Privacy Policy

1. Who we are and how to reach us

Mirantly Technologies Inc. 1892 Starling Drive Tsawwassen, British Columbia V4M 0C7 Canada

We are the organization responsible for the personal information described in this policy.

Our Privacy Officers are Ovo Okpubuluku, Co-founder and Chief Technology Officer, and Simeon Igbabul, Founder and Chief Executive Officer. You can reach them at privacy@mirantly.com.

For security matters, including reporting a vulnerability, write to security@mirantly.com.

2. The information we collect

We collect information in three ways: information you give us, information generated as you use the Services, and limited device and diagnostic data needed to run and secure the Services.

We do not currently collect precise location data.

3. Sensitive information

Some of what you give us is sensitive because it can reveal your identity, immigration status, legal history, finances, or family relationships. This includes government identifiers, passport and permit numbers, dates of birth, travel history, employment and education records, and the contents of documents you upload.

Here is what we commit to:

• We practise data minimization. We collect only what is reasonably needed for the feature you are using, the support issue you have raised, or a legal obligation we have to meet. We do not ask for sensitive information unrelated to a feature you are using.
• We restrict internal access. Access to sensitive information is limited to personnel and contractors who need it for support, security, infrastructure, or a service you have requested, and that access is logged.
• We do not sell your information. We do not sell, rent, or share your documents, private messages, or device data for advertising, and we do not provide them to data brokers.
• We do not let AI vendors train on your information. Our AI processing vendors, Microsoft Azure OpenAI Service and Anthropic, are contractually prohibited from using your information to train their general-purpose models. Your documents and case details are processed only to produce the output you requested.
• We share with professionals only at your direction. If you choose to engage a professional through the Services, we share documents and case details only as you direct or as the workflow you started requires.

4. Device data, permissions, and diagnostics

We automatically collect limited technical data to keep the Services running, secure accounts, detect abuse, and troubleshoot problems. This includes IP address, device and browser identifiers, operating system, app version, language, time zone, error logs, and analytics events describing how the product is used.

We request access to device features such as camera, photo library, file storage, and notifications only where the permission supports a feature you are using. Camera and photo access let you capture and upload a document. Push notifications deliver reminders and updates you have opted into. You can change or withdraw any of these permissions in your device settings at any time, though some features will stop working if you do.

We do not use your documents, immigration details, or device permission data for cross-context behavioural advertising.

5. How we use personal information

We use personal information to:

• create and authenticate your account and maintain your profile;
• generate eligibility results, pathway matches, score estimates, document checklists, and scenario simulations;
• organize and process the documents you upload;
• deliver your MoveJourney plan, tasks, and milestones;
• enable connections with professionals where you have asked for one;
• process subscriptions and payments;
• provide customer support and respond to your questions;
• send you service messages, reminders, and, where you have not opted out, product and marketing communications;
• detect, investigate, and prevent fraud, abuse, and security incidents;
• monitor and improve the quality, accuracy, and reliability of the Services;
• enforce our Terms of Service; and
• comply with our legal and regulatory obligations.

We also use aggregated or de-identified information for analytics and product improvement. We do not attempt to re-identify individuals from that information.

6. Our basis for processing, and your consent

Under Canadian privacy law we rely primarily on your consent, which you give when you create an account, submit information, or enable a feature. In some cases we process information without consent where the law permits or requires it, such as to investigate a breach of an agreement, to detect fraud, to comply with a legal order, or to protect someone's safety.

You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawing consent may mean we can no longer provide some or all of the Services. To withdraw consent, write to privacy@mirantly.com.

7. AI-assisted features and automated decisions

Some features use artificial intelligence to summarize rules, organize your next steps, flag missing documents, estimate scores, and generate scenario guidance.

These outputs are informational. They are not legal advice, they do not guarantee any outcome, and they do not replace decisions made by governments or licensed professionals. AI systems can make mistakes and miss context.

Some results are produced without human review. Your eligibility results, pathway matches, and score estimates are generated automatically from the information you provide, using rules published by immigration authorities. These results do not by themselves decide anything about your immigration status; only a government authority does that.

You have the right to be informed about how an automated result was reached, to submit information you think we have missed, and to ask that a person review it. Write to privacy@mirantly.com and tell us which result you are asking about.

We may use human review to check quality, investigate abuse, or resolve a support issue. Where a person reviews your information, that access is limited and logged.

8. When we share personal information

We share personal information only in these situations:

• With service providers who help us operate the Services, listed in Section 9. They may use your information only to perform services for us, under contract.
• With professionals and marketplace partners, where you ask us to make a connection or share information as part of a workflow you started.
• With the app stores and payment processors needed to complete your purchase.
• In a corporate transaction, such as a merger, financing, reorganization, or sale of assets, subject to appropriate notice and protections.
• With regulators, courts, or law enforcement, where disclosure is required by law or legal process, or where we have reasonable grounds to believe it is necessary to protect someone's safety or the integrity of the Services.
• With your consent, or at your direction.

We do not sell personal information.

9. Our service providers

Apple and Google process purchases made as in-app purchases under their own privacy policies.

We update this list as our providers change. Material changes are reflected in the effective date above.

10. Where your information is stored

Your account data and uploaded documents are stored in Canada, in Amazon Web Services data centres in the Canada region.

Some of our service providers process information outside Canada, as shown in Section 9. When information is processed in another country, it is subject to the laws of that country, and courts, law enforcement, and regulators there may be able to access it under those laws.

Where we transfer personal information outside Canada, we use contractual protections requiring the provider to give it a level of protection comparable to what it receives here, and we assess the transfer before it begins where the law requires us to.

You can ask us where your information is stored by writing to privacy@mirantly.com.

11. How long we keep your information

We keep information longer only where we are required to by law, or where it is needed to resolve a live dispute or enforce our agreements.

12. Security

We use administrative, technical, and organizational safeguards to protect personal information from unauthorized access, loss, misuse, alteration, and disclosure. These include:

• encryption of data in transit and encryption of stored documents at rest;
• role-based access controls, with access to sensitive information limited to those who need it;
• authentication protections on user accounts and on internal systems;
• logging and monitoring of access to sensitive data;
• security review of our service providers before we engage them; and
• an incident response process for suspected breaches.

No system is completely secure. If we become aware of a breach that creates a real risk of significant harm to you, we will notify you and the appropriate regulators as required by law, and we will tell you what happened and what you can do about it.

To report a security concern, write to security@mirantly.com.

13. Your rights and choices

Depending on where you live, you have the right to:

• Access the personal information we hold about you, and be told how it has been used and to whom it has been disclosed;
• Correct information that is inaccurate or incomplete;
• Delete your information, subject to the retention periods in Section 11 and any legal obligation we have to keep it;
• Withdraw consent to processing, as described in Section 6;
• Receive a copy of the information you gave us, in a structured, commonly used technological format, and ask us to transfer it to another organization where that is technically feasible;
• Ask about an automated result and request human review, as described in Section 7;
• Ask us to stop disseminating information about you, or to de-index it, where the law provides that right; and
• Opt out of marketing at any time.

Ways to exercise these rights:

Update your profile, preferences, and notification settings from your account.

Unsubscribe from marketing email using the link in any such message. We will still send service and account messages where necessary.

Manage device permissions in your operating system settings.

For anything else, write to privacy@mirantly.com.

We respond to rights requests within 30 days. We may need to verify your identity first, and we will tell you if we need more time or if an exception applies.

There is no cost to make a request. If a request is manifestly unfounded or excessive, we will tell you before doing any work and explain why.

14. Cookies and similar technologies

We use cookies, pixels, local storage, and software development kits on our website and in our applications. Our Cookie Policy explains which ones we use and how to control them.

15. Children

The Services are for adults. You must be at least 18 to hold an account, as set out in our Terms of Service. Where a person under 18 is the subject of an immigration journey, a parent or legal guardian holds and manages the account.

We do not knowingly collect personal information directly from children. If we learn that we have collected personal information from a child in a way that is not permitted, we will delete it and take steps to prevent it happening again. If you believe a child has given us information, write to privacy@mirantly.com.

16. Changes to this policy

We may update this Privacy Policy to reflect changes in the Services, our providers, the law, or our practices. When we make a material change, we will update the effective date above and give notice through the Services, by email, or both.

17. Contact us, and how to complain

For privacy questions, rights requests, or complaints, write to privacy@mirantly.com, or to our Privacy Officers at the address in Section 1.

We take complaints seriously and will respond in writing. If you are not satisfied with our response, you may complain to:

• Office of the Privacy Commissioner of Canada — priv.gc.ca
• Commission d'accès à l'information du Québec, if you live in Quebec — cai.gouv.qc.ca

You may also be able to complain to the privacy regulator in your own province or territory.