Modern Slavery and Privacy Policy

---

Modern Slavery Policy

This statement is made pursuant to the Modern Slavery Act 2015 and sets out the policy that Kamaly Consultancy a niche immigration practice, has taken and continues to take to ensure that modern slavery or human trafficking is not taking place within our business.

Modern slavery encompasses slavery, servitude, human trafficking, and forced labour. Kamaly Consultancy has a zero-tolerance approach to any form of modern slavery. We are dedicated to acting ethically, with integrity and transparency in all our business dealings, and to implementing effective systems and controls to safeguard against any form of modern slavery.

Our Business

Kamaly Consultancy is a niche immigration firm providing specialist immigration services worldwide. Headquartered in Cambridge, UK, we are regulated by the Office of the Immigration Services Commissioner (OISC). We adhere to rigorous ethical standards designed to protect and uphold human rights and ensure that no form of modern slavery infiltrates our operations.

Our Policies

We have implemented several internal policies to ensure ethical and transparent business conduct:

• Recruitment Policy: We conduct thorough eligibility checks for all hires, ensuring all employees  have the legal right to work in their respective countries.
• Whistleblowing Policy: We maintain a whistleblowing system that allows employees to report concerns  about unethical practices or suspected modern slavery, anonymously and      without fear of retaliation.
• Compliance Training: All employees undergo mandatory compliance training focused on recognising and preventing modern slavery and human trafficking in global immigration processes.

Our Network 

We conduct due diligence on all prospective partners and suppliers to ensure they comply with anti-slavery laws. Our process includes:

• Online checks to verify that organisations have not been involved in modern slavery.
• Mandatory compliance training for all team members involved in Kamaly Consultancy matters.

Business Practices

Kamaly Consultancy commits to the following practices:

• Treat all employees with respect and dignity.
• Pay at least the national minimum/living wage in all jurisdictions where we operate.
• Ensure no employee is required to lodge deposits or identity papers and can leave employment with reasonable  notice.
• Abolish child labour and ensure no one under the minimum legal working age is employed.
• Guarantee reasonable remuneration in  accordance with national labour laws.
• Adhere to national regulations on working  hours and paid holidays.
• Protect employee health and safety,  ensuring access to clean facilities, drinkable water, and, where  applicable, food storage areas.

Our Steps for 2025

As part of our ongoing efforts, we will take the following additional steps in 2025:

• Expand the whistleblowing policy to allow  external stakeholders to report concerns.
• Track and enhance attendance in mandatory  training sessions focusing on identifying forced labour and human trafficking.
• Collaborate with independent auditors to conduct periodic reviews of our policies and processes.

Our Performance Indicators

We measure the effectiveness of our anti-slavery efforts based on:

• The absence of reports from employees, partners, or external entities regarding modern slavery.
• Successful completion of training  programs by all employees and partners.
• Regular audits with no findings of non-compliance related to modern slavery or human trafficking.

Privacy Policy

This Privacy Policy applies to Kamaly Consultancy. We are committed to providing our clients with excellent, succinct and straightforward service. As part of this commitment, we take the trust our customers and site visitors place in us very seriously. We recognise that it is our responsibility to protect your privacy and to inform you of our information collection practices through our Privacy Policy. This Privacy Policy is effective as of April 19, 2018. 

Our Privacy Policy outlines:

• The Information that We Collect
• How the Information We Collect is Used
• Kamaly Consultancy’s EU GDPR Compliance Statements
• Kamaly Consultancy’s EU-U.S. Privacy Shield Statement and Accountability for Onward Transfers
• How We Collect Information
• How Kamaly Consultancy’s Protects Your Information
• How to opt out of Further Communication
• How to Contact Kamaly Consultancy’s
• Links to Other Websites
• Kamaly Consultancy’s stance on Collecting Personal Information from Children
• Disclaimer

Kamaly Consultancy reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.

The Information We Collect

By using our websites and/or our services we may collect and request information from you which includes your name, title, company, address, telephone number, date of birth, e-mail address and service payment details.

If Kamaly Consultancy are handling your visa or immigration matter, additional information may be requested by the application forms of destination country. These additional items can include items such as your personal and family information, educational background, employment history, travel history, and financial records. As required by relevant visa or governmental authorities such additional sensitive information can include ethnicity, race, religion, trade union membership, health related information, biometrics, and information about criminal history.

Other information we collect may include marketing information and web interaction information such as:

• Data from marketing opt-in lists, consumer surveys, or publicly available information.
• Unique IDs such as a cookie placed on a computer, mobile or device IDs.
• Internet Protocol address (“IP address”)
• Information about a device such as information contained in HTTP headers or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings and  information about or from the presence or use of “apps” on mobile devices.
• The web search term(s) a consumer used to locate and navigate to a website.

How Information Is Used

We do not sell your personal information to any third parties. Additionally, Kamaly Consultancy will not share the information with any third party, except as otherwise set forth in this Privacy Policy.

Kamaly Consultancy may share the personal information with third parties for the following purposes:

• To complete your visa, document legalization, or immigration process request as necessary to provide visa and immigration services to you and your family, including disclosure to      government agencies in the form of applications, photographs, and petitions for visa requests and/or immigration benefits. This may include providing sensitive data required for immigration process request to Visa Application Centres, Logistics Companies, Invitation Providers and/or Translators/Solicitors.
• Share data with companies that provide services to assist us with our business activities in visa and immigration request fulfilment. Any sharing of data is subject to both EU-US Privacy Shield and EU GDPR requirements outlined below.
• To improve our products and services, provide superior customer service, and identify market opportunities
• As required by law in response to requests by public authorities including meeting national security or law  enforcement requirements

Kamaly Consultancy may also use the information to communicate with you directly via survey, e-mail or direct mail, such as to inform you about newsworthy topics and upcoming events that may be of interest to you, or to confer with you regarding your visa or passport request, or immigration case. We may also use your email address to send you reminders of expiring visas, passports, or immigration status. If you would like to discontinue receiving this information, see the How to Opt-out of Further Communication section below.

Data Sharing

We do not sell your personal information. We may share your data with third parties only when necessary to fulfil your requests, such as:

• Government agencies, visa application centres,  logistics companies, and translators/solicitors.
• Service providers who assist us in our business operations, subject to confidentiality agreements.

Your Rights Under GDPR

If you are a resident of the European Union, you have the following rights under the General Data Protection Regulation (GDPR):

• Access: Request access to the personal  data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data, subject to legal requirements.
• Data Portability: Request to transfer your data to another service provider.
• Objection: Object to the processing of your data for specific purposes.

The Right to Have Your Personal Information Erased

At any time, you have the right to request that Kamaly Consultancy erase the personal information you have provided to us Kamaly Consultancy will erase any data if it is legally allowed to according to the laws and regulations in the countries in which we operate. You may request to erase your personal information via email: info@kamalyconsultancy.com . The following will then occur:

• Kamaly Consultancy will acknowledge your request.
• Kamaly Consultancy will review your specific request and the country of its origin and determine if we are lawfully allowed to oblige the request.
• Kamaly Consultancy will then either:
  • inform you that your data has been removed from our systems  or
  • inform you as to the date that Kamaly Consultancy is legally allowed to remove said data from our systems give the nature of said data and the country of its origin.

The Right to Access Your Personal Information

At any time, you have the right to access your personal information held by Kamaly Consultancy. To make a request for access to your data, a personal appearance is required at a Kamaly Consultancy location with a government issued ID. After validating the identity of the requestor, Kamaly Consultancy will provide your personal information in accordance with our policies.

International Transfer of Your Personal Information

Your information may need to be transferred outside the EU region to Government Authorities and Logistics Companies in the countries for which you have requested travel documentation to successfully process your service request. Such countries may not have data protection laws equivalent to countries in the EU. We will use all reasonable endeavours to ensure that your personal information remains confidential when transferred to such countries. You may withdraw your consent at any time but if the consent is withdrawn prior to the provisioning of the service, we will then be unable to complete the provision of the services.

If you consider that we have breached your rights under GDPR you may complain to the data protection authority in the country in which you reside or to the lead supervisory authority at https://ico.org.uk/concerns/ or by phone at +44 303 123 1113.

EU-US Privacy Shield Compliance & Accountability for Onward Transfers

Kamaly Consultancy complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

In the event Kamaly Consultancy transfers personal data covered by this Privacy Policy to a third party acting as a controller, Kamaly Consultancy will do so consistent with any notice provided to the subjects of that data and any consent they have given, and only if the third party has given Kamaly Consultancy contractual assurances that it will (i) process the personal data for limited and specified purposes consistent with any consent provided by the subjects of such data; (ii) provide at least the same level of protection as is required by the Privacy Shield Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the personal data or take other reasonable and appropriate steps to remediate if it makes such a determination. If Kamaly Consultancy has knowledge that a third party acting as a controller is processing personal data covered by this Privacy Policy in a way that is contrary to the Privacy Shield Principles, Kamaly Consultancy will take reasonable steps to prevent or stop such processing.

With respect to Kamaly Consultancy agents, Kamaly Consultancy will only transfer the personal data covered by this Privacy Policy needed for an agent to deliver to Kamaly Consultancy the requested product or service. In addition, Kamaly Consultancy will: 

(i) permit the agent to process such personal data only for limited and specified purposes; 

(ii) require the agent to provide at least the same level of privacy protection as is required by the Privacy Shield Principles;

(iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with Kamaly Consultancy obligations under the Privacy Shield Principles; and 

(iv) require the agent to notify Kamaly Consultancy if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles Kamaly Consultancy will take reasonable and appropriate steps to stop and remediate unauthorized processing.

Kamaly Consultancy remains liable under the Privacy Shield Principles if an agent processes personal data covered by this Privacy Policy in a manner inconsistent with the Privacy Shield Principles, except where Kamaly Consultancy is not responsible for the event giving rise to the damage.

If Kamaly Consultancy transfers personal data to one of its affiliated entities within its corporate group, Kamaly Consultancy will take steps to ensure that such personal data is protected within the same level of protection that the Privacy Shield Principles require.

Recourse, Enforcement and Liability

Kamaly Consultancy has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Kamaly Consultancy conducts an annual self-assessment of its consumer personal data practices to verify that the attestations and assertions the company makes about its Privacy Shield privacy practices are true and that the company’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumers may file a complaint concerning Kamaly Consultancy processing of their Personal Data. Kamaly Consultancy will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Kamaly Consultancy as specified below about complaints regarding the company’s Consumer Personal Data practices.

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, you can also submit your complaint to Privacy Trust, an independent third party. Visit https://www.privacytrust.com/drs/cibt to file a complaint.

Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

Kamaly Consultancy’s compliance with the Privacy Shield Principles is subject to the investigatory and enforcement powers of the Federal Trade Commission.

We may collect information from you in the following ways:

• By Asking: We  may collect personal information from you by asking that you provide it to      us. Kamaly Consultancy will only collect information that is needed to help us provide the service you request
• Cookies: Kamaly  Consultancy uses cookies to enhance your experience while using our      website Cookies are small text files that reside on your computer to  identify you as a unique user. Cookies may also allow us to track your  status or progress when requesting our services or information. Kamaly  Consultancy employ third-party cookies to perform functions on our behalf  such as data analysis and marketing assistance. The data that we provide  them is anonymous and does not reveal specific personal information  related to our customers. This data is used for specific functions that  require broad-based user statistics, which help to improve the overall Kamaly  Consultancy client experience. If you choose, you can set your browser to  reject cookies or you can manually delete individual or all of the cookies  on your computer by following your browser’s help file directions.  However, if your browser is set to reject cookies or you manually delete  cookies, you may have some trouble accessing and using some of the pages  and features that are currently on the Website, or that we may put on the  Website in the future. We do not respond to web browser ‘do not track’  signals however we will continue to monitor relevant legislation and policy updates and adjust our ‘do not track’ strategy as required
• Web Beacons: A  web beacon is an electronic file on a web page that allows us to count and      recognize users who have visited that page.  Among other things, a web beacon can be used in HTML-formatted email to determine responses to our communications and measure their effectiveness. For instance, if you get an email from us and click on a link in that email to go to the Website.  You can generally avoid web beacons in email by turning off HTML display      and displaying only the text portion of your email.
• Web Server Logs: Web  server logs are records of activity created by the computer that delivers  the webpages you request to your browser. For example, a web server log  may record the search term you entered or the link you clicked to bring  you the webpage. The web server log also may record information about your  browser, such as your IP address and the cookies set on your web browser  by the server.

Protecting your information

Protecting personal information, we receive from you is of crucial importance to Kamaly Consultancy. While there is always some risk involved with transmitting information over the internet, we strive to protect against the misuse of any personal information that we receive from you via our website. Kamaly Consultancy data is protected by Industry endorsed Transport Layer Security (TLS) technology. TLS is the most widely deployed security protocol used today and is used for Web browsers and other applications that require data to be securely exchanged over a network. This technology ensures the safe transmission of all data, including personal and credit card information. By taking such measures, Kamaly Consultancy customers can feel secure in the knowledge that their data is protected when using our website.

Deleting Your Information

We will retain and use your information only for as long as is necessary to comply with our legal obligations, government auditing requirements, resolve disputes, and enforce our agreements (including those agreed with our clients). At the end of such period, we may, at our discretion, destroy such personal data without notice to you.

How to Opt-Out of Further Communication

We provide users the opportunity to opt-out of receiving further communications from us at their request. To opt-out of further communications contact us by email at info@kamalyconsultancy.com .

The website includes social media features, such as the LinkedIn Like button and widgets. These features may collect your IP address, which page you are visiting on the website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the website. Your interactions with these features are governed by the privacy policy of the company providing it.

How to Contact Us

For privacy-related inquiries, please contact our Data Protection Officer at:
Email: info@kamalyconsultancy.com

Links to Other Websites

Our website may contain links to other sites. Kamaly Consultancy is not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy policies of these websites before transmitting any personal identifiable information to third parties. Information collected by the third party is not governed by this Privacy Policy. Any link to a website owned by a third party does not constitute an endorsement, approval, association, sponsorship or affiliation with the linked site unless specifically stated.

The website may include social media features, such as the LinkedIn Like button and widgets, such as the “Share this” button or interactive mini-programs that run on the website. These features may collect your IP address, which page you are visiting on the website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the website. Your interactions with these features are governed by the privacy policy of the company providing it.

Personal Information from Children

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

Disclaimer

While every effort is made to provide accurate information, travel visa and passport requirements are constantly changing and there may be a delay before we are advised of such changes. Therefore, we are unable to guarantee accuracy. Processing times and charges given are solely for guidance purposes and cannot be guaranteed. Where ‘no’ travel visa is indicated, we recommend this information be confirmed by the carrier and the relevant embassy or consulate. Kamaly Consultancy recommend that travel visas be obtained before travel. Where information for travel visas upon arrival are given, we always recommend confirmation of this information with the airline and embassy or high commission prior to travel. Travel arrangements should not be confirmed prior to the visa or passport being issued unless they are a specifically required for that consulate. In such cases, refundable arrangements should be made.