GDPR Compliant

Privacy Policy

Information about the processing of personal data by IVS / ComfortPass in accordance with Regulation (EU) 2016/679 (GDPR). Applicable as of May 25th, 2018.

Data Protection Notice

To comply with Regulation (EU) 2016/679 (GDPR), INTERNATIONAL VISA SERVICE Limited Liability Company Limited Partnership informs about the processing of personal data and the rights to which clients are entitled. Rules applicable as of May 25th, 2018.

1The Controller of Personal Data

Who is responsible for your data

Legal Entity

IVS sp. z o.o. sp.k.

ul. Graniczna 29 (29 Graniczna St.)

40-017 Katowice, Poland

NIP: 9542766476 · REGON: 364718356

KRS: 0000623079

Katowice-Wschód District Court, 8th Commercial Division

2Data Protection Officer

Your DPO contact

Aleksander Posmyk

Data Protection Officer at IVS

+44 2031 293 603[email protected]

3Purpose and Legal Basis of Data Processing

Why we process your data

IVS processes personal data for the purpose of executing a contract to which the person whose data are processed is a party, or to take actions at the request of the data subject before concluding the contract (Article 6 par. 1 letter b of the GDPR).

In certain situations, IVS may process personal data due to the need to comply with legal obligations (Art. 6 par. 1 letter c), protect vital interests (Art. 6 par. 1 letter d), or for the purposes of legitimate interests (Art. 6 par. 1 letter f), in particular:

  • 1)Marketing of IVS products and services;
  • 2)Monitoring and improvement of the quality of services provided by IVS, including monitoring of telephone conversations and meetings, carrying out customer satisfaction surveys;
  • 3)If applicable, the conduct of disputable proceedings, as well as proceedings before public authorities and other proceedings, including carrying on enquiry and defence against claims;
  • 4)Improving the quality of services, which includes examining traffic on the website and profiling.

Consent-based processing: In all other situations, personal data are processed solely on the basis of consent granted for the purpose specified in its content (Article 6 par. 1 letter a of the GDPR). We do not process sensitive personal data.

4Recipients of Data

Who may receive your data

Public authorities

Public authorities and relevant state offices in connection with the fulfillment of obligations arising from legal regulations.

Payment processors

Entities that participate in the processes necessary to perform contracts concluded with clients, including banks, credit card operators, electronic and online payment agents.

Business support entities

Entities which support IVS in business processes — hosting companies, legal and accounting services, and external entities carrying out activities necessary to conclude the contract.

5Time of Data Processing

How long we keep your data

Contract data

Until executed

+ up to 7 years max

Legitimate interest data

Up to 7 years

From collection date

Consent-based data

Until withdrawn

Withdraw anytime

The client's personal data are processed by IVS for the time necessary to achieve the objectives indicated in point 3, that is, until the Agreement is fully executed and the Service is concluded. After that period, IVS may process the client's data for a period specified by law, however, no longer than 7 years since their collection. Insensitive data processed on the basis of separate consent shall be kept until the consent is withdrawn.

6Your Rights as a Data Subject

GDPR rights guaranteed to all clients

1

Right to Access

You have the right to access your personal data held by IVS.

2

Right to Rectification

Request correction of incorrect data or supplementing of incomplete data.

3

Right to Erasure

"Right to be forgotten" — you can request deletion of your data in specific circumstances (data no longer necessary, unlawful processing, etc.).

4

Right to Restriction

Request restriction of processing in certain situations (e.g. while a dispute is resolved).

5

Right to Data Portability

Receive your data in a structured, machine-readable format when processing is based on consent or contract and is automated.

6

Right to Object

Object to processing based on legitimate interests due to your particular situation.

7Withdrawal of Consent

How to withdraw your consent

To the extent of the client's consent to processing of their personal data, the client is entitled to withdraw the consent at any time. The withdrawal takes place without affecting the legality of the processing which was carried out on the basis of the consent prior to its withdrawal.

To withdraw your consent, contact us at: [email protected]

8Right to Lodge a Complaint with the Supervisory Authority

How to escalate concerns

In any situation, when the client considers that IVS processes personal data contrary to the provisions of the GDPR, the client has the right to lodge a complaint with the appropriate supervisory authority. In Poland, the supervisory authority is the President of the Personal Data Protection Office (UODO).

9Transfer of Personal Data to Countries Outside the EEA

International data flows

IVS may transfer personal data to international organizations and countries outside the European Economic Area for which the Commission has not found an adequate level of protection. The transfer of data takes place on the basis of standard contractual clauses agreed with the recipient, the content of which has been adopted by the European Commission and ensures the highest standards of personal data protection applied on the market.

🇨🇦

Canada

Transfer is necessary for carrying out the contract of the visa agency. The Commission decision of 20th December 2001 stated that Canada ensures an adequate level of protection of personal data.

The client has the right to obtain a copy of the data transferred by IVS.

10Obligation to Provide Personal Data

Is providing data mandatory?

Providing personal data is entirely voluntary. However, providing data is a condition for concluding an agreement with IVS or it is necessary to achieve the objectives arising from the legitimate interests of IVS. Failure to provide all the data will prevent conclusion and execution of the indicated contract.

Questions about your data?

Contact our Data Protection Officer or support team: