Bluehill Immigration & Consulting and Bluehill Recruiting (hereinafter “Bluehill”) are committed to the proper management of the personal information of clients and others, and of all visitors to our website (the “Site”) that we collect, use and disclose in the course of business.
Controlling the collection, use and disclosure of personal information is an ongoing process. We will continue to review our personal information management practices and improve them as necessary to better protect the privacy of individuals.
We are responsible under applicable privacy legislation for the Personal Information in our possession or control. This includes Personal Information we receive directly, such as from individual clients or others, and Personal Information we receive indirectly.
“Personal Information” means any information about an identifiable individual, but does not extend to information that is not personal information as defined or interpreted under applicable law, nor to information about our employees or partners.
We follow 10 principles when collecting, using and disclosing your personal information:
We are accountable for personal information under our control.
The purpose for collecting personal information is identified at or before the time it is collected.
We obtain your consent before collecting, using or disclosing your personal information, except where otherwise permitted or required by law.
We limit the personal information we collect to that which is necessary for us to conduct business.
The personal information we collect is only used, disclosed or retained for its original intended purpose (unless you provide your consent to a different use or disclosure), and we retain it only as long as necessary for those purposes.
We take care to ensure that the information we have is accurate.
We safeguard your personal information through security measures.
We are open with you about our policies and practices related to managing your personal information.
Upon request, we provide you with access to your personal information, subject to any limitations imposed by law.
We address your concerns. If you have questions or concerns regarding your privacy or this Policy please contact us as described below.
Consent may be provided orally or in writing, or it may be implied, such as where you continue to provide Personal Information to us in the context of an ongoing relationship, or where you provide Personal Information to members of Bluehill in connection with our service offerings. This includes Personal Information provided in the course of our representing you in immigration and/or recruitment matters, which may require disclosure as part of the immigration proceedings or recruitment process. We will not, as a condition of supplying a service, require you to consent to the collection, use or disclosure of your Personal Information beyond that which is required to enable us to provide the service(s) requested.
If you provide us with Personal Information of another individual, you represent and warrant that you have the authority to do so, and, where applicable, that you have obtained the necessary consent for us to collect, use and/or disclose such Personal Information for the purposes described in this Policy.
You may refuse to give Personal Information and may, subject to legal or contractual restrictions and reasonable notice, withdraw your consent to the continued use and disclosure of Personal Information previously collected, by contacting our privacy officer, whose contact information can be found below. The period of reasonable notice will depend on the nature of the information. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain immigration services.
If you provide us with the personal information of another individual, you represent and warrant that you have the authority to do so, including where applicable that you have obtained the necessary consent of the other person for us to collect, use and/or disclose their personal information.
COLLECTION OF PERSONAL INFORMATION
We will not collect personal information indiscriminately. We will limit the amount and the type of information we collect to that necessary to fulfill the purposes we have identified to you, or as otherwise permitted or required by law. We may also collect information about your business and business interests or your personal interests to better serve you and foster our relationship.
We collect and use personal information to determine whether we can act for or against you, including to identify conflicts of interest; to offer and provide immigration and/or recruitment services to you and to communicate with you about our firm and our services; to administer our client records and to bill for our services; to fulfill our professional obligations; and as permitted or required by law or for purposes for which you otherwise provide your consent.
INTERNET SERVER PROVIDER
Certain information may be collected on the Site through various technologies, described below, without your actively providing the information.
Our website is hosted on servers shared with an Internet service provider (ISP). Any personal information collected on our behalf by the ISP, such as server log data (see below), is managed in accordance with this Policy and is protected by applicable law.
In the normal course of establishing and maintaining Internet connections, our servers automatically log information about visits to our website. Server logs record statistical information, such as a visitor’s IP address and type of operating system, the time and duration of visit and Web pages requested. The server logs also identify categories of visitors by items such as domain and browser type. These statistics are reported in aggregate form to us and are used to improve our website and ensure that it provides the optimal online experience for visitors.
We do not link server log information to any other data in a way that would enable us to identify individual visitors, except for security purposes, as discussed above.
Cookies are small text files that contain a unique identification number that are automatically deposited on a visitor’s computer. Per session cookies track information during an open session and are stored only temporarily in your computer’s memory. Persistent cookies are deposited on a visitor's computer until they expire or until the visitor deletes the cookies. Information from these cookies help us analyze traffic patterns to the Site, including the total number of visitors, the geographical location of the visitor, and the types of Internet browsers (e.g., Google Chrome or Microsoft Edge) and operating systems (e.g., Windows or Macintosh) that our visitors use. We use this information to facilitate and enhance your online visits. We do not cross-reference this information with any type of personal information that is voluntarily offered through the Site.
The Site also uses third party vendor re-marketing tracking cookies, including the Google AdWords tracking cookie. We do not collect personal information through the use of Google's or any other third party remarketing system.
USE OF PERSONAL INFORMATION
We use personal information only as described in this Policy or as otherwise disclosed to your or permitted or required by law. Before your personal information is used or disclosed for a new purpose, we will ask for your consent unless use or disclosure without your consent in the circumstances is otherwise permitted or required by law.
In order to maintain a professional level of service, we may occasionally ask you to update your Personal Information or preferences. Alternatively, you may request corrections to be made where you can show that the information we possess is inaccurate. You are responsible for ensuring that the information you have provided is truthful, accurate, reliable and complete, and does not infringe the rights of others.
If you wish to access, verify or update your Personal Information, or have concerns relating to your access to or to the accuracy of your Personal Information, you may contact our privacy officer whose contact information can be found below. Clients are encouraged to direct such requests or concerns to their lawyer. We will respond to such requests or concerns within a reasonable timeframe.
CHANGES TO THIS POLICY
We may amend this Policy at any time. We will post the Policy as amended on our website and will take reasonable steps to inform you of any amendments.
MORE INFORMATION ABOUT BLUEHILL’S PRIVACY PRACTICES
Please contact Bluehill’s Privacy Compliance Officer with any questions or concerns you have about this Policy or Bluehill’s handling of your personal information. We will promptly respond to your inquiry.
Kwang Joo (Julie) Kim
Certified Information Privacy Professional/Canada (CIPP/C)
Certificate No. 000240506I