Limmi Global Inc., carrying on business as Limmi Global/EuroPassport (“Limmi Global/EuroPassport,” “we,” “us,” or “our”) is committed to protecting your privacy and personal information. This Privacy Notice explains how we collect, use, disclose, and safeguard your personal information when you use our services to obtain European Union member countries, Switzerland or United Kingdom citizenship through ancestry, and when you visit our website at https://limmiglobal.com and https://europassport.ca.

Important Notice About Our Role: Limmi Global/EuroPassport acts as your agent and intermediary in the citizenship, visa and residence permit application process. While we facilitate your application, the European lawyers, advocates, and other professionals we work with have primary legal obligations under their respective jurisdictions’ laws for protecting your personal data during the citizenship application process.

This Privacy Notice applies to:

• Citizenship, Visa and Residence Permit Services: Information collected and processed for EU/UK/Switzerland citizenship, visa and residence permits applications
• Website Visitors: Information collected when you visit our website
• Prospective Clients: Information collected during eligibility assessments and consultations

DATA RETENTION

Personal Information for Citizenship, Visa and Residence Permit Services When you engage our services, we collect and process the following categories of personal information:

Identity and Contact Information:

• Full name, date and place of birth
• Current and previous addresses
• Phone numbers and email addresses
• Government-issued identification documents (passports, driver’s licenses, etc.)

Genealogical and Family Information:

• Ancestral birth, death, marriage and divorce certificates
• Family tree documentation
• Historical immigration and citizenship records
• Military service records of ancestors
• Religious and civil records

Financial Information:

• Payment and banking card details for service fees through an approved payment processor.
• Invoice and payment history

Supporting Documentation:

• Translated documents and certified copies
• Apostilled and legalized documents
• Court records and legal documentation
• Educational certificates and employment records

Website Information

When you visit our website, we automatically collect:

Technical Information:

• IP address and location data
• Browser type and version
• Device information and operating system
• Pages visited and time spent on site
• Referring websites and search terms

Cookies and Tracking Technologies:

We use cookies and similar technologies to enhance your website experience. See our “Cookies and Tracking” section below for details.

The primary legal basis for processing your personal information is contract performance.

When you engage our citizenship services, we process your personal information to fulfill our contractual obligations under our Client Services Agreement.

Additional Legal Bases:

• Legal Obligations: To comply with Canadian and European legal requirements
• Legitimate Interests: For business operations, security, and service improvement
• Consent: For marketing communications and certain website features (where required)

Legal Basis by Activity Type

Contract Performance:

• All citizenship application processing activities
• Document preparation and verification
• Communication with European professionals
• Government application submissions
• Payment processing for contracted services

Legal Obligations:

• Record retention requirements
• Regulatory reporting
• Compliance with court orders and legal processes
• Anti-money laundering and identity verification

Legitimate Interests:

• Website analytics and improvement
• Fraud prevention and security measures
• Business development and operational efficiency
• Customer service and support

Consent:

• Marketing communications and newsletters
• Non-essential website cookies and tracking
• 3Optional service enhancements

We use your personal information for the following purposes:

Citizenship Application Processing (Contract Performance)

• Application Preparation: Compile and organize documentation for citizenship applications
• Document Verification: Authenticate and verify ancestral and supporting documents
• Legal Representation: Facilitate representation by European lawyers and advocates
• Government Submission: Submit applications to relevant European government authorities
• Application Tracking: Monitor application status and communicate updates
• Compliance: Meet legal requirements in Canada and European jurisdictions

Business Operations (Legitimate Interests & Legal Obligations)

• Customer Service: Respond to inquiries and provide support
• Payment Processing: Process fees and financial records
• Service Improvement: Analyze and improve our services
• Legal Compliance: Meet regulatory and legal obligations
• Marketing: Communicate about our services (with your consent where required)

Website Operations (Legitimate Interests)

• Functionality: Ensure website operates properly
• Analytics: Understand website usage and improve user experience
• Security: Protect against fraud and security threats

We do not sell personal information.

Limmi Global/EuroPassport as Your Agent

Limmi Global/EuroPassport acts as your agent in facilitating citizenship applications. In this capacity:

• We collect and organize your personal information on your behalf under our contractual agreement
• We engage European professionals to represent you in citizenship, visa and residence permit matters
• We coordinate the application process across multiple jurisdictions
• You main ownership and control over your personal information subject to contractual and legal obligations

Sharing with European Professionals

We share your personal information with our network of qualified professionals, including:

Lawyers and Legal Advocates:

• Licensed attorneys in European countries who handle citizenship applications
• Legal professionals bound by their jurisdictions’ professional obligations and data protection laws
• Advocates who become your legal representatives for citizenship matters.

Specialized Service Providers:

• Genealogists and family history researchers
• Document authentication and translation services
• Archival research specialists
• Notaries and certification services

Government Authorities

Your information is ultimately submitted to European government authorities as part of the citizenship application process. These authorities become the final controllers of your personal data for citizenship determination purposes.

We may disclose your information in the following circumstances:

Legal Requirements:

• To comply with court orders, subpoenas, or legal processes
• To meet regulatory requirements in Canada or European jurisdictions
• To respond to lawful requests from government authorities

Business Protection:

• To protect our legal rights and contractual interests
• To investigate fraud or security incidents
• To enforce our terms of service and contractual agreements

Business Transfers:

• In connection with mergers, acquisitions, or business asset sales
• To successors who agree to honor this Privacy Notice and existing contractual obligations

Marketing Communications:

• To send you information about our services where you have provided consent
• You may withdraw consent for marketing at any time without affecting our contractual services

Your personal information will be transferred to and processed in European countries where we have partnered professionals. These transfers are necessary to fulfill our contractual obligations for citizenship services and may involve countries with different data protection standards than the jurisdiction in which you reside.

Safeguards for International Transfers:

• Contractual obligations requiring adequate protection standards from European partners
• Selection of professionals in countries with robust data protection laws
• Implementation of appropriate technical and organizational security measures
• Regular monitoring of data protection compliance of our partners

Your Rights Regarding International Transfers:

Objecting to international transfers of your personal information will prevent us from fulfilling our contractual obligations to provide citizenship services, as these transfers are essential to the application process. Any such objection would need to be addressed in accordance with the terms of our Client Services Agreement.

We retain your personal information in accordance with our contractual obligations, Canadian legal requirements, and the professional and legal obligations of our European partners:

Active Citizenship, VISA and Residence Permits Applications:

• During the entire application process (typically 12-24 months, but potentially longer depending on the country to which the application is made)
• Until citizenship is granted or application is finalized

Completed and Unsuccessful Applications:

• Retention periods vary by European jurisdiction and professional obligations
• Governed by the legal and professional requirements of the European lawyers and advocates handling your application
• Limmi Global/EuroPassport retains records for 7 years after application completion for Canadian legal compliance
• Some information may be retained longer if required by European authorities, professional rules, or legal obligations.

Contractual Records:

• 7 years after contract completion for Canadian business law compliance
• Longer if required for legal proceedings or regulatory requirements

Website Information:

• Analytics data: 24 months
• Cookie data: As set in cookie preferences
• Marketing data: Until consent is withdrawn or 3 years of inactivity

Important Note: Even if you withdraw from the citizenship application process, certain information may still be retained according to the legal obligations of Limmi Global/EuroPassport and the European professionals involved in your application.

Depending on your location and applicable laws, you may have the following rights:

Access and Correction

• Right to Access: Request copies of personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete information
• Right to Completion: Request completion of incomplete personal information

Data Control

• Right to Deletion: Request deletion of your personal information (subject to contractual and legal obligations)
• Right to Restriction: Request limitation of processing in certain circumstances
• Right to Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing based on legitimate interests

Contract Management

• Right to Withdraw: Withdraw from the citizenship, visa and residence permit application process (subject to contractual terms and legal obligations)
• Right to Modify: Request changes to the scope of services under contract 7Marketing Communications
• Right to Opt-Out: Withdraw consent for marketing communications at any time

Complaints

• Right to Complain: File complaints with relevant privacy authorities.

Exercising Your Rights: To exercise these rights, contact us using the information in the “Contact Us” section. For rights related to data held by European professionals, we will coordinate your request with the appropriate European lawyer or advocate responsible for that aspect of your application.

Response Timeline: We will respond within 30 days and may request additional information to verify your identity.

Important Limitations:

• Rights may be limited by contractual obligations necessary for citizenship application processing
• European professionals may have their own obligations under professional and data protection rules
• Some processing may be required by legal obligations in Canada or European jurisdictions
• Withdrawal from the application process may not result in immediate deletion of all information due to legal retention requirements

Our website uses cookies and similar technologies to enhance your experience:

Types of Cookies We Use

Essential Cookies:

• Required for website functionality
• Enable secure areas and account access
• Cannot be disabled without affecting site functionality

Analytics Cookies:

• Help us understand how visitors use our website
• Collect anonymous information about page visits and user behavior
• Used to improve website performance and user experience

Marketing Cookies:

• Track your preferences and interests
• Deliver relevant advertisements
• Measure advertising effectiveness

Third-Party Cookies:

• Google Analytics for website analytics
• Social media plugins and widgets
• Payment processor cookies for transaction security

Managing Cookies

You can manage cookies through your browser settings:

• Accept All: Allow all cookies for full website functionality
• Customize: Choose which types of cookies to accept
• Reject All: Block all non-essential cookies (may limit website functionality)

Most browsers allow you to:

• View cookies stored on your device
• Delete existing cookies
• Block future cookies
• Set cookie preferences

Note: Disabling certain cookies may affect website functionality and your user experience.

Essential cookies required for core website operation cannot be disabled.

By signing this Agreement, the Client explicitly consents to receive text messages (SMS) from EuroPassport regarding customer support, updates, and account notifications. Message and data rates may apply. Message frequency may vary. The Client may opt-out at any time by replying “STOP”. Furthermore, mobile information and SMS consent data will not be shared with third parties or affiliates for marketing or promotional purposes under any circumstances. 

Given the highly sensitive nature of the genealogical, identity, and citizenship information you provide, you play a crucial role in protecting your personal information. We require our clients to maintain appropriate security practices when accessing our services and handling their own data.

Required Security Practices

Multi-Factor Authentication:

• Enable multi-factor authentication (MFA) on all accounts used for our services
• Use authentication apps, SMS codes, or hardware tokens as provided
• Never share your authentication codes or devices with others

Password Security:

• Create strong, unique passwords for your Limmi Global/EuroPassport account
• Do not reuse passwords from other websites or services
• Use a reputable password manager to generate and store complex passwords
• Change passwords immediately if you suspect they may have been compromised

Secure File Transmission:

• Use only the secure file upload and communication methods provided by Limmi Global/EuroPassport
• Do not send sensitive documents via regular email, text messages, or unsecured file-sharing services
• Verify file upload completion and receipt confirmation before considering transmission complete

Device Security:

• Maintain current antivirus and anti-malware protection on all devices used to access our services
• Keep operating systems and software up to date with the latest security patches
• Use device lock screens with strong PINs, passwords, or biometric authentication
• Log out of accounts when finished and lock your device when unattended

Recommended Security Practices

Network Security:

• Avoid using public Wi-Fi networks for accessing sensitive information or uploading documents
• Use secure, password-protected home or office networks when possible
• Consider using a reputable VPN service when accessing our services from public locations

Document Management:

• Store physical documents containing personal information in secure, locked locations
• Make secure backup copies of important documents before submitting originals
• Properly dispose of document copies by shredding or secure destruction
• Limit access to your personal documents to only those who need them

Account Monitoring:

• Regularly review your account activity and uploaded documents
• Report suspicious activity, unauthorized access, or unusual communications immediately
• Monitor your email for account notifications and verify their authenticity
• Keep your contact information current so we can reach you about security matters

Phishing and Fraud Prevention:

• Be cautious of emails, calls, or messages claiming to be from Limmi Global/EuroPassport requesting sensitive information
• Verify the authenticity of communications by contacting us directly through official channels
• Never provide login credentials, passwords, or sensitive information in response to unsolicited requests
• Report suspected phishing attempts or fraudulent communications to us immediately

Software and Browser Security:

• Use updated web browsers with current security features enabled
• Avoid installing suspicious software or browser extensions
• Regularly clear browser cache and cookies from shared or public computers
• Use reputable security software and keep it updated

Data Breach Prevention

Immediate Actions Required:

• Report suspected security incidents or data breaches to us within 24 hours
• Change passwords immediately if you suspect unauthorized access
• Preserve evidence of security incidents (screenshots, emails, etc.) for investigation
• Follow our guidance for containment and remediation measures

Personal Device Management:

• Use screen locks and automatic logout features
• Avoid saving login credentials in browsers on shared devices
• Regularly audit who has access to your devices and accounts
• Remove access for former employees, family members, or others who no longer need it

Consequences of Non-Compliance

Service Limitations: Failure to maintain adequate security practices may result in:

• Suspension of access to secure services and document uploads
• Requirement for additional identity verification
• Delays in application processing
• Termination of services if significant security risks are identified

Shared Responsibility: While we implement robust security measures, the security of your information also depends on your adherence to these practices. You acknowledge that failure to follow these security requirements may compromise the protection of your personal information.

Incident Reporting: You agree to promptly report any suspected security incidents, unauthorized access, or potential data breaches related to your information or account. Early reporting helps us minimize potential impacts and protect all clients.

Security Training and Updates

Ongoing Education:

• We may provide security awareness training and updates
• Stay informed about current cybersecurity threats and best practices
• Participate in any required security training related to your application process

Policy Updates:

• We will notify you of important changes to security requirements
• New security measures may be implemented as technology and threats evolve
• Continued use of our services constitutes agreement to updated security requirements

We implement comprehensive security measures to protect your personal information, working in partnership with your security practices:

Technical Safeguards

• Encryption: Data encrypted in transit and at rest using industry-standard protocols
• Access Controls: Multi-factor authentication and role-based access restrictions
• Network Security: Firewalls, intrusion detection, and secure networks
• Regular Updates: Security patches and system updates

Organizational Safeguards

• Staff Training: Regular privacy and security training for all employees
• Background Checks: Screening of personnel with access to personal information
• Confidentiality Agreements: Contractual obligations for staff and contractors
• Incident Response: Procedures for detecting and responding to security breaches

Physical Safeguards

• Secure Facilities: Physical access controls to offices and systems
• Document Security: Secure storage and disposal of physical documents
• Equipment Protection: Secure handling of computers and storage devices

Third-Party Security

• Vendor Assessment: Security evaluation of all service providers
• Contractual Requirements: Data protection obligations for all third parties
• Regular Audits: Monitoring of third-party compliance

In the event of a privacy breach involving your personal information, the response will depend on which party has primary responsibility for the affected data:

When Limmi Global/EuroPassport Has Primary Responsibility:

• Immediate containment and investigation of the breach
• Assessment of risks to affected individuals
• Implementation of remedial measures
• Documentation of the incident and response actions
• Notification to relevant privacy authorities within 72 hours (where required by Canadian law)
• Direct notification to affected individuals if high risk to privacy rights

When European Professionals Have Primary Responsibility:

• Coordination with the responsible European lawyer or advocate
• Support for their breach response obligations under applicable European laws
• Communication with affected clients as appropriate
• Assistance with remedial measures within our control

Notification Timeline:

• Notification to relevant authorities according to the requirements of the jurisdiction where the principally responsible party operates
• Direct notification to affected individuals as required by applicable law
• Public notification if breach affects a large number of individuals

Your Response: If you suspect a privacy breach or unauthorized use of your information, contact us immediately using the information in the “Contact Us” section. We will coordinate the appropriate response based on where the breach occurred and who has primary responsibility for the affected data.

CHILDREN’S PRIVACY

We may update this Privacy Notice periodically to reflect changes in our practices, services, or legal requirements.

How We Notify You:

• Email Notice: For material changes affecting your rights
• Website Notice: Prominent notice on our homepage
• Direct Communication: Personal notification for significant changes

Effective Date: Changes take effect on the date specified in the updated notice.

Your Continued Use: Continued use of our services after notice of changes constitutes acceptance of the updated Privacy Notice.

Our services are not directed to individuals under 18 years of age. If you are a parent or guardian we rely on your authorization for the processing of personal data for minors. This will happen only in the context of processing a citizenship application for a minor at your direction, with appropriate authorization provided by you in the Service Agreement, and any powers of attorney signed by you and required by legal authorities or legal agents in the relevant countries, pursuant to the laws of that country.

For questions, concerns, or to exercise your privacy rights, please contact us:

Limmi Global/EuroPassport Inc. Head Office:

2 St. Clairr Ave. W., 18th floor, Toronto, Ontario M4V 1L5 Canada

Limmi Global/EuroPassport Labs:

Legal Innovation Zone Toronto Metropolitan University 10

Dundas St. East (10th Floor), Suite 1002 Toronto, Ontario M5B 2G9

• Phone: +1 (647) 725-2552
• Toll-Free: 1 (877) 633-7967
• Email: [email protected]
• Privacy Officer: For privacy-specific inquiries, you may contact our Privacy Officer directly at [email protected].
• Response Time: We will acknowledge receipt of your inquiry within 5 business days and provide a substantive response within 30 days.
• Regulatory Contacts: If you are not satisfied with our response to your privacy concerns, you may contact:
• Canada: Office of the Privacy Commissioner of Canada (www.priv.gc.ca)
• European Union: Your local data protection authority (https://digital-strategy.ec.europa.eu/en/library/list-personal-data-protection-competent-authorities)
• United Kingdom: Information Commissioner’s Office (https://ico.org.uk)
• Switzerland: Federal Data Protection and Information Commissioner(https://www.edoeb.admin.ch/en).