Privacy Policy

Innova Educational Services LLC, operating as Innova Evaluations (“Innova”, “we”, “our” or the “Company”, and its cognates), respects the privacy of its clients and visa applicants, and is committed to protecting the personal information you may share with us. We also protect the privacy of our clients' employees, as well as visitors to our website, site visitors, followers, vendors, service providers, partners, and other individuals who come into contact with Innova (these and anyone else about whom we collect personal data will be collectively referred to as “Clients”, “you”, or “Data Subjects”).

Innova provides foreign credential evaluations and associated visa application services (the “Services”) on behalf of our Clients to their own customers who wish to apply for a Visa to work or study, or to continue working or studying, in the U.S. (“Visa Applicants”).

This privacy policy and notice (the “Privacy Policy”) explains the types of information we may collect from you, that we may receive about you, or that you may provide when you visit our website, including at innovaevaluations.org (the “Website”), our social media pages, or that you may provide to us in the course of your interest in our services, business transactions, or conferences. This policy also explains how we process the personal data of Visa Applicants on behalf of our clients. We are transparent about our practices regarding the information we may collect, use, maintain, and process, and we describe our practices in this Privacy Policy. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This Privacy Policy describes our data management practices subject to the data protection law of the European Economic Area (the “Data Protection Law”). With respect to such personal data, Innova will generally be a data controller (the “Controller”) in relation to the Personal Data of our clients and prospective clients. Innova will generally be a data processor (the “Processor”) in relation to Visa Applicants.

1. WHAT INFORMATION DO WE COLLECT?

Summary: We collect both personal data that can identify individuals and non-personal data. We collect personal data about visa applicants, our clients, users of our website, our visitors, our employees and job candidates, and service providers.

We collect data about you in connection with your transactions with us, or in processing data for our clients.

One type of data is non-identifiable, anonymous information (“non-personal data”). We also collect various categories of personal data, sometimes also called Personally Identifiable Information or “PII” (“Personal Data”).

Here we detail two categories of Personal Data that we collect from, on behalf of, or in connection with our Clients.

Data we collect about you from your transactions with us:

The personal data collected consists of any personally identifiable details knowingly and voluntarily provided by you, or by an organization you represent or are associated with, or through your use of the website (as described below). This may include your name (first and last name), email address, phone numbers, photograph, mailing address, job title and organization name, and other information you may choose to provide to Innova. In addition, we may obtain location data related to the geographic location of your laptop, mobile device, or other digital device on which the Innova website is used.

You are under no legal obligation to provide any information to Innova; however, we require certain information to perform contracts or provide any services. If you choose not to provide us with certain information, we may not be able to provide you or your organization with some or all of the services.

Innova also collects the email addresses of individuals who contact Innova by email or other means or who create accounts and login credentials.

When registering on the website or submitting support or information requests through the website, Innova will collect details including your name, company name, the phone number and personal or company email you provided, address, and other similar information. Innova may use this information to offer Innova's services and support.

Innova also collects personal data through the use of closed-circuit television cameras. This may consist of video images of you in public spaces at Innova sites, as well as records of your entries and exits from Innova sites, buildings, and office floors. Innova may not be aware of the nature of the information collected through our services (for example, through our CCTV systems), and such information may include sensitive or special categories of Personal Data, but we do not knowingly collect such data about our Clients, employees, site visitors, etc.

Data we process on behalf of our clients:

Our clients collect Personal Data about candidates who wish to apply for a Visa to work in the U.S. As part of the Services we offer our clients, we store and process this Personal Data. This may include candidates' names, mailing address, email address, phone numbers, résumés, degree certificates, work experience, references, photographs, notes made by our clients on the candidates' application, and any other personal data our clients choose to collect as part of their visa application process, as well as data generated by other service providers in this process, such as immigration attorneys. This may also include sensitive categories of Personal Data, such as data revealing racial or ethnic origin, health data, and union membership. We use this data to provide foreign credential evaluation services to our clients.

2. HOW DO WE COLLECT YOUR PERSONAL DATA AT INNOVA'S FACILITIES AND SERVICES?

Summary: We collect personal data through our website and our application processes, whether online, through direct communication, or otherwise.

We collect personal data through your use of our website. In other words, when you use the website, we are aware that it gathers, collects, and records information related to such use, either independently or with the help of third-party services, as detailed below. This may include technical information and behavioral information, such as the user's Internet Protocol (IP) address used to connect their computer to the Internet, their Uniform Resource Locators (URLs), operating system, browser type, browser plug-in types and versions, screen resolution, Flash version, time zone settings, the user's “clickstream” on the website, the length of time the user visited the website, the methods used to navigate away from a page, and any phone number used to call our customer service number. Likewise, we may place cookies on your browsing devices (see the “Cookies” section below).

We collect the personal data necessary to provide services when you register interest and/or submit an evaluation request. In addition, we collect your Personal Data when you provide us with such information by entering it manually or automatically, or through your use of our website, facilities, and services, or in connection with site visits, in the course of preparing a contract, or otherwise by engaging with us. We also collect Personal Data through our CCTV recordings, which automatically collect information about your presence at Innova's facilities.

3. WHAT ARE THE PURPOSES OF THE PERSONAL DATA WE COLLECT?

Summary: We use Personal Data to provide and improve our Services, and to comply with our contractual, ethical, and legal obligations.

We will use Personal Data to provide and improve our services to our clients and others and to fulfill our contractual, ethical, and legal obligations, including, for example:

Processing that is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract (GDPR Article 6(1)(b)), such as:

carrying out our obligations arising from any contract entered into between you or your employer or organization and Innova and/or any contract entered into with Innova, and providing you with the information, products, and services you request from Innova;
managing your account with Innova, including identifying and authenticating you and your organization's users;
verifying and carrying out financial transactions in relation to payments you make in connection with the products;

Processing that is necessary for compliance with a legal obligation to which Innova is subject (GDPR Article 6(1)(c)) or processing that is necessary for the purposes of the legitimate interests pursued by Innova or by a third party (GDPR Article 6(1)(f)) of providing an efficient and effective service to clients, including:

notifying you about changes to our service and products;
contacting you for the purpose of providing technical assistance and other information related to the products;
responding to your inquiries, troubleshooting problems, detecting and protecting against errors, fraud, or other criminal activities;
contacting you to provide commercial and marketing information about events or promotions or additional services and products offered by Innova, including at other locations;
requesting feedback in connection with your use of the services;
tracking the use of Innova's facilities and services to allow us to optimize them;
contacting you to inform you about additional services that may be of interest to you;
compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for the prevention and prosecution of crime to the extent it relates to our staff, clients, facilities, etc.;
if necessary, we will use personal data to enforce our terms, policies, and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity theft, and any other misuse of the service, and to take any action in any dispute and legal proceeding;
for security reasons and to identify and authenticate your access to the parts of the facilities;
we collect personal data from our clients' staff, which will be used for the purposes set out above.

4. SHARING DATA WITH THIRD PARTIES

Summary: We transfer your Personal Data to third parties who assist us in providing the Services. We have a contract with those third parties to govern their processing on our behalf. We may also transfer Personal Data to comply with any obligation we may have.

We transfer Personal Data in a variety of circumstances. We take steps to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties include business partners, suppliers, affiliates, agents, and/or subcontractors for the performance of any contract we enter into with you. They assist us in providing the services we offer, processing transactions, fulfilling information requests, receiving and sending communications, analyzing data, providing IT and other support services, or in other tasks, from time to time. These third parties may also include search engine and analytics providers that help us improve and optimize our website and marketing.

We periodically add and remove third-party providers. At present, our third-party providers to whom we transfer personal data also include the following:

Experts who evaluate foreign credentials in various fields.
Microsoft and other computing and cloud service providers.
CRM, cybersecurity, billing, payroll, scheduling, task management, team collaboration, and other similar business service providers.
Call centers.
Our attorneys, accountants, and other standard business service providers.
Other partners and industry-standard business software.

In addition, we may disclose your personal data to third parties if part or all of our businesses or assets are acquired by a third party, including through a merger, stock acquisition, asset purchase, or any similar transaction, in which case personal data may be one of the transferred assets. Likewise, we will transfer personal data to third parties if we are under an obligation to disclose or share your personal data to comply with any legal, audit, or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect the rights, property, or safety of Innova, our clients, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes and to prevent cybercrime.

For the avoidance of doubt, Innova may transfer and disclose non-personal data to third parties at its own discretion.

5. WHERE DO WE STORE YOUR DATA?

Summary: We store your personal data on servers controlled by us or by reputable cloud service providers.

We store your Personal Data on servers that are owned or controlled by Innova, or processed by third parties on Innova's behalf, by reputable cloud service providers in the U.S., including Amazon and Microsoft. See the following section on international transfers.

6. INTERNATIONAL DATA TRANSFERS

Summary: Our services involve the transfer of data outside the EEA, which is carried out through various mechanisms, including adequacy decisions, the Privacy Shield, and standard contractual clauses.

Personal Data may be transferred, stored, and used at a destination outside the European Economic Area (EEA) that may not be subject to data protection laws equivalent to those of the EU. When your Data is transferred outside the EEA, we will take all reasonably necessary steps to ensure that your Data is subject to appropriate safeguards and treated securely and in accordance with this privacy policy. Innova transfers data to other jurisdictions as follows:

In the United States of America. Innova stores Personal Data on Microsoft servers located in the U.S. The transfer to the U.S. is subject to Microsoft's Privacy Shield certification, as well as to other GDPR-compliant service providers. Occasional transfers may be made to third-party recipients that are not Privacy Shield certified or included in an adequacy program when necessary for the performance of a contract or service for the data subject.

We may transfer your personal data outside the EEA in order to:

store or back up the information;
enable us to provide you with the services and products and fulfill our contract with you;
comply with any legal, audit, ethical, or compliance obligation that requires us to make that transfer;
facilitate the operation of our group's businesses, where it is in our legitimate interest and we have concluded that these are not overridden by your rights; and to serve our clients in multiple jurisdictions.

7. DATA RETENTION

Summary: We retain your Personal Data only for as long as necessary to fulfill our legal and ethical obligations, which for different types of data will be different periods. For the visa applicant, that is usually five years from the issuance of the visa.

Innova will retain the personal data it processes only for as long as, in our judgment, is necessary to provide the services and as necessary to comply with our legal and other obligations, to resolve disputes, and enforce agreements. Given the nature of the outcome of our work with Personal Data, i.e., the issuance of visas for Data Subjects, we consider it necessary to retain the data for five years from the date of completion of the application. We will also retain personal data to comply with any audit, compliance, and business best practices.

Data with respect to which Innova is the Processor will be deleted only by action and/or instruction of the Controller, except where we must retain such data, in our judgment, as indicated above.

Data that is no longer retained will be anonymized or deleted. Likewise, some metadata and statistical information about the use of our services are not subject to the deletion procedures of this policy and may be retained by Innova. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers' servers until deleted in accordance with their privacy and retention policies.

8. WEBSITE DATA COLLECTION, SERVICES, AND COOKIES

Summary: We use cookies, pixels, and similar technologies in our Services. You can disable cookies, but your online experience on our Services will be limited.

When you access or use our services or website, Innova uses industry-standard technologies such as cookies, pixels, and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device and, in some cases, associate them with the user, enable the automatic activation of certain features, and make your user experience more convenient and effortless. We use different types of cookies: some cookies are strictly necessary, required for the operation of our website and services under our terms with you; this includes, for example, cookies that allow you to log into secure areas of our services. We also use analytics and performance-tracking cookies, which allow us to recognize and count the number of visitors and see how visitors move around our website and services when they are using them. Finally, we use functionality cookies that are used to recognize you when you return to our Site. This allows us to personalize content according to your preferences, including, for example, your choice of language or region.

Different cookies are stored for different periods. Session cookies are used to track your online activities during a given browsing session; these cookies generally expire when the browser is closed, but may be retained on your device for a period. Persistent cookies remain in operation even after you have closed the browser; they are used to remember your login details and password. Third-party cookies are installed by third parties with the aim of collecting certain information to research behavior and demographics. Third-party cookies on our site include, for example, Google Analytics. Similarly, Facebook pixels and others that enable the integration of third-party service providers (e.g., Twitter, YouTube, Pinterest, Instagram) are not currently, but may in the future be, embedded on our site. Third-party cookies will be retained in accordance with the terms of those third parties, and you can control those cookies in your browser settings.

We use cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because their use serves our legitimate interests in improving, optimizing, and personalizing our services, and your rights do not override them.

Most browsers will allow you to clear cookies from your computer's hard drive, block the acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or delete cookies, your online experience on our website and services will be limited.

How to disable cookies: the effect of disabling cookies depends on which cookies you disable, but, in general, the website and some of the services provided through it may not function properly, may not recognize your device, may not remember your preferences, etc., if cookies are disabled or deleted. However, allowing or disabling cookies is your choice and under your control. If you wish to disable cookies on our site, you must change your browser settings to reject cookies. How you can do this will depend on the browser you use. You can find more details on how to disable cookies here:

Internet Explorer: windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
Google Chrome: support.google.com/chrome/answer/95647?hl=en
Firefox: support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Safari: help.apple.com/safari/mac/8.0/#/sfri11471

Our services and the website may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies and practices, or content of such sites.

9. INFORMATION SECURITY AND STORAGE

Summary: We take industry-standard measures to maintain the security of the Personal Data we process. Upon discovering a breach, we will promptly notify, as necessary, the controller, the relevant authorities, and the data subjects, and take steps to remedy the breach.

We take great care in implementing, enforcing, and maintaining the security of the personal data we process. Innova implements, enforces, and maintains security measures, technologies, and policies to prevent unauthorized or accidental access to, or destruction, loss, modification, use, or disclosure of, personal data. Where we consider it necessary in light of the nature of the data in question and the risks to data subjects, we may encrypt the data. Likewise, we take industry-standard measures to ensure that our website and services are secure. When we are processing data as a processor, we will process such data in accordance with the Controller's instructions, including the Controller's data security requirements.

However, please note that no data security measure is perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses, and other data security breaches will never occur.

Within Innova, we limit access to personal data to those members of our staff who: (i) require access for Innova to fulfill its obligations, including under its agreements, and as described in this Privacy Policy, (ii) have been appropriately and periodically trained with respect to the requirements applicable to the processing, care, and handling of Personal Data, and (iii) are under confidentiality obligations as required by applicable law.

Innova will act in accordance with its policies and applicable law to promptly notify the relevant authorities and data subjects in the event of any loss or theft of personal information processed by Innova, or in the event that unauthorized access to it has occurred, all in accordance with applicable law and following the instructions of a qualified authority. Innova will promptly take reasonable corrective measures.

10. DATA SUBJECT RIGHTS

Summary: Data subjects whose Personal Data is covered by the GDPR have rights to data portability, to access the data, rectify the data, object to processing, and erase the data. These rights cannot be exercised in a manner inconsistent with the rights of others.

Data subjects with respect to whose data the GDPR applies have rights under the GDPR and local laws, including, in different circumstances, rights to data portability, rights of access to data, rectification of data, objection to processing, and erasure of data. It is clarified, for the avoidance of doubt, that where personal data is provided by a client who is the data subject's employer, such data subject rights must be exercised through that client. In addition, data subjects' rights cannot be exercised in a manner inconsistent with the rights of Innova's employees and staff, with Innova's property rights, and the rights of third parties. As such, data subjects may not access, erase, or rectify employment references, reviews, internal notes and evaluations, documents, and notes that include proprietary information or forms of intellectual property. Furthermore, these rights may not be exercisable when they relate to data that is not in structured form, for example, emails, or where other exemptions apply. If processing is based on consent, data subjects generally have the right to withdraw their consent.

Where Innova is the Controller, a data subject who wishes to modify, delete, or retrieve their Personal Data may do so by contacting Innova (info@innovaevaluations.org). Please note that Innova may need to carry out a process to identify a data subject exercising their rights. Innova may retain details of such exercised rights for its own compliance and audit requirements. Please note that Personal Data may be deleted or retained in an aggregated manner without being linked to any identifier or Personal Data, depending on technical business capability. This information may continue to be used by Innova.

Data subjects in the EU have the right to lodge a complaint with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority does not address a complaint, you may have the right to an effective judicial remedy.

Where Innova is a Processor, data subjects' rights can only be exercised through the relevant Controller.

Innova will not discriminate against a consumer because the consumer exercised any of the consumer's rights, including, but not limited to, by:

Denying goods or services to the consumer.
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or the imposition of penalties.
Providing a different level or quality of goods or services to the consumer.
Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

GENERAL

Summary: We do not knowingly collect Personal Data about minors under 16. We update this policy from time to time. Our goal is to process only adequate Personal Data limited to needs and purposes. Our contact details for data protection matters are below.

We do not knowingly collect or solicit information or data from children aged 16 or under, nor do we knowingly allow children aged 16 or under to register for Innova's services. If you are 16 or under, do not register or attempt to register for any of Innova's Services or send us any information about yourself. If we learn that we have collected or been sent Personal Data from a child aged 16 or under, we will delete that Personal Data as soon as reasonably possible without any liability to Innova. If you believe we may have collected or received information from a minor aged 16 or under, please contact us at: info@innovaevaluations.org as soon as possible.

Changes to this Privacy Policy. The terms of this Privacy Policy will govern the use of the services, the website, and any information collected in connection with them. Innova may modify or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: innovaevaluations.org/politicas-privacidad/. Changes to this Privacy Policy become effective as of the “Last Revised” date indicated, and your continued use of our services will constitute your active acceptance of the changes and terms of the Privacy Policy.

Innova aims to process only adequate, accurate, and relevant data limited to the needs and purposes for which it is collected. It also aims to retain the data for the time necessary to fulfill the purpose for which it is collected. Innova only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy. Our policies and practices are constantly evolving and improving, and we welcome any suggestions for improvement, questions, or comments regarding this Privacy Policy; you can contact us (details above) and we will make an effort to respond within a reasonable time.