EFFECTIVE DATE: January 7, 2019

Privacy Notice

Global Mobility Partners (GMP) wants to ensure that our clients are informed about the security
and use of personal information that we receive and process on behalf of companies, employees,
and any other affected data subjects.

Accordingly, this Privacy Notice explains in detail the types of personal information we and our
partners/service providers may collect, and how we secure that data and process it as applicable.

Personal Information We Collect and How We Use It

GMP collects personal information about individuals needing immigration support to provide
immigration consulting and legal services, relocation services and tax advising. This personal
information may include name, address, telephone number, date of birth, marital status, passport
number, employment history, educational background, tax status, employee number, job title and
function and expatriate status. Where required for the service, we will also collect personal
documents such as passport copies, educational documents, CVs, visa and permit copies, birth
and marriage certificates, employment letters, and other documents.

We obtain personal information via numerous ways, such as through our web-based case
management system, secure email server, telephone, and forms/questionnaires completed online
through a secure system or sent via secure email.

We use the personal information obtained to provide the necessary immigration related
consulting and legal services, including analyzing, completing, and processing visas and related
filings and submissions to relevant government agencies, eligibility for obtaining immigration
benefits, assisting with relocation and other expatriate matters.

Information We Share

We will not sell, share, transfer, rent, use, or distribute an individual’s or company’s information
for purposes other than those disclosed herein, unless required by law or as authorized by the
individual, employer, or company.

We share and transfer individual’s and company’s information provided by them to our service
providers as appropriate or necessary in connection with the services to be rendered. These
service providers have been retained by us and are under contract with us, such as third country
law firms, visa processing agents, translators, education evaluation services, couriers, or other
necessary entities.

We ensure these indicated service providers protect the information consistent with this Privacy
Notice and as required, in accordance with applicable third-country data privacy laws. We and
our service providers will disclose personal information to government agencies and immigration
authorities, as authorized by an individual or company, to obtain immigration benefits as
required.

How We Protect Personal Information

We ensure that all personal information obtained is protected and secured with the utmost care
for our clients. Our computers and mobile devices are all password protected and our servers use
an encrypted platform to provide enhanced security. We regularly monitor our systems for
vulnerabilities and continuously review and improve our security and data privacy protocols, in
keeping with applicable laws.

All third parties who assist in our provision of services abide by all applicable privacy and data
protection laws. They have their own internal privacy notice in accordance with this Privacy
Notice and all applicable laws.

Choices and Rights

Our clients will have the right to request access to their personal data, review, and correct
inaccuracies, delete unnecessary personal information and receive a copy of applicable personal
documents. In the event an individual or company informs us in writing of the wish to withdraw
consent and future processing of personal information we will respect the request. In the event
we are processing personal information based on our legitimate interest, a request can be made
for an immediate cessation of such activities, which we will honor.

Data Maintenance

Our client’s data is maintained in our secure repositories on the Cloud with a proven, stable, and
dependable backup and disaster recovery process. Further, we maintain a backup on another
Cloud-based secure server, to ensure business continuity.

We have a policy of maintaining all transaction data, for which the immigration process has been
completed, for 3 years, or as agreed with a client, after which this data is removed from the
servers.

At the expiry of a contract, we remove all transaction data from our servers after a six-month
period. We provide the client with an option to have all their data transferred to them at the
expiration of the contract.

Data Access

At GMP, we have a well-defined protocol that restricts access to confidential and sensitive
personal data to designated case officers only. This is strictly on a need-to-know basis. Our data
handling policy is a critical element of our employees’ training and performance management.

The access to sensitive and confidential data is restricted to a maximum of 2-3 GMP employees,
which includes the case officer, a supervisor and advisor.

We allow Client Access to relevant data on the basis that the staff designated by the Client is
familiar with the principles of data privacy. We trust that our clients have similar stringent
processes for data handling.

Policy Review

This data privacy policy is reviewed periodically not exceeding one year, where, based on
revised rules, laws, and evolution of technology landscape, we review and reconfirm or revise
this policy.

Summary

We hope this Privacy Notice has been helpful in how we handle personal information and secure
our environment for the processing of such data. We will continuously improve our privacy
protocols in keeping with changing laws applicable to our clients and coverage areas worldwide.
In certain countries, additional or different procedures not inconsistent with this Privacy Notice
may apply as necessary to satisfy local legal regulations.

If you have any questions that have not been covered herein, please contact us at:
info@globalmobilitypartnersllc.com