Protecting your personal information is our priority. This Statement of Privacy applies to L & F Investor Services, LFIS, www.L-and-F.us (collectively referred to as “LFIS”). Personal information you provide is stored in a secure location and is accessible only by designated staff. We will collect and use information through our website only in the ways disclosed in this statement. The LFIS website is a private business consulting website that connects clients from across the globe wishing to apply for a U.S. visa with information and a team of highly experienced investment and installation specialists. By using the LFIS website, you consent to the data practices described in this statement.
Recently the European Union has required companies collecting personal data to follow new privacy regulations (detailed below). We are adopting those regulations for all of our users. Here is a basic overview so that you can make an informed decision about giving us your information:
– we use a customer relationship manager (CRM) called Ontraport to save customer information. You can see their GDPR policy here.
– we will periodically send you emails containing great free resources and marketing of our goods and services to you
– at any time you can use the unsubscribe link in our emails
Information Collection and Usage
We collect two types of information: (1) optional personally identifiable information, such as your name, email address, billing information and physical address when you sign up as a User or purchase products/services from LFIS. We do not honor or respond to Do Not Track requests. If you become a User and purchase access to the LFIS secure User Area, we collect billing and credit card information. (2) We may automatically collect information about your computer hardware and software. This information can include: your IP address, browser type, domain names, access times, and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the LFIS website.
We encourage you to review the privacy statements of websites you choose to link to from LFIS so that you can understand how those websites collect, use, and share your information. LFIS is not responsible for the privacy statements or other content on websites outside of the LFIS website.
Use of your Personal Information
We do not sell, rent, or lease our visitor or user lists to third parties. LFIS collects and uses your personal information to operate its website(s) and deliver the services you have requested.
We may also use your personally identifiable information to inform you of updates and provide our newsletters. LFIS may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
LFIS will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on LFIS or the site; (b) protect and defend the rights or property of LFIS; and, (c) act under exigent circumstances to protect the personal safety of users of LFIS, or the public.
The LFIS website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize LFIS pages, or register with LFIS site or services, a cookie helps LFIS to recall your specific information on subsequent visits. This simplifies the process of recording your personal information. When you return to the same LFIS website, the information you previously provided can be retrieved, so you can easily use the LFIS features that you customized.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the LFIS services or websites you visit.
Security of your Personal Information
LFIS secures your personal information from unauthorized access, use, or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
Children Under Thirteen
We do not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.
Opt-Out & Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Our email communications include an unsubscribe option where you can control the communications that you receive from us. Users may opt-out of receiving any or all communications from LFIS by contacting us through our website Contact Form submission.
Changes to this Statement
We will occasionally update this Statement of Privacy to reflect organization and customer feedback. We encourage you to periodically review this Statement to be informed of how LFIS is protecting your information.
GDPR Compliance Statement
The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardize data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.
LFIS is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR.
LFIS is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.
How We are Preparing for the GDPR
LFIS already has a consistent level of data protection and security across our organization, however, it is our aim to be fully compliant with the GDPR by 25th May 2018. Our preparation includes:
– Information Audit – carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
– Policies & Procedures – implementing new data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
– Data Protection – our main policy and procedure document for data protection has been created to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
– Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimization’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
– Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
– International Data Transfers & Third-Party Disclosures – where LFIS stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
– Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
– Legal Basis for Processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
– Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
– Obtaining Consent – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
– Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
– Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large-scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
– Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.
– Special Categories Data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via email of an individual’s right to access any personal information that LFIS processes about them and to request information about:
– What personal data we hold about them
– The purposes of the processing
– The categories of personal data concerned
– The recipients to whom the personal data has/will be disclosed
– How long we intend to store your personal data for
– If we did not collect the data directly from them, information about the source
– The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
– The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
– The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organisational Measures
LFIS takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including: – firewall, strong passwords, no local storage of contacts, and IT best practices.
GDPR Roles and Employees
LFIS has designated our founder as our Appointed Person and has appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
LFIS understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the subject.
If you have any questions about our preparation for the GDPR, please contact LFIS at:
L & F Investor Services
27 W. Anapamu Street, Suite 406
Santa Barbara, California 93101
Effective as of May 23, 2018. We reserve the right to modify this policy at any time