Dolcemigration

Privacy Policy

DolceMigration – Privacy Policy

Your privacy is important to us. It is DolceMigration’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, https://dolcemigration.com, and other sites we own and operate.

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service. Particularly in the context of migration services, this can include sensitive details necessary for applications and consultations.

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.

This policy is effective as of October 26, 2023.

Last updated: October 26, 2023.

Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

Log Data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Personal Information

We may ask for personal information — when you contact us or utilize our services — which may include one or more of the following:

  • Name
  • Email
  • Date of birth
  • Phone/mobile number
  • Home/mailing address
  • Passport details
  • Family information (relevant to migration cases)
  • Employment history (relevant to migration cases)
  • Educational background (relevant to migration cases)
  • Financial information relevant to migration applications/consultations

This information, particularly details related to migration status, applications, and personal history, is treated with a high degree of confidentiality.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

Collection and Use of Information

We may collect personal information from you when you do any of the following on our website:

  • Use a mobile device or web browser to access our content
  • Contact us via email, social media, or on any similar technologies
  • Engage our services for visa assistance, citizenship applications, or relocation consulting
  • When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to provide you with our platform’s core features and services
  • to deliver migration consulting, application assistance, and related services to you
  • to contact and communicate with you regarding your inquiries or services
  • for internal record keeping and administrative purposes
  • to comply with legal obligations related to migration advising and services

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, Our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.

You are responsible for ensuring the security of your own information when interacting with our services (e.g., ensuring the confidentiality of information shared via email or other channels).

How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of engaging our migration services, we may retain this information for the duration of the service engagement, and for a reasonable period afterwards for record-keeping, compliance, and to address any follow-up inquiries or potential legal requirements. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

  • a parent, subsidiary or affiliate of our company
  • third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers (like Bluehost), analytics platforms (like Google Analytics), CRM and marketing platforms (like Hubspot, Vbout), AI service providers (like Google Gemini, OpenAI used for internal processing or communication assistance, subject to their terms), error loggers, maintenance or problem-solving providers, professional advisors, and payment systems operators
  • our employees, contractors, and/or related entities
  • our existing or potential agents or business partners
  • courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights (this may include immigration authorities if legally required as part of service delivery)
  • third parties, including agents or sub-contractors who assist us in providing information, products, services, or direct marketing to you
  • third parties to collect and process data
  • an entity that buys, or to which we transfer all or substantially all of our assets and business

Third parties we currently use include:

  • Google Analytics
  • Hubspot
  • Vbout
  • Bluehost
  • Google Gemini (or other Google AI services)
  • OpenAI

International Transfers of Personal Information

The personal information we collect is stored and/or processed primarily in the United States, or where we or our partners, affiliates, and third-party providers maintain facilities.

The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information (e.g., Canada or EU/UK). If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordanceance with the requirements of applicable law (e.g., ensuring appropriate safeguards); and (ii) we will protect the transferred personal information in accordance with this privacy policy.

Your Rights and Controlling Your Personal Information

  • Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it (especially migration services requiring specific details).
  • Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
  • Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
  • Access: You may request details of the personal information that we hold about you.
  • Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
  • Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer, we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
  • Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
  • Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
  • Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Use of Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.

Please refer to our cookie policy page for more information.

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy (dolcemigration.com/privacy-policy).

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

Additional Disclosures for U.S. States Privacy Law Compliance

The following section includes provisions that comply with the privacy laws of certain US states (e.g., California, Colorado, Delaware, Florida, Virginia, and Utah) and is applicable primarily to the residents of those states. Specific references to a particular state are only a reference to that state’s law and apply only to that state’s residents. Non-state specific language applies to all of the states listed above where applicable.

  • Do Not Track: Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals. We adhere to the standards outlined in this privacy policy.
  • Cookies and Pixels: At all times, you may decline cookies from our site if your browser permits. Refer to the Cookies section and our Cookie Policy.
  • California Privacy Laws (CCPA/CPRA):
    • Under California Civil Code Section 1798.83 (Shine the Light), California residents may request information about sharing personal information with third parties for their direct marketing purposes. Contact us with “Request for California privacy information” in the subject line.
    • Notice of Collection: In the past 12 months, we have likely collected categories of personal information including: Identifiers (name, email, phone, IP address, passport info); Customer records (address, potentially financial info); Demographics (DOB, potentially family info); Professional or employment-related information; Education information; Inferences (preferences based on site usage). Note: Some migration-related data might fall under “Sensitive Personal Information” under CPRA – careful handling is required. We collect this for the purposes described in “Collection and Use of Information”.
    • Right to Know and Delete: California residents have the right to request details about the specific pieces of personal information collected, the categories of sources, the purposes, the categories of third parties shared with, and to request deletion of their personal information, subject to certain exceptions (e.g., necessary to complete a transaction/service, legal compliance). Contact us to exercise these rights.
    • Right to Correct: California residents have the right to request correction of inaccurate personal information.
    • Right to Limit Use of Sensitive Personal Information: If applicable under CPRA, you may have rights regarding the use of sensitive data (like passport numbers or financial details) beyond what’s necessary for service provision.
    • Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

Additional Disclosures for UK General Data Protection Regulation (UK GDPR) & EU General Data Protection Regulation (GDPR) Compliance

  • Data Controller: For the purposes covered by this Privacy Policy, DolceMigration is the Data Controller.
  • Legal Bases for Processing: We process personal information based on: Consent (e.g., for marketing, or implied when you contact us); Performance of a Contract (providing migration services you requested); Legitimate Interests (operating the website, improving services, security, analytics); Compliance with Law (legal or regulatory obligations).
  • International Transfers: As noted, data is primarily processed in the US. When transferring data outside the UK/EEA (e.g., to the US), we rely on appropriate safeguards as required by GDPR/UK GDPR (such as Standard Contractual Clauses or adequacy decisions, where applicable).
  • Your Rights under GDPR/UK GDPR: Residents of the UK/EEA have rights including: Right to be Informed, Right of Access, Right to Rectification, Right to Erasure (‘right to be forgotten’), Right to Restrict Processing, Right to Data Portability, Right to Object, Rights related to automated decision making and profiling. Contact us to exercise these rights.
  • Complaints (UK/EU): You have the right to lodge a complaint with a supervisory authority. For the UK, it’s the Information Commissioner’s Office (ICO). For the EU, it’s the data protection authority in your country of residence. We would appreciate the chance to address your concerns first.

Additional Disclosures for Personal Information Protection and Electronic Documents Act (PIPEDA) Compliance (Canada)

  • Accountability: DolceMigration is responsible for personal information under its control. Audra De Falco is designated for accountability regarding this policy.
  • Identifying Purposes: We identify the purposes for collecting personal information at or before the time of collection.
  • Consent: Your knowledge and consent are required for the collection, use, or disclosure of personal information, except where permitted or required by law. Consent may be express or implied (e.g., by using our services after reviewing this policy). You may withdraw consent at any time, subject to legal or contractual restrictions, by contacting us (this may impact service delivery).
  • Limiting Collection: We limit collection to what is necessary for the identified purposes.
  • Limiting Use, Disclosure, and Retention: Information is not used or disclosed for other purposes without consent, except as required by law. Retention is only as long as necessary for fulfilling purposes and legal requirements.
  • Accuracy: We aim to keep personal information accurate, complete, and up-to-date as necessary.
  • Safeguards: We use security safeguards appropriate to the sensitivity of the information.
  • Openness: We make information about our policies and practices readily available.
  • Individual Access: Upon written request, you have the right to be informed of the existence, use, and disclosure of your personal information and be given access to it, subject to exceptions. You can challenge the accuracy and completeness and have it amended as appropriate. A minimal fee may apply as permitted by law.
  • Challenging Compliance: Contact us with any questions or concerns about compliance.
  • International Transfers (Canada context): Your personal information is primarily processed in the USA. While we take steps to ensure protection, information in the USA may be subject to US laws, potentially accessible by US authorities. By providing your information, you consent to this transfer and processing.
  • Complaints (Canada): If concerns are not resolved, you can contact the Office of the Privacy Commissioner of Canada.

Contact Us

For any questions or concerns regarding your privacy, you may contact us using the following details:

Audra De Falco
DolceMigration
ciao@dolcemigration.com

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