VFS GLOBAL PVT LTD PRIVACY DISCLAIMER Version 1.0
Privacy Disclaimer Scope VFS GLOBAL (hereinafter referred to as VFS GLOBAL ) is an outsourced partner of Diplomatic Missions across globe, and is authorized to receive applications for various categories of visa, permit and travel document and perform administrative and non-judgmental tasks/functions related to the same, as per the mandate of concerned Diplomatic Missions. By virtue of processing these applications, VFS GLOBAL acts as a data processor and the respective Diplomatic Mission/s are the data controller. This Privacy Policy describes how VFS GLOBAL collects, uses, discloses and manages personal information related to individuals (hereinafter referred to as Applicant/s ) applying for visas and permits, and makes available to relevant authorities for the purpose detailed below. Purpose of collection, use, disclosure etc. of Personal Information Applicants may be required to provide certain information pertaining to them such as name, photograph, address, date of birth, telephone number, passport information, birth certificate, income, citizenship status, marital status, employment details, criminal and educational background information etc. This information is collected as per the requirement mandated by the concerned Diplomatic Missions / Governments and/ or relevant Visa Offices. Such personal information may be collected, used or disclosed in order to facilitate the processing of visa VFS Internal Page 2 of 16
application(s) and/or request(s) including but not limited to for the following purposes: Process applications received for requests for various categories of visa, permit and travel documents etc. and perform various tasks/ functions related thereto; Respond to various inquiries on the visa application submission process in general. Respond to various inquiries regarding status of application made with VFS GLOBAL; Provide/ offer any other services as per requirements of the respective Governments /Diplomatic Missions. Provision of personal information is voluntary. Please note, however, that a refusal to provide personal information may limit or affect ability of VFS GLOBAL to provide the requested services. As mandated by the Diplomatic Mission/s, VFS GLOBAL may (by itself of through third party service providers/ vendors) provide various facilities for inquiries related visa application process in general and/ or status of visa applications submitted through VFS GLOBAL such as call center, online tracking, e-mail etc. Inquiry about general visa application process: VFS Internal Page 3 of 16
Users making inquiries as regards visa application process in general, need not provide any personal information. Inquiry about status of submitted visa application/s: Users making inquiries as regards status of visa application submitted through VFS GLOBAL can quote application reference number to receive an update on the status of their visa, permit or travel document applications. The users may be requested to provide personal information such as given name or family name or date of birth or phone number or street address or email address or application date etc. or combination of such information for verification/ authentication purposes. Users making inquiries as regards visa application process however should not ask or reveal the passport number or personal information while interacting via email with VFS GLOBAL and/or its third party service providers/ vendors. Instead use of application reference number is recommended. VFS GLOBAL shall not be obliged to respond to e-mails containing personal information. In case any personal information is disclosed, the same shall be at the sole risk of the Users/ applicants and VFS GLOBAL will not be in any manner responsible for any events of misuse etc. For the quality control purposes the interaction/s with user/s may be recorded. In such cases the user/s will be informed of this practice and purpose at the start of any such VFS Internal Page 4 of 16
interaction. Unless a different requirement is mandated by the respective Diplomatic Mission/s, such recordings will be purged after a period of 30 days from the date of such interaction/s. Interview Scheduling: Certain Diplomatic Missions may require the Applicant s to attend for personal interview. Applicants will be required to provide their application reference number and/or certain personal information such as family name, given name, date of birth, phone number, street address, email address, application date, and passport number for purpose of scheduling interviews. All such information, posted, furnished and submitted by the Applicants while scheduling an interview appointment is converted into such formats as may be required and communicated to the respective Diplomatic Mission having jurisdiction to receive such application/s. Certain data and information related to visa applications received by VFS GLOBAL is presently stored/ hosted at data centre/s in UK (London) and India (Mumbai). The data captured by VFS Global in its systems for processing of visa VFS Internal Page 5 of 16
applications of applicants from European Union is stored within the European Union (EU) boundary. The data of applicants other than that from EU may be stored in VFS Global systems either within the EU boundary at data center in UK (London) or at data center in India (Mumbai). This information may be used, disclosed by VFS GLOBAL for performing its various obligations towards respective Diplomatic Missions and will be purged within 30 (thirty) days from the date of receipt by VFS GLOBAL. However no information/ data containing Personal Information of the Applicant/s is stored at the data centre/s mentioned above. Disclosures of Personal Information: VFS GLOBAL will not trade, rent or sell personal information of the Applicants. VFS GLOBAL does disclose or otherwise transfer Personal Information of the Applicants, except as otherwise set out herein. Personal Information will be used only for the purposes of providing services and performing its various obligations. However VFS GLOBAL may need to disclose and share Personal Information when it is necessary to comply with a VFS Internal Page 6 of 16
court order, any on-going judicial proceeding, or other legal, statutory or regulatory process served on VFS GLOBAL or to exercise the legal rights or defend against legal claims, criminal investigations, judicial matters or in prevention, investigation, detection, prosecution of criminal activities or matters related to national security. VFS GLOBAL hereby state that in accordance with Protection of Personal Data Law ( PPDL ) numbered 6698; your personal data that you have shared with us and that we required in capacity of processor on condition to be related, limited and retrained with purpose of processing; and in line with purposes these to be processed; shall be recorded, stored, retained, rearranged, shared with institutions who are lawfully authorized to require these, transferred to third parties in land or abroad in circumstances stipulate by PPDL, assigned, classified and be processed under other manners stipulated in PPDL. Service Provider Arrangements: VFS GLOBAL may disclose (or otherwise make available) personal information to third party service providers providing services like courier delivery, SMS, call center services. These third party service VFS Internal Page 7 of 16
providers are provided with such information they need to perform their designated functions and are not authorized to use or disclose personal information for their own purposes. For example, where the visa applicant has opted for courier service, VFS GLOBAL will disclose certain Personal data such as name, address, phone number to the third party courier service providers. However personal information will not be shared with service provider/s for SMS service/s. Such third party service providers are also required to adhere to security & privacy requirements as outlined by VFS GLOBAL. Cookies Cookies are files or pieces of information that may be stored on system or internet enabled devices of the User, when the User visits the website/s of VFS GLOBAL. VFS GLOBAL uses cookies to make the website/s simpler to use. VFS GLOBAL cannot identify the User personally from this information. VFS GLOBAL website offers certain features that are only available through the use of cookies. VFS Internal Page 8 of 16
The cookies help website users and maintain their signed-in status. Most cookies are "session cookies," meaning that they are automatically deleted from website user s hard drive at the end of a session when the applicant/user exits the website. However Persistent cookies remain in place across multiple visits to our websites. Applicant/ website user may encounter cookies from any links of third parties on certain pages of the website that VFS GLOBAL does not control. Once a User accesses the website/s of VFS GLOBAL, User consents to use of cookies by VFS GLOBAL. If User does not agree to use of cookies, User should not use website/s of VFS GLOBAL. If the cookies are disabled, it may impact the User experience on website/s of VFS GLOBAL. SPAM VFS GLOBAL does not tolerate spam. VFS GLOBAL website/s or communication tools shall not be used to send spam or otherwise send content VFS Internal Page 9 of 16
that would violate the terms and conditions of VFS GLOBAL user agreement. VFS GLOBAL filters and automatically scans messages for viruses and other illegal or prohibited content before they are sent. To report any issues related to spam or spoof emails to VFS GLOBAL, please address e-mails to communications@vfsglobal.com. VFS GLOBAL does not permanently store email messages sent to or by it through various formats. VFS GLOBAL does not rent or sell any email addresses to third parties. A user/users is/are not licensed, permitted, expected to add, modify, deface, hack, misuse or abuse VFS GLOBAL website or the contents therein. Security VFS GLOBAL has implemented measures designed to help protect personal information in its custody and control. VFS GLOBAL maintains reasonable administrative, technical, physical and organizational safeguards in an effort to protect personal information VFS Internal Page 10 of 16
in its custody and control. However, VFS GLOBAL shall not be liable for unlawful access, use, modification, destruction, or interceptions by unauthorized persons. Retention & Destruction of Personal Information: Application packages collected from Applicants will not be copied or retained by VFS GLOBAL. Unless otherwise mandated by the concerned Diplomatic Mission, any other paper, hard copies, forms or other records containing personal information will be destroyed by a secure shredding process within thirty (30) days of a passport s return to an applicant. For the purposes of assisting the Applicants should they contact VFS GLOBAL with follow-up queries, Applicant personal information may be retained in electronic form, after passport and/or documents have been returned to the Applicants, for a maximum of thirty (30) days or for such period as specified by the respective Governments/ Diplomatic Missions. VFS Internal Page 11 of 16
VFS GLOBAL performs secure disposal or destruction of personal information on the equipment or devices used for storing personal information. When disposing of equipment or devices used for storing personal information (such as filing cabinets, computers, diskettes, and audio tapes), VFS GLOBAL takes appropriate measures such as removal or deletion of any stored information to prevent access by unauthorized parties. Legal VFS GLOBAL and its third party service providers/vendors may provide personal information in response to a search warrant or other legally valid inquiry pursuant to contravention of law / order or to an investigative body or as otherwise required or permitted by applicable law VFS GLOBAL may also disclose personal information where necessary for the establishment, exercise or a defense of legal claims, or as otherwise permitted by law. Third Party Links VFS Internal Page 12 of 16
VFS GLOBAL website may contain links to other/ third party sites promoting various products and/or services that VFS GLOBAL does not own or operate. These links to websites are in nature of paid advertising are not verified by VFS GLOBAL. These links are provided for convenience access to these links is voluntary and does not indicate that VFS GLOBAL endorses or is associated with any of these other third party websites. Users are requested to use their own discretion which dealing with these websites and neither VFS GLOBAL nor its officers, employees, agents shall have any responsibility or liability of any nature whatsoever for these other third party websites or any information contained in them. These linked websites have their own separate and independent privacy statements, notices and terms of use, which Users are recommended to carefully review the same. VFS GLOBAL does not have any control over such third party websites, and therefore shall have no liability or responsibility their personal information practices. VFS Internal Page 13 of 16
To Personal Information Please note that disclosure of personal information is voluntary. The Applicants / Users disclosing personal information shall be deemed to have read and understood this Privacy Policy and consents to use and disclosure of the personal information as provided in this Privacy Policy. The Applicants / Users have right to withdraw their consent prior to further disclosure of the personal information by VFS GLOBAL to the Diplomatic Missions / Governments and/ or relevant Visa Offices or other third parties. Applicant/s have right to their personal information provided by them. Users may request access to their personal information by writing an email to the Info email ID mentioned on the Contact Us page with subject line as Subject Access Request. This request will be forwarded to the respective Governments/ Diplomatic Missions since they are the data controllers and further action will be taken by VFS GLOBAL based on the directions received by the respective Governments/ Diplomatic Missions. VFS Internal Page 14 of 16
VFS GLOBAL shall not be responsible to ascertain authenticity or accuracy of the information provided by the Applicant. It shall be the duty of the Applicant to ensure that the information provided to VFS GLOBAL is accurate, complete and upto date. Changes to This Privacy Policy Please be advised that the Privacy Policy may be updated from time to time and Users/ Applicants to regularly visit VFS GLOBAL website to access the latest policy statement. Contact Us For any questions about this Privacy Policy or the practices described herein, please write to vfsprivacy@vfsglobal.com for more information. Inquiries VFS Internal Page 15 of 16
For inquiries as regards Privacy Policy please send e- mail to VFS Global privacyofficer@vfsglobal.com. VFS Internal Page 16 of 16