1. Introduction
SureVisa Ltd (“SureVisa”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains how we collect, use, store, share and protect personal information when you visit our website at https://www.surevisa.co.uk, contact us, enquire about our services, instruct us to provide immigration advice or services, or otherwise interact with us.
SureVisa Ltd provides immigration advice and services in accordance with its applicable authorisation from the Immigration Advice Authority (IAA).
We process personal information in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended.
Please read this Privacy Policy carefully to understand how we handle your information and the rights available to you.
2. Who We Are
SureVisa Ltd is the organisation responsible for deciding how and why your personal information is processed for the purposes described in this Privacy Policy.
Organisation: SureVisa Ltd
Company number: 16781425
Website: https://www.surevisa.co.uk
Email: info@surevisa.co.uk
Business address: Harris House, 1B Park Avenue, Mitcham, London CR4 2EQ
For questions about this Privacy Policy, your personal information or the exercise of your data protection rights, please contact us using the details above.
3. Personal Information We Collect
Depending on how you interact with us, we may collect the following categories of personal information.
3.1 Identity and contact information
This may include your name, date of birth, postal address, email address, telephone number, nationality and other details necessary to identify and communicate with you.
3.2 Immigration and case information
Where necessary to provide immigration advice or services, we may collect information concerning your immigration history, current immigration status, visa applications, travel history, employment, education, family relationships, financial circumstances, supporting documents and communications with relevant authorities.
3.3 Identity documents and supporting evidence
Where required for an immigration matter, we may process passport details, identity documents, proof of address, financial records, employment documents, certificates, application forms and other supporting evidence.
3.4 Special category and criminal offence information
Some immigration matters may require us to process sensitive information, including health information, information concerning religious or political beliefs, racial or ethnic origin, biometric information where applicable, or information about criminal convictions and offences.
We will process such information only where necessary and where the additional legal requirements for that category of information are satisfied.
3.5 Payment and transaction information
Where applicable, we may collect information relating to invoices, payments, refunds, transaction references and accounting records. Payment card details may be processed by a payment service provider where applicable.
3.6 Website and technical information
When you visit our website, certain technical information may be collected, such as your IP address, browser type, device information, pages visited, access times and information relating to website security.
Cookies and similar technologies may also collect information, depending on the technologies used on our website and your cookie preferences.
3.7 Communications and marketing information
We may retain information contained in enquiries, emails, telephone notes, messages, feedback, complaints and other communications.
Where applicable, we may also record your marketing preferences, consent choices and requests to stop receiving promotional communications.
4. How We Collect Personal Information
We may collect personal information:
- Directly from you when you complete a website form, contact us, provide documents or instruct us to act on your behalf.
- During consultations, meetings, telephone calls, emails and other communications.
- From documents and information you provide in support of an immigration matter.
- From authorised representatives or other third parties involved in your matter, where appropriate and lawful.
- From relevant public authorities, official records or publicly available sources where necessary and lawful.
- Automatically through website logs, security systems, cookies and similar technologies, where applicable.
Where we receive personal information from another source, we will provide the required privacy information where applicable.
5. Why We Use Your Personal Information
We may use your personal information for the following purposes:
- 1. To respond to enquiries and assess your immigration needs.
- 2. To provide immigration advice and services.
- 3. To prepare, review, submit and manage immigration applications and supporting documents.
- 4. To communicate with you about your case, appointments, instructions, fees and progress.
- 5. To maintain accurate client files, attendance notes, correspondence and case-management records.
- 6. To process payments, issue invoices and maintain accounting records.
- 7. To comply with applicable legal, regulatory and professional obligations.
- 8. To manage complaints, disputes and legal claims.
- 9. To maintain, secure and improve our website and business operations.
- 10. To prevent fraud, unauthorised access, misuse of our services and other unlawful activity.
- 11. To send educational information, service updates and promotional communications where permitted by law.
- 12. To establish, exercise or defend legal claims where necessary.
We will not use your personal information for a new purpose that is incompatible with the original purpose without first addressing any applicable legal requirements.
6. Our Lawful Bases for Processing
We must have a lawful basis under the UK GDPR for processing personal information. The lawful basis depends on the purpose and circumstances of the processing.
6.1 Contract and pre-contractual steps
We may process personal information where necessary to take steps at your request before entering into an agreement or to perform a contract for immigration advice or services.
This may include assessing your instructions, preparing applications and communicating with you about your matter.
6.2 Legal obligation
We may process personal information where necessary to comply with applicable legal obligations, including relevant regulatory, accounting, tax and record-keeping requirements.
6.3 Legitimate interests
We may process personal information where necessary for our legitimate business interests or those of a third party, provided those interests are not overridden by your rights and freedoms.
These interests may include managing our business, maintaining appropriate records, securing our website, protecting our legal rights and handling disputes.
Where we rely on legitimate interests, we consider the impact on your privacy and whether the processing is necessary and proportionate.
6.4 Consent
We may rely on your consent where required by law, including for certain marketing communications and optional cookies or similar technologies.
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
6.5 Sensitive and criminal offence information
Where we process special category personal data, we will identify an applicable lawful basis and an additional condition required by data protection law.
Where we process criminal offence data, we will identify an applicable lawful basis and the additional legal authority or condition required for that processing.
We will document these requirements where applicable.
7. Marketing Communications
SureVisa Ltd may use appropriate communication channels to share information about immigration services, educational resources, events, service updates and relevant offers.
These communications may include emails, text messages or direct messages through social media.
We will obtain consent where required by applicable law or rely on a valid legal exception where its conditions are satisfied. We will not assume that making an enquiry automatically gives us permission to send promotional messages.
Where applicable, we may send certain marketing communications to existing customers under the relevant existing-customer exception, provided all legal conditions are met.
You can opt out of marketing communications at any time by using the unsubscribe option, following the instructions in the message or contacting us directly.
We will respect your marketing preferences and retain only the information reasonably necessary to maintain suppression records or demonstrate compliance where justified.
Opting out of marketing will not prevent us from sending essential service-related communications concerning an existing instruction, application, payment or other necessary matter.
8. Cookies and Similar Technologies
This website does not itself set cookies and does not use analytics or advertising tools. This is based on a review of the website's code.
Some content on our pages is loaded from other companies' servers, so those companies may receive information such as your IP address and may set their own cookies. These are: Google Fonts, which supplies the fonts used on our pages; the IAA digital badge in the page footer, which is supplied by Yoshki on behalf of the Immigration Advice Authority; and, where we embed videos, YouTube (using its privacy-enhanced address; videos never play automatically). Links to social media platforms and GOV.UK take you to other websites with their own policies.
If we add analytics or other non-essential cookies in future, we will update this Privacy Policy and ask for your consent where the law requires it.
You can manage cookies through your browser settings. Disabling certain cookies may affect some website features.
9. Who We Share Personal Information With
We may share personal information where necessary and lawful with:
- The Home Office, UK Visas and Immigration, courts, tribunals and other relevant authorities where required for your matter or by law.
- The Immigration Advice Authority and other relevant regulatory or supervisory bodies where applicable.
- Professional advisers, legal representatives or other authorised individuals involved in your matter.
- Website hosting, email hosting, cloud storage, IT support and security providers.
- Payment processors, banks, accountants and other business service providers.
- Insurers or professional advisers where necessary to manage risks, disputes or legal claims.
- Other parties where you have authorised the disclosure or where disclosure is otherwise lawful.
We seek to ensure that third parties receiving personal information have an appropriate reason and legal basis to receive it.
Where a provider processes personal information on our behalf, we will put appropriate contractual and data protection arrangements in place where required.
We do not sell your personal information to third parties.
10. Website Hosting, Email and Third-Party Services
Our website is hosted by Namecheap, and our business email (info@surevisa.co.uk) is provided by Namecheap Private Email. We use this one email address for all correspondence and communication.
Other providers may be used for communications, storage, security, payments, analytics or other business functions.
These providers may process personal information on our behalf or in accordance with their own roles and responsibilities. We take reasonable steps to ensure that relevant providers are subject to appropriate data protection and security safeguards.
Information about specific providers, their role and any international transfers will be provided where required.
11. International Transfers
Some of our service providers may store or process personal information outside the United Kingdom.
Where personal information is transferred internationally, we will ensure that the transfer complies with applicable data protection law.
Depending on the circumstances, this may involve a relevant adequacy regulation or decision, appropriate safeguards such as the applicable international data transfer agreement or addendum, or another permitted transfer mechanism.
Where required, we will provide information about the relevant transfer arrangements and how you can obtain further details.
12. How Long We Keep Your Information
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing services, meeting legal and regulatory obligations, maintaining appropriate business records and establishing, exercising or defending legal claims.
Our retention periods depend on the type of information and the circumstances.
Client and immigration case files
We retain client records for at least the minimum period required by the applicable regulatory rules. For client records subject to the relevant IAA record-keeping requirements, our retention schedule will reflect the applicable minimum period, including the six-year minimum where that requirement applies.
The retention period may be longer where required by law or regulation, or where reasonably necessary for a legal claim or other lawful purpose.
General enquiries
We retain enquiries that do not result in an instruction for a period appropriate to handling the enquiry, maintaining necessary business records and addressing potential disputes.
Financial and accounting records
We retain financial and accounting records for the applicable statutory and regulatory retention periods.
Marketing information
We retain marketing information while it remains necessary for the relevant marketing purpose and in accordance with your preferences and applicable law. We may retain limited suppression records to ensure that opt-out requests are respected.
Website and technical information
Website logs, security records, cookies and analytics information are retained according to their purposes, the settings of the relevant services and applicable requirements.
When personal information is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it, unless a lawful reason requires continued retention.
13. How We Protect Your Information
We take appropriate technical and organisational measures to protect personal information against unauthorised access, accidental loss, destruction, alteration, disclosure or misuse.
Depending on the systems used, our safeguards may include:
- Access restrictions and appropriate account permissions.
- Strong passwords and suitable authentication measures.
- Secure storage and transmission where appropriate.
- Software updates and security controls.
- Confidentiality arrangements and appropriate staff access restrictions.
- Secure disposal of information when it is no longer required.
- Appropriate oversight of third-party service providers.
We seek to ensure that access to confidential immigration records, identity documents and other sensitive information is limited to authorised individuals who need it for legitimate purposes.
No method of electronic transmission or storage can be guaranteed to be completely secure. However, we take reasonable and appropriate steps to protect the personal information entrusted to us.
14. Your Data Protection Rights
Subject to applicable law and any relevant exemptions, you may have the right to:
- Access: Request a copy of the personal information we hold about you.
- Rectification: Request correction of inaccurate or incomplete information.
- Erasure: Request deletion of personal information in certain circumstances.
- Restriction: Request that we restrict the processing of your information in certain circumstances.
- Objection: Object to certain processing, including processing based on legitimate interests.
- Data portability: Request your personal information in a portable format where the legal conditions apply.
- Withdraw consent: Withdraw consent where our processing is based on consent.
- Complain: Raise a concern with the Information Commissioner's Office (ICO).
These rights are not absolute in every situation. For example, we may need to retain certain client records to comply with legal or regulatory obligations even if you request their deletion.
You have an absolute right to object to the use of your personal information for direct marketing.
To exercise your rights, please contact us using the contact details in Section 2. We may need to verify your identity before responding.
We will respond within the applicable statutory time limits.
15. Complaints and the Information Commissioner's Office
If you have a concern about how SureVisa Ltd handles your personal information, please contact us first so that we can investigate and respond.
You also have the right to complain to the UK Information Commissioner's Office (ICO), the independent authority responsible for upholding information rights in the United Kingdom.
Website: https://ico.org.uk/make-a-complaint/
You may contact the ICO directly if you believe that your personal information has been handled unlawfully or your data protection rights have not been respected.
16. Automated Decision-Making
We do not intend to make decisions about you solely through automated processing, including profiling, where those decisions produce legal effects or similarly significant effects on you, unless permitted by law and subject to the applicable safeguards.
If our practices change, we will provide the information required by applicable data protection law.
17. Children's Information
Our services may involve immigration matters concerning children or dependants. Where necessary, we may process a child's personal information to provide the relevant service or meet legal and regulatory obligations.
We handle children's information with appropriate care and take account of their rights and interests. Where required, we will obtain information or instructions from an appropriate parent, guardian or authorised representative, subject to applicable law and the circumstances of the matter.
18. Links to Other Websites
Our website may contain links to third-party websites or services.
We are not responsible for the privacy practices or content of websites that we do not operate. We encourage you to read the privacy policies of those websites before providing personal information.
19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our services, business practices, technology or applicable law.
Any revised version will be published on our website with an updated revision date. Where required by law, we will provide additional notice of material changes.
20. Contact Us
If you have questions about this Privacy Policy, wish to exercise your data protection rights or want to raise a concern about the handling of your personal information, please contact:
SureVisa Ltd
Website: https://www.surevisa.co.uk
Email: info@surevisa.co.uk
Business address: Harris House, 1B Park Avenue, Mitcham, London CR4 2EQ
We will consider your request and respond in accordance with applicable data protection legislation.