Privacy Policy

Last Updated: January 1 2021

Introduction

Purpose of Policy

International Creative Capital, LLC (“us”, “we”, “ICC”, “our”, or “Company”) is committed to respecting the privacy rights of its clients, visitors, and other users (“you”, “your”, “user(s)”, or “Client(s)”). We want you to be familiar with how we collect, use and disclose data.
This Privacy Policy describes the privacy practices of ICC for data that we collect:

  • through websites operated by us from which you may be accessing this Privacy Policy, including https://internationalcreativecapital.com and any other websites owned or controlled by International Creative Capital (collectively, the “Site”);
  • through our social media pages that we control from which you may be accessing this Privacy Policy (collectively, our “Social Media”);
  • through newsletters or other HTML-formatted email messages that we send you that link to this Privacy Policy and through your communications with us; and,
  • when you exchange information with us through secure cloud-based document services such as DropBox or Sharefile; and
  • when you visit our facilities, speak with one of our case managers via telephone, chat applications, email, or through any other offline interactions.

Collectively, we refer to the Site and our Social Media as the “Online Services” and, together with the other channels described above, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Policy.

Services Not for Use by Minors

We do not knowingly collect information from minors (individuals below 18 years). To use the Services, including this Site, you must be the age of legal majority in your place of residence. By using the Services, you hereby represent that you are at least the age of legal majority in your place of residence. We do not use an application or other mechanism to determine the age of users of the Services. All information provided to ICC will be treated as if an adult provided it. If, however, we learn that a minor has submitted information about himself/herself to us, we delete the information as soon as possible.

Information Collection Practices

Our goal in collecting visitor information online or in-person is to provide the best experience possible by delivering relevant information that meets user needs and/or to allow us to provide the Services.

Personal Information Collected

In order to provide the Services, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information means any information relating to an identified or identifiable natural person. We may collect the following:

  • Name
  • Address
  • Phone number
  • Email
  • Information related to your immigration pursuit
    • Date of birth, Social Security Number, passport copies
    • Green card copies, approval dates, USCIS receipt notices
    • Banking, payment, and investment information necessary for us to perform any services for you
    • Information on your family, profession, educational background, and other personal information

We may receive and store any information you enter on the Site, Social Media, or give us in any other way, including in-person or telephonically. You can choose not to provide certain information, but, by choosing to not provide such information, you might not be able to take advantage of certain features on the Site or any services we may otherwise provide to you. We do not sell, rent, share, or otherwise disclose personally identifiable information from clients for commercial purposes in violation of the commitments set forth in this Privacy Statement.

Geographical Information

Company may access your geographic location data at the time that you visit the Site. We may also track and analyze aggregate usage and volume statistical information from you and provide such information to third parties in order to improve services we offer you, to improve analytics, or site functionality.

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.

Tracking Technologies

We and our partners, e.g. marketing partners, affiliates, or analytics or service providers, e.g. online client support provider, etc. use cookies and/or similar technologies to analyze trends, administer the site, track users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Use of Cookies
We use various types of session and persistent cookies to help you access and navigate the Site more efficiently, customize your experience of the Site, and statistically monitor how many visitors are using the Site. You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. The use of cookies by our partners is not covered by our privacy policy. We do not have access or control over these cookies. Our partners use session ID cookies to provide us with information about how you use the Services.

Social Media Features

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

Embedded content from other websites

The Site may include embedded content (e.g., forms, videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Use And Sharing Of Information

Personal Information

Any Personal Information you enter on the Site, Social Media, or give us in any other way, including in-person or telephonically, is used to send you information about our Company or our products or services, or promotional material from some of our partners, or to contact you when necessary. We may use your Personal Information to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Site or in regards to the Services. We may also use your Personal Information to send follow-up information regarding ICC’s services, contact you regarding other services ICC offers, inform you of the availability of a newsletter or information available on our Site, any changes to the Services, or to send you additional information about the EB-5 Visa Program.
We share certain categories of information we collect from you in the ways described in this Privacy Policy. We may provide your Personal Information to companies or individuals that provide services to help us with our business activities such as sales, marketing, and client service. We also share Personal Information with our business partners who assist us by performing core services which include but are not limited to, hosting, data storage, and security. ICC shares this information only with affiliated companies or providers in order to help us better serve you. These affiliates are required to maintain your information in confidence and use shared information to carry out their specific business obligations to ICC.
We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information, including supporting your contractual relationship with us. For example, if you share your name and contact information to ask a question, we will use that personal information to respond to your inquiry.
  • To provide, support, personalize, and develop our Websites, products, and services.
  • To create, support, maintain, and secure your investment with us for your immigration pursuit.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud. For example, if you subscribe to a ICC Thresher Fund limited partnership, we will share your address with the shipping company if we send out documentation related to your subscription.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your experience on the Site and Social Media.
  • To help maintain the safety, security, and integrity of the Site, products and services, databases and other technology assets, and business. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
  • For testing, research, analysis, and product development, including developing and improving our Site, products, and Services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Websites is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
As we continue to develop International Creative Capital, we might sell, buy, or create new businesses. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy notice. Also, in the unlikely event that International Creative Capital is acquired, customer information will of course be one of the transferred assets.
We do not sell, rent, share, or otherwise disclose personally identifiable information from clients for commercial purposes in violation of the commitments set forth in this Privacy Notice.

Communication From The Site

We communicate with our clients using information provided to us in various ways, which include but are not limited to:

Service-related Communications
We will send you strictly service-related communications when it is necessary to do so. We send you emails confirming your use of the Services. On rare occasions, if our Site is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature.
Client Service
Based upon the Personal Information you provide us, we will communicate with you in response to your support inquiries to provide some of the Services you request. We will generally communicate with you by email, unless you request to communicate by telephone or other means by providing us with the information necessary to be able to communicate with you, such as a phone number.
Newsletters
If you wish to subscribe to our newsletters, we will use your name and email address to send the newsletter to you. Your name and email address will not be sold or shared with outside companies. Out of respect for your privacy, we provide you a way to unsubscribe in each newsletter. Please see the ‘unsubscribe’ feature at the bottom of each newsletter.
Surveys or Contests
From time-to-time, we may provide you the opportunity to participate in contests or surveys on our Site. If you participate, we will request certain Personal Information from you. Participation in these surveys or contests is completely voluntary. Therefore, you have a choice whether or not to disclose this information. The requested information typically includes contact information and demographic information (such as zip code). We use this information to notify contest winners and to monitor site traffic or personalize the Site. Out of respect for your privacy, we provide you a way to unsubscribe from such communications. Please see the ‘unsubscribe’ feature at the bottom of each newsletter.
Testimonials
We post testimonials from time to time. We always receive permission to post prior to posting. If you wish to update or delete your testimonial, you can contact us, here.

Links to Third Party Sites

When using links found on our Site or Social Media to other websites not affiliated with International Creative Capital, LLC, please be aware those websites have their own privacy policies, which may be different from our own. Also, International Creative Capital is not responsible for services or products that are offered on these websites.

Legal Disclosure

In certain situations, ICC may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your Personal Information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, to any other third party with your prior consent to do so. If ICC is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Data Retention

We will retain your information for as long as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Supplementation of Information

In order to provide or enhance our services to you, we may, on occasion, supplement the Personal Information you submitted to us with information from third-party sources. To enrich our profiles of individual clients, we tie this information to the Personal Information you have provided to us.

Confidentiality and Security

Security

Keeping your information secure is important to us, which is why we use a secure server and Secure Socket Layer (SSL) technology.
When using secure pages of our Sites, your computer will automatically begin to communicate with our server in secure mode. SSL technology encrypts your personal information on these secure pages, to protect it from being read by others during online transmittal. When applicable, we highly recommend that you create a secure password with at least 8 characters, mixed with upper and lower case letters, numbers, and special characters. And that you change your password at least every 6 months.

Confidentiality and Security of Personal Information

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is required by law or in the good-faith belief that such disclosure is necessary: (a) conform to the edicts of the law or comply with legal process served on ICC or its parent company, subsidiaries or affiliates, (b) protect and defend the rights or property of ICC or users of the Services, (c) act under exigent circumstances to protect the safety of the public or Clients. ICC does not sell your personal information.

Contact Information and Policy Updates

Updates and Changes

We may update, amend, modify, or supplement this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email or by means of a notice on this Site. We encourage you to periodically review the most recent version of our Privacy Policy at https://internationalcreativecapital.com/privacy-policy/. Your continued use of the Site constitutes your agreement to the changes to the Privacy Policy.

Contacting Us

If you have any questions or concerns regarding this Privacy Policy, please feel free to contact us, here, or at the address below:
International Creative Capital
2885 Electronics Drive
B11
Melbourne Florida, 32935

Residents of California or the European Union

Notice to the EU General Data Protection Regulation (GDPR) and California Residents

If you are a resident of the State of California or the European Union, you have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Emailing us at: info@internationalcreativecapital.com
Calling us at: 01 (888) 928-1788
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:

  • Copy and/or scan of applicable photo identification;
  • Confirmation of address, phone number, and birthdate;

Additionally, the verifiable consumer request must describe your request with sufficient detail that allows us to understand, evaluate, and respond to it properly. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.