We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and what to do if you have a complaint.

This privacy policy does not apply to any third party websites that may have links to our own website.

Clients of this firm should read this policy alongside our general terms and conditions, which provide further information on confidentiality.

1 Who are we and what do we do?

1.1 Aviva Visas is a Limited Liability Company, Registered at the Companies House. Contact details can be found at section 15

1.2 We collect, use and are responsible for certain personal data about you. When we do so we must comply with the UK General Data Protection Regulation (UK GDPR).

1.3 Our services and website are not aimed specifically at children who are usually represented by their parents or guardians. If you are a child and you want further information about how we might use your data, please contact us (see ‘How to contact us’ at section 15).

2 Terminology

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Aviva Visas, a limited liability Company incorporated in England and Wales with registered number 13991315, with registered office is at 341 B Regents Park Road, London, N3 1DP.
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientatio
Data subject	The individual who the personal data relates to

3 Personal data we collect about you

3.1 We collect or use the following information

Personal data we will collect	Personal data we may collect depending on why you have instructed us
Your name, address and telephone number	Your National Insurance and tax details
Information to enable us to check and verify your identity, e.g. your date of birth or passport details	Details of your professional online presence, e.g. LinkedIn profile
Gender and pronoun preferences	Details of your spouse/partner and dependants or other family members, e.g. if you instruct us on a family matter or a will
Occupation	Your employment status and details including salary and benefits, e.g. if you instruct us on matter related to your employment or in which your employment status or income is relevant.
Marital status	Criminal records data, including driving or other convictions
Electronic contact details, e.g. your email address and mobile phone number	Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information.
Information relating to the matter in which you are seeking our advice or representation	Your employment records including, where relevant, records relating to sickness and attendance, performance, disciplinary, conduct and grievances.
Your financial details so far as relevant to your instructions	Genetic information and/or biometric information used to identify someone, e.g. where this is relevant to matter we are working on for you.
Payment details (including card or bank information for transfers and direct debits)
Information about how you interact with and use our website, products and services
Audio recordings, e.g. calls
Video recordings, e.g. of virtual meetings

3.2 The main purpose of collecting and using this information is to provide products and services to you. However, we may also collect and use the above information for the purposes set out in section 5.3.

3.3 If you do not provide personal data we ask for, it may delay or prevent us from providing those services

4 How your personal data is collected

4.1 We collect most of the above information from you.

5 How and why we use personal data

5.1 Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

5.1.1 You have given consent—where we need your consent, we will ask for it separately of this privacy policy and you can withdraw consent at any time;

5.1.2 To comply with our legal and regulatory obligations;

5.1.3 To fulfil our contract with you or take steps at your request before entering into a contract; or

5.1.4 For our legitimate interests or those of a third party.

5.2 A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or the processing is required to establish, exercise or defend legal claims.

5.3 The table below explains what we use your personal data for and why.

What We Use Your Personal Data For	Our Reasons
Providing services to you	To fulfil our services to you
Preventing and detecting fraud against you or us	For our and/or your legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our clients and verify their identity	Depending on the circumstances: To comply with our service obligations For our legitimate interests
Screening for financial and other sanctions or embargoes
Other activities necessary to comply with professional obligations

5.4 Where we process special category personal data (see section 2 ‘Terminology’), we will also ensure we are permitted to do so under data protection laws, e.g.:

5.4.1 we have your explicit consent;

5.4.2 the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;

5.4.3 the processing is necessary for reasons of substantial public interest.

6 Marketing

6.1 We may use your personal data to send you updates (e.g. by email, text message, telephone, post or social media channels) about our services, including exclusive offers, promotions or new services.

6.2 We have a legitimate interest in using your personal data for marketing purposes (see section 5 ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. Where this is not the case, we will always ask for your consent.

6.3 In all cases, you have the right to opt out of receiving marketing communications at any time by contacting us to opt-out.

6.4 We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

6.5 We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

7 Who we share your personal data with

7.1 We routinely share personal data with:

7.1.1 third parties we use to help deliver our services to you, e.g. Embassies, Visa Centres, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments;

7.1.2 companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies;

7.1.3 other third parties we use to help promote our business, e.g. marketing agencies;

7.1.4 third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;

7.1.5 our insurers and brokers;

7.1.6 our banks;

7.2 We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal and professional obligations.

7.3 We or the third parties mentioned above may occasionally also share personal data with:

7.3.1 our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;

7.3.2 our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;

7.3.3 other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale or in the event of our insolvency—usually, information will be anonymised but this may not always be possible and the recipient of any of your personal data will be bound by confidentiality obligations.

7.4 If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ in section 15).

8 Where your personal data is held

8.1 Personal data may be held at our offices and those of our third-party agencies, service providers, representatives, and agents as described in section 7 ‘Who we share your personal data with’.

8.2 Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see section ‘Transferring your personal data abroad’.

9 How long your personal data will be kept

9.1 Following the end of the relevant retention period, we will delete or anonymise your personal data.

9.2 If you would like further information about how long we keep your personal data, please contact us (see ‘How to contact us’ in section 15).

10 Your rights

10.1 You have the following rights, which you can exercise free of charge:

Access	You have the right to ask us for copies of your personal data. You can request other information such as where we get personal data from and who we share personal data with. There are some exemptions which means you may not receive all the information you ask for.
Rectification	You have the right to ask us to correct or delete personal data you think is inaccurate or incomplete.
Erasure (right to be forgotten)	You have the right to ask us to delete your personal data—in certain situations.
Restriction of processing	You have the right to ask us to limit how we use your personal data—in certain situations, e.g., if you contest the accuracy of the data.
Data portability	You have the right to ask that we transfer the personal data you gave us to another organisation or to you—in certain situations.
To object	You have the right to object: At any time to your personal data being processed for direct marketing (including profiling). In certain other situations to our continued processing of your personal data.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
The right to withdraw consent	When we use your consent as our lawful basis, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

11 Keeping your personal data secure

11.1 We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use, and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

11.2 We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.

12 How to complain

12.1 Please contact us if you have any queries or concerns about our use of your personal data (see ‘How to contact us’ at section 15). We hope we will be able to resolve any issues you may have.

12.2 You may also have the right to lodge a complaint with the Information Commissioner’s Office (the UK data protection regulator also known as the ICO) and/or the relevant supervisory authority in your jurisdiction.

12.3 The contact details for the ICO are:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint

13 Changes to this privacy policy

13.1 This privacy policy was published on 14 October 2024.

13.2 We may change this privacy policy from time to time. When we do, we will publish the updated version on our website and ask for your consent to the changes if legally required.

14 Updating your personal data

We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, e.g., your surname or address—see ‘How to contact us’ at section 15.

15 How to contact us

15.1 Individuals in the UK

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.