particular the areas of machine learning, artificial intelligence, and deep learning. In doing so we only use pseudonymized or aggregated data as far as technically possible.

6. Your Choices

You have certain choices regarding the personal information we collect about you. For example, you may:

Opt Out of Promotional Email Communications. You may opt out of promotional emails by clicking on the unsubscribe link in the email. To opt-out of further communications, contact us by email at [email protected].
Opt Out of Interest-Based Advertising. We use third party providers to help us provide advertisements to you that are tailored to you based on interests that you have expressed on our Services or elsewhere ('Interest-Based Ads'). Any tracking done by third parties ad partners through cookies and other mechanisms are subject to those parties own privacy policies. You may manage Google cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en.
You also may opt out of receiving Interest-Based Ads from many third-party ad networks, such as those provided by members of the Network Advertising Initiative ('NAI') and the Digital Advertising Alliance ('DAA'). For more information regarding Interest-Based Ads by NAI members and DAA members, including how to opt out of Interest-Based Ads provided by NAI and DAA members, please visit their respective websites: optout.networkadvertising.org and optout.aboutads.info.
You must opt out on each browser and on each device.
Industry ad choice programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you.
U.S. Users: you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device.
EU Users: youronlinechoices.eu (European Interactive Digital Advertising Alliance)
Canada Users: youradchoices.ca/choices/ (Digital Advertising Alliance of Canada)
Japan: http://www.ddai.info/optout (Data Driven Advertising Initiative in Japan)

Please note that opting out of participating ad networks does not mean that you will not see advertisements at all, and you will continue to receive advertisements on other websites and from companies that do not participate in the above programs. Even if you opt out of interest-based ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type and recent, previous searches related to your current search.

Please note that even if you opt out of receiving marketing communications from us, we may still send you communications about your account or any products or services you have purchased from us and we will still respond to your inquiries and requests for information.

Mobile Device Settings. In addition to the above, some of our apps may include third-party advertising and analytics. For iOS devices, you can turn off 'Allow Apps to Request to Track' setting (go to Settings>Privacy> Tracking). For Android devices, turn on 'Opt out of Ads Personalization' setting (go to Settings>Privacy>Tracking and select/toggle on Opt out of Ads Personalization). In addition, our apps may include analytics and related personalization that you can opt out of through an in-app settings for that app (you can access this setting from the main menu).

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