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Privacy Policy for National Niner LLC
Effective Date: April 10, 2025
Last Updated: April 10, 2025
1. Introduction
National Niner LLC (“National Niner,” “we,” “us,” or “our”) is an Arizona-licensed Alternative Business Structure (ABS) specializing in providing U.S. visa assistance, representation services for petitions made to U.S. Citizenship and Immigration Services (USCIS), and assistance with U.S. company formation for both foreign and domestic individuals and entities. We are committed to protecting the privacy and security of the personal information entrusted to us.
This Privacy Policy describes how we collect, use, share, and protect personal information obtained through our website https://nationalniner.com, our marketing activities (including advertisements on Meta platforms like Facebook and Instagram, and Google Ads), our online forms, and in the course of providing our professional services.
By accessing our website, interacting with our advertisements or forms, or engaging our services, you acknowledge and agree to the terms of this Privacy Policy.
2. Information We Collect
We collect different types of personal information depending on your interaction with us:
Information from Prospective and Business Clients:
When you inquire about or engage our services for your business or personal needs (like company formation), we collect information such as: Business name (if applicable), contact person(s) name, email address, phone number, and details related to the services you require.
Information for Visa Petitions and Representation (End-Client/Petitioner Information – Highly Sensitive):
To provide visa assistance and prepare petitions for submission to USCIS, we collect extensive personal information directly from the petitioners, beneficiaries, and their family members as required for the specific petition type. This may include, but is not limited to:
Full names, aliases
Contact information (address, email, phone)
Dates and places of birth
Current and past immigration status details
Specific case details relevant to the petition
Government-issued identification numbers (e.g., Passport numbers, A-Numbers, Social Security Numbers where legally permissible and required for the form)
Signatures (digital or physical)
Detailed employment history and information
Detailed educational background and qualifications
Marital status and family information
Financial information (if relevant to the petition, e.g., for affidavits of support or investment visas)
For business-related petitions: Detailed information regarding the business formation, structure, finances, employees, ownership, etc.
This information is collected directly from the individuals involved via secure digital channels, including encrypted email and secure document management platforms.
Information Collected Through Our Website and Online Forms:
When you use contact forms, lead generation forms (potentially linked from ads), or similar features on our website, we may collect: Name, email address, phone number, profession, and basic career data (similar to information typically found on a CV).
Information Collected Automatically (Website Usage and Advertising):
Log Data: When you visit our website, our servers automatically record information (“Log Data”), including your IP address, browser type, pages visited, time/date of visit, time spent on pages, etc.
Cookies and Tracking Technologies: We use cookies, Meta Pixel, Google Ads Conversion Tracking tags, Google Analytics, and similar technologies. These tools help us:
Operate and improve our website.
Analyze website traffic and user behavior.
Track conversions from our advertising campaigns on Meta and Google.
Measure the effectiveness of our ads.
Create audiences for targeted advertising and remarketing (showing our ads to you on Meta or Google platforms after you have visited our site). We may use identifiers derived from information like your email address (in a hashed, non-human-readable format) to create Custom Audiences on these platforms.
3. How We Use Your Information
We use the personal information we collect for the following specific purposes:
Providing Services:
To prepare, review, and file visa petitions and related applications with USCIS on behalf of our clients.
To assist clients with the formation of U.S. companies.
To provide representation and communicate with USCIS regarding client matters.
To manage client relationships, process payments, and fulfill contractual obligations.
Crucially, the highly sensitive End-Client/Petitioner information is used solely for the purpose of providing the requested immigration legal services, including petition preparation and filing.
Communication: To respond to inquiries, provide updates on case status or service requests, send important notices, and deliver customer support.
Marketing and Advertising:
To market our visa assistance and company formation services.
To deliver targeted advertisements on Meta and Google platforms using remarketing lists and Custom Audiences based on website interactions or provided contact information (e.g., hashed emails).
To track the effectiveness of our advertising campaigns (e.g., tracking form submissions originating from an ad).
To send marketing communications (like newsletters via Mailchimp) to those who opt-in.
Website Operation and Improvement: To analyze usage trends, monitor performance, administer the site, improve content and functionality, and enhance user experience using tools like Google Analytics.
Compliance and Legal Obligations: To comply with applicable laws, regulations, Arizona State Bar rules governing ABS, legal processes, governmental requests (including from USCIS or the Department of Labor), and to protect our rights, privacy, safety, or property, and/or that of our clients or others.
Referral Acknowledgement: To share basic contact information (name, email) with the person or company who referred a client to us, solely for acknowledgment or administration of referral arrangements.
4. How We Share Your Information
We understand the sensitivity of the information we handle, particularly immigration-related data. We do not sell your personal information. We share information only in the following limited circumstances:
USCIS and Relevant Government Agencies: We submit the necessary End-Client/Petitioner Information to USCIS and potentially other required government bodies (e.g., Department of State, Department of Labor) as an integral part of filing petitions and providing representation.
Service Providers: We use third-party vendors to perform functions on our behalf. These include:
CRM Systems
Email Marketing Platforms
Cloud Storage
Analytics Tools
Secure Document Platforms
Payment Processors
Advertising Partners: We share information collected via cookies/pixels (like browsing behavior, IP address) and potentially hashed identifiers (derived from emails) with Meta and Google to facilitate our advertising campaigns (conversion tracking, remarketing, Custom Audiences), subject to their respective platform terms and privacy policies.
Referral Sources: As mentioned above, we may share only the client’s name and email address with the referring party for acknowledgment purposes. We do not share sensitive petition details with referral sources.
Legal Requirements: If required by law, subpoena, court order, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, respond to a government request, or comply with regulatory obligations (including Arizona State Bar ABS rules).
Business Transfers: In the event of a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, client information (including sensitive petition data, subject to confidentiality and professional obligations) may be transferred as part of the transaction, under duties of confidentiality.
With Your Explicit Consent: We may share information for other purposes not listed here only if we have obtained your explicit consent beforehand.
Crucially, we treat all End-Client/Petitioner information related to immigration matters with the highest level of confidentiality, consistent with our professional responsibilities, and do not share it except as necessary for the immigration process itself or as legally compelled.
5. Cookies, Tracking Technologies, and Online Advertising
We use cookies and technologies like the Meta Pixel and Google Ads tags for essential website function, performance analysis (via Google Analytics), and advertising purposes. This includes:
Remembering your preferences.
Understanding how you interact with our website.
Measuring the success of our advertising campaigns.
Delivering targeted ads to you on Meta and Google platforms based on your previous visits to our site (remarketing) or based on audience lists we create (Custom Audiences).
You can manage cookie preferences through your browser settings. To learn more about interest-based advertising and opt-out options, visit:
Network Advertising Initiative (NAI): http://optout.networkadvertising.org/
Digital Advertising Alliance (DAA): http://optout.aboutads.info/
Google Ads Settings: https://adssettings.google.com/
Meta Ad Preferences: https://www.facebook.com/ads/preferences/
Opting out of interest-based advertising does not stop all ads, but makes them less relevant to your interests.
6. Data Security
We implement robust administrative, technical, and physical security measures designed to protect the confidentiality, integrity, and availability of the personal information we handle. This includes using encrypted systems, implementing strict access controls, utilizing secure servers, and training our personnel on data privacy and security best practices. Given the sensitivity of the immigration data we process, we take heightened precautions to safeguard it against unauthorized access, use, or disclosure. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
7. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including providing our services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing our agreements, and complying with applicable laws. Specifically for client petition files, we retain this data for up to one (1) year after the petition is made (filed or potentially concluded), unless a longer retention period is required by law, applicable Arizona State Bar rules for ABS record-keeping, or necessary for ongoing legal matters or appeals. Prospect information may be retained for a shorter period consistent with our marketing cycles unless they become clients.
8. Your Privacy Rights
Depending on your location and applicable laws (e.g., GDPR for residents of the EEA/UK, CCPA/CPRA for California residents), you may have rights regarding your personal information, including:
The right to access the personal information we hold about you.
The right to correct inaccurate personal information.
The right to request deletion of your personal information, subject to legal and ethical exceptions (e.g., we cannot delete data required for active cases or mandated record-keeping).
The right to opt-out of marketing communications (you can use the “unsubscribe” link in emails or contact us directly).
The right to object to or restrict certain processing activities.
The right to data portability (receiving your data in a usable format).
The right to opt-out of the “sale” or “sharing” of personal information (as defined under laws like CCPA/CPRA – note that our use of advertising cookies/pixels may fall under “sharing”).
To exercise any applicable rights, please contact Joshua Sardinha using the details in Section 12. We will respond to verifiable requests in accordance with applicable law. We may need to verify your identity before fulfilling your request.
9. Children’s Privacy
Our services are generally not directed to individuals under the age of 18 acting independently, although we necessarily process information about children as beneficiaries or dependents in family-based immigration petitions provided by their parents or legal guardians. We do not knowingly collect personal information directly from children under 16 without parental consent. If we learn we have inadvertently collected such information without necessary consent, we will promptly delete it.
10. International Data Transfers
We operate in the United States, and our servers are located here. As we serve clients from around the globe, personal information (including sensitive petition data) will be transferred to and processed in the United States. When transferring data from regions with specific data protection laws (like the European Economic Area, UK, Switzerland), we rely on appropriate transfer mechanisms, such as the necessity of the transfer for the performance of a contract (our service agreement with you) or for the establishment, exercise, or defense of legal claims (filing petitions with U.S. authorities), or potentially standard contractual clauses where applicable. By engaging our services, you consent to the transfer of your information to the U.S. for the purposes outlined in this policy.
11. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. We will post the revised policy on our website with an updated “Last Updated” date. We encourage you to review this policy regularly.
12. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy, our data practices, or wish to exercise your privacy rights, please contact our designated representative:
Joshua Sardinha, COO
National Niner LLC
20715 N Pima Road, Suite 108 #1056
Scottsdale AZ 85255
Email: [email protected]
Phone: +1 (480) 876-8617