Privacy Policy
1. Who We Are & Who Is Accountable
Migrawise is operated by Venusian Tech Inc. ("we", "us", or "our"), a corporation incorporated under the laws of Canada with its registered office at Office 732, 145 1/2 Church Street, Unit 5, Toronto, Ontario M5B 1Y4, Canada. Migrawise is a trade name of Venusian Tech Inc. and not a separate legal entity.
We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. Where provincial privacy laws provide stronger protections, those laws take precedence.
1.1 Who is accountable for what
Migrawise is a practice-management platform used by professional firms. Two different categories of personal information flow through it, and our role differs for each.
- (a) Firm and practitioner information — we are the accountable organization. For personal information about a firm, its owner and its staff — names, business contact details, professional credentials, account, sign-in and security records, usage and log data, support and contact-form correspondence, public-tool submissions, and billing and payment records — Venusian Tech Inc. determines the purposes of collection and use and is the organization accountable for that information under PIPEDA. This Policy governs that information, and the rights described in Section 6 are exercisable against us.
- (b) Client and case information — the firm is the accountable organization; we act on its instructions. All information a firm enters into or uploads to its workspace concerning its own clients and their matters — applicant identity and travel documents, immigration and civil histories, financial records, questionnaire responses, correspondence, electronically signed documents, generated letters and forms, and case files ("Firm Client Data") — is collected by the firm from its client, for the firm's own professional purposes, under the firm's retainer and under the firm's regulatory obligations. The firm is the organization accountable for Firm Client Data under PIPEDA. We handle Firm Client Data solely as a service provider acting on the firm's behalf and on its documented instructions, on the terms of the Firm Data Addendum in our Terms of Service. We do not determine the purposes for which Firm Client Data is collected or used, do not use it for our own purposes, and do not disclose it except as that Addendum permits or as required by law.
1.2 If you are a client of a firm
If you are an individual whose personal information a firm has entered into Migrawise, or who signs in to a client portal, your privacy relationship is with the firm that represents you, not with us. Your consent to the collection and use of your personal information is given to your immigration representative, under their own professional and privacy obligations, not to us. We hold your information on your representative's behalf and process it only on their instructions.
Please direct questions, access requests, correction requests and complaints about your personal information to that firm. Where we receive such a request directly, we will acknowledge it, tell you which firm holds your information, refer the request to that firm, and act only on that firm's instructions. We make this Policy available to you so you can see how the platform your representative uses handles information.
1.3 If you are a practitioner
If you are a firm owner or a staff member, this Policy governs your relationship with us, and you accepted it when you created your account.
2. Information We Collect
We collect the following categories of information. Categories marked [Firm Client Data] are held on a firm's behalf under Section 1.1(b).
Practitioner and firm information
- Full name, email address, phone number, and mailing address
- Professional credentials (RCIC membership number, Law Society membership details)
- Firm name and business contact information
- Sign-in and account-security records, including sign-in verification and device records where enabled
Case and client data [Firm Client Data]
- Immigration case details, including case type, status, and applicant information
- Documents uploaded to the platform (identification documents, supporting letters, forms)
- Questionnaire responses and intake form submissions
- Communication records between practitioners and clients within the platform
- Electronic signature records and signed documents
- Content generated by the platform's AI features, including drafted letters, filled forms, summaries and audits
Financial information
- Invoicing records and payment history
- Per-case billing records and transaction history (case reference, dollar amount, timestamp)
- Stripe customer identifier and the last four digits of saved cards, where applicable. Full payment card details are handled directly by Stripe and are never stored on our servers
Usage and technical data
- Log data including IP address, browser type, operating system, and access times
- Device information and screen resolution
- Pages visited, features used, and actions taken within the platform
- Document access logs — a record of which staff member opened, downloaded, exported or ran an AI feature over which document, and when
- Error logs and performance metrics
- Email delivery and engagement: for email the platform sends on a firm's behalf, our transactional email provider reports delivery status and whether the message was opened and its links clicked. We store those counts against the message so the firm can see whether its message arrived and was read. Recipients are usually the firm's own clients; the firm is accountable for that processing, and can avoid it by configuring its own SMTP server
Website inquiries and public tools
- Contact form submissions: when you contact us through the website, we collect your name, email address, firm name (if provided), the topic you select, and your message. This is used to respond to your inquiry and is reviewed only by our team
- Calculator results by email: if you ask us to email you a result from one of our free public tools (such as the CRS or FSW calculator), we store your email address, which tool you used, and the headline result, and use them to deliver that email. The individual answers you enter into the calculators are not stored or transmitted with your email
3. How We Use Information
We use the information we collect for the following purposes:
- Service delivery: to provide, maintain, secure and support the Migrawise platform, including case management, document storage, client portal access, and all core features
- Communication: to send service-related notifications, including account updates, security alerts, billing notices, and feature announcements
- AI features: to power AI-assisted case analysis, document review, form filling, questionnaire autofill and letter drafting. Case content — which includes personal information and uploaded documents — is transmitted to our AI infrastructure provider in two situations: when a firm member runs an AI feature on a case, and automatically whenever any document is uploaded to a case — including a document your client uploads through the client portal (see Sections 5 and 12)
- Platform improvement: to understand how the Service is used, identify technical issues, and develop new features. For this purpose we use aggregated statistics and de-identified technical telemetry only. We do not use Firm Client Data to develop, train or improve our products, and our AI provider's commercial terms prohibit using API submissions to train or improve their models
- Security: to detect, prevent and respond to fraud, abuse and security incidents
- Legal obligations: to comply with applicable laws, regulations, legal processes or governmental requests, and to exercise the rights reserved in Section 9 of our Terms of Service (immigration integrity)
We do not sell your personal information. We do not use your data for advertising.
4. How We Store & Protect Information
We employ industry-standard measures to protect the information we hold. These are the measures we implement and maintain; they are not a guarantee of any particular outcome, and no system can be guaranteed to be free of defects or immune from compromise.
- Location: data is stored on servers located within Canada (AWS ca-central-1, Montreal). Application data resides on AWS Lightsail and uploaded files on AWS S3, both within the same Canadian region, as do backups. Two categories of processing cross the border: the AI features, and outbound email delivery. Both are described in Sections 5 and 12
- Encryption in transit: data transmitted between your device and our servers is protected using TLS 1.2 or higher
- Encryption at rest: stored credentials (such as the SMTP, payment-gateway and integration secrets a firm configures) and electronic-signature images are encrypted by the application using AES-256. Uploaded documents, database contents and backups are encrypted at rest by our infrastructure provider's storage-layer encryption
- Tenant isolation: each firm's data is logically isolated at the database level, and our multi-tenant architecture is designed and tested so that no firm can access, view or modify another firm's data
- File storage: uploaded documents are stored outside the web-accessible directory and are reachable only through authenticated API requests with the appropriate authorization
- Access controls: role-based access controls limit users to the data appropriate to their role within the firm. Access by our own personnel is limited to those who need it to operate or support the Service, and is logged
- Backups: encrypted backups of the database and of uploaded files are taken daily to Canadian AWS storage and are retained on a rolling cycle (see Section 7)
5. Service Providers & Sharing
We share data with the following service providers, strictly as necessary to deliver the Service:
- Amazon Web Services (infrastructure — Canada): our servers (AWS Lightsail), file storage and backups (AWS S3) are hosted in the ca-central-1 (Montreal) region. Uploaded documents, database backups and application files remain within Canadian AWS infrastructure. AWS operates under data processing agreements requiring compliance with applicable privacy law.
- Anthropic, PBC (AI processing — United States): AI-powered features (case audits, chat, form filling, portal autofill, questionnaire fill, and letter drafting) are processed by Anthropic. The relevant case content — including client personal information and uploaded documents — is transmitted to Anthropic over encrypted connections for the sole purpose of generating the requested output. Anthropic's commercial API terms prohibit using these submissions to train or improve their models; submissions are retained by Anthropic only for the limited periods their API terms allow (for example, abuse monitoring). Case content reaches Anthropic in two situations: when a firm member runs an AI feature on a case, and whenever any document is uploaded to a case — each uploaded document is automatically summarized so the case's AI assistant can work with it, — including uploads made by your own clients through the client portal, which are summarized in exactly the same way. If no document is uploaded to a case and no AI feature is run on it, no content from that case is sent to Anthropic. Separately, messages sent to the in-product assistant are processed by Anthropic in the same way. AI use is included in the flat per-case fee, so it is not metered or billed per action.
- Stripe (payments): when payments are made or received through the platform — per-case fees, invoice settlements and refunds — payment information is processed directly by Stripe, which is PCI-DSS Level 1 certified. We share only the minimum necessary to process transactions (amount, currency, customer identifier) and do not have access to full card numbers.
- Transactional email provider (currently Postmark — United States): unless your firm or you configure your own SMTP server (see Terms of Service, Section 15), outbound email from the platform — portal invitations, notifications, invoices, sign-in and account emails — is delivered through our transactional email provider. That provider processes the recipient's email address and the content of the message, and retains a copy of sent messages for a limited period for delivery troubleshooting. While held there, that content is subject to the laws of that country. Firms that prefer all outbound email to stay within their own infrastructure can configure their own SMTP server.
- Cloudflare (security): we use Cloudflare Turnstile on sign-in, registration, password-reset, client-portal login, contact-form and public-tool pages to protect against automated abuse. Cloudflare may process your IP address and browser metadata to verify that you are a legitimate user. No personal information beyond what is necessary for this verification is shared with Cloudflare.
- Google (address lookup — United States): the client portal offers address autocomplete to help a client enter an address accurately. As a person types, the characters entered in that field are sent to Google's Places service in the United States, which returns matching suggestions. Only the address text typed into that field is sent — no documents, no case data, and no other personal information. Google processes it under its own terms and privacy policy, and that data is subject to United States law while it is there.
- Calendly (scheduling — only if your firm connects it): if your firm connects a Calendly account, the booking information your clients submit — including name, email address and appointment details — is processed by Calendly under its own terms and privacy policy, and flows back into your workspace as contact and appointment records.
Apart from the service providers described above, we do not sell, rent or trade your personal information, and we do not disclose it to third parties except:
- to service providers who process it on our behalf, under contract, only on our instructions and only to deliver the Service;
- where required or permitted by law, including in response to valid legal process, and we will tell you unless we are prohibited from doing so;
- where we exercise the reporting right reserved in Section 9 of our Terms of Service (immigration integrity), to the extent permitted by law;
- in connection with a business transaction — a merger, acquisition, financing, reorganization or sale of all or part of our business — where the information is necessary for the parties to determine whether to proceed or to carry the transaction out, subject to an agreement requiring the recipient to use it only for that purpose, to protect it, and to use or disclose it thereafter only for the purposes for which it was originally collected. If a transaction completes and your information is transferred, we will tell you;
- to our professional advisers (legal, accounting, insurance and audit), bound by confidentiality obligations;
- with your consent.
Our accountability for transfers. Using a service provider does not transfer our responsibility. Where we transfer personal information to a service provider for processing, we remain accountable for that information and use contractual and other means to require a comparable level of protection while it is processed on our behalf.
6. Your Rights
6.1 If you are a practitioner, firm owner or staff member
In respect of the personal information for which we are the accountable organization (Section 1.1(a)), you may:
- Access: request a copy of the personal information we hold about you. We respond within thirty (30) days. Where a request is complex, involves a large volume of information, or requires us to consult others, PIPEDA permits us to extend that period by up to a further thirty (30) days; if we need to, we will tell you within the first thirty days, explain why, and say when to expect our response
- Correction: request correction of inaccurate or incomplete information. You can also update most information directly in your account settings
- Withdraw consent: withdraw consent to a use or disclosure at any time, subject to legal and contractual restrictions and to reasonable notice. Withdrawal may prevent us from continuing to provide the Service
- Deletion of your account information: request deletion of your account and the personal information we hold about you as the accountable organization — subject to information we must retain (see the Retention Schedule in Section 7), and subject to your firm's own records, which are governed by Section 6.3
- Complain: raise a concern with us, or with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca
To exercise these rights, contact our Privacy Officer using the details in Section 14.
6.2 If you are a client of a firm
Your personal information in a firm's workspace is held by us on that firm's behalf and on its instructions (Section 1.1(b)). Please direct requests to access, correct or delete that information, or to withdraw consent, to the firm representing you — they can act on them directly within the platform. We are not able to alter or delete a firm's case records on our own initiative.
If you contact us anyway, we will not ignore you: we will acknowledge your request, tell you which firm holds your information, and forward the request to that firm's designated contact so it can be actioned — unless doing so would be unlawful or would prejudice an investigation. If you cannot identify or reach the responsible firm, contact our Privacy Officer and we will help you locate them.
6.3 A note about deleting case records
PIPEDA gives you a right of access, a right of correction, and a right to withdraw consent. It does not create a general right to have information erased. Canadian immigration practitioners are also subject to record-keeping obligations, and case files are ordinarily retained for at least six years after a matter closes (Section 7). Neither a firm nor we can delete a client's case records on request where those obligations apply. A request to delete case information is a matter for the responsible firm to assess against its professional obligations.
7. Retention Schedule
We keep personal information only as long as we need it for the purposes described in this Policy, or as long as a legal or regulatory obligation requires. Where two periods apply to the same information, the longer period governs. This Schedule is the single authoritative statement of our retention periods; where our Terms of Service and this Schedule differ, this Schedule governs.
- Active accounts — for as long as the account is open and in use, so we can deliver the Service.
- Closed or completed cases — six (6) years from the date the case is closed, covering documents, questionnaire responses, notes, invoices and correspondence. At the end of that period the case and its data are permanently deleted automatically, and the firm owner is notified by email when that deletion happens. Reopening a case clears the clock; closing it again starts a fresh six-year period. This period reflects the client-record retention requirements applicable to regulated immigration practitioners in Canada — verifying the period that applies to your own practice remains your professional responsibility. A firm owner may delete a case earlier, at the firm's own risk and responsibility, after an explicit confirmation.
- Account deletion requested by the firm — when a firm asks us to delete its account, data remains available for export for thirty (30) days, and is then permanently deleted from our production systems and from S3 file storage. That deletion covers everything in the workspace, including closed case files still inside their six-year window. If your professional obligations require you to keep those records, export them before the window closes — we cannot recover them afterwards. Two categories survive: the electronic-signature audit trail (with personal information removed from it) and our billing and transaction ledger.
- Electronically signed documents and e-signature records — a completed envelope is retained for seven (7) years from completion, after which the signed PDF, the stored signature images and the values typed by signers are permanently deleted. The audit trail and the document hash are kept, so the fact and integrity of the signature remain provable. We hold these for their evidentiary value and to cover the limitation periods within which a claim about a signed instrument could be brought, not because a specific statute prescribes seven years.
- Billing, tax and transaction records — retained in our billing ledger, and not deleted when an account is purged, so the financial record remains complete and auditable. We retain them for at least the books-and-records retention period applicable to Canadian businesses under the Income Tax Act and, where applicable, the Excise Tax Act — generally six years from the end of the tax year to which they relate — and, in practice, for the life of the ledger.
- Document access logs — 24 months from the access event, then automatically deleted. This matches PIPEDA's 24-month breach-record requirement, which these logs substantiate. They are deleted with the account when a firm closes.
- Breach records — at least 24 months, as PIPEDA requires, including breaches that do not meet the reporting threshold.
- Operational telemetry — AI usage records 180 days; backup and scheduled-job history 90 days; asynchronous AI job records 30 days.
- Encrypted backups — on-server copies for 3 days; encrypted copies in Canadian AWS storage for 30 days, on a rolling cycle.
- Aggregated, de-identified statistics — retained indefinitely for platform improvement; they cannot be linked to any individual.
About backups. When we delete data, we remove it from our production systems promptly. Encrypted backups are retained on the rolling cycle above and are overwritten in the ordinary course, so deleted data ages out of backups within thirty (30) days rather than being individually erased from each backup file. We do not restore deleted data from backup except to recover from a system failure, and any such restoration is followed by re-application of the deletion.
9. Browser Extension (Migrawise Autofill)
Migrawise offers a Chrome browser extension ("Migrawise Autofill") that assists immigration practitioners in filling IRCC portal application forms. It runs inside the practitioner's own browser, on a portal account the practitioner has signed in to with their own credentials, and acts only at the practitioner's direction. Section 5 of our Terms of Service sets out the responsibilities that go with that, including for unattended runs.
Data accessed by the extension
- Case questionnaire data: when you use the extension to fill a form, it retrieves questionnaire responses and applicant information for the selected case from your Migrawise account via our API
- IRCC form fields: the extension reads the form field structure on the current IRCC portal page (field IDs, labels, types, and options) to determine how to map your case data to the correct fields
Data stored locally
- Sign-in token: a session token is stored in Chrome's local storage to maintain your sign-in. It expires and must be renewed, and it is revoked when you sign out, when your firm revokes device access, or when your sign-in security settings change
- Mapping cache: field mapping results are cached locally for a short period to avoid redundant AI processing on repeated page visits. The cache is cleared on expiry or when you switch cases
- Selected case: your currently selected case ID is stored to persist your selection between popup opens
Data not accessed
- The extension never reads, stores, or transmits IRCC portal sign-in credentials. Your GCKey, IRCC Secure Account, or portal passwords are never accessed by the extension
- The extension does not access browsing history, bookmarks, or data on non-IRCC websites
- The extension does not track your activity or collect analytics beyond what is described above
Data transmission
- All communication between the extension and Migrawise servers occurs over HTTPS (TLS 1.2+)
- The extension sends data only to migrawise.ca — it sends nothing directly to any third-party service
- AI-powered field mapping is processed server-side by the same AI provider, under the same practices, described in Sections 5 and 12
Permissions
The extension requests the following browser permissions, each used for a specific purpose:
- Host access to IRCC portals (*.gc.ca, *.canada.ca): required to read form fields on IRCC application pages and fill them with your case data
- Host access to migrawise.ca: required to communicate with the Migrawise API for authentication, case data retrieval, and field mapping
- Storage: used to store your sign-in token and mapping cache locally in your browser
- Scripting: required to interact with IRCC portal form elements that use Angular framework controls
- Active tab, side panel and alarms: used to act on the tab you are viewing, to show the assistant panel beside the page, and to schedule the pacing timers an unattended run uses
Uninstallation
When you uninstall the extension, the data it stored locally (sign-in token, mapping cache, preferences) is removed by Chrome. Server-side records of the sign-in session are cleared on our ordinary cycle.
10. Breach of Security Safeguards
10.1 Information we are accountable for
If we become aware of a breach of security safeguards involving personal information for which we are the accountable organization (Section 1.1(a)), we will assess whether it creates a real risk of significant harm; where it does, we will notify affected individuals as soon as feasible, report to the Office of the Privacy Commissioner of Canada as required by section 10.1 of PIPEDA, and notify any other organization that may be able to reduce the risk of harm.
10.2 Firm Client Data
If we confirm a breach affecting Firm Client Data in a firm's workspace (Section 1.1(b)), we will notify the firm as soon as feasible after determining that a breach has occurred, with the information reasonably available to us, and will keep the firm updated as the investigation develops. We aim to make initial contact within one business day of that determination; where the full picture is not yet known, we will tell you what we do know rather than wait. We will give the firm the information it needs and reasonable assistance in assessing the breach.
The firm, as the accountable organization, determines whether the breach creates a real risk of significant harm to its clients, and is responsible for any notification to those clients, to the Office of the Privacy Commissioner of Canada, and to its regulator. We will not contact a firm's clients directly about an incident except at the firm's written direction, or where we are independently required by law to do so.
10.3 In all cases
We take immediate steps to contain the breach, investigate its cause and implement measures to prevent recurrence, and we maintain records of all breaches of security safeguards — including those that do not meet the reporting threshold — for at least twenty-four (24) months, as PIPEDA requires, and make those records available to the OPC on request.
11. Minors
Migrawise is a professional tool. We do not offer accounts to, or knowingly collect personal information directly from, individuals under the age of 18, and no one under 18 should create a Migrawise account.
Immigration matters frequently concern minors — dependent children in family sponsorship, study permit and permanent residence applications, among others. Personal information about a minor applicant is entered into the platform by the authorized immigration practitioner handling the file, or by the minor's parent or guardian through the client portal, and is not intended to be entered by the minor directly. Where a firm gives a minor access to the client portal, the firm remains accountable for that decision and for the consents its obligations require.
Where a case file contains a minor's personal information, the firm handling that file is the organization accountable for it, including for obtaining consent from the minor's parent or legal guardian where their professional and privacy obligations require it. We hold that information on the firm's behalf and process it only on the firm's instructions. Requests concerning a minor's information — access, correction or deletion — are made to the firm handling the file, which can act on them directly within the platform. We apply the same safeguards and the same retention rules to a minor's information as to any other case information (Section 7).
12. Cross-Border Processing
Migrawise stores data within Canada. Three categories of processing cross the border:
- AI features (United States): when a member of your firm runs an AI feature on a case, or when any document is uploaded to a case — by your firm or by your client through the client portal — (each upload is automatically summarized for the case's AI assistant), the case content needed for that request — including client personal information and uploaded documents — is transmitted to Anthropic, PBC in the United States, processed to generate the requested output, and protected by encryption in transit, contractual no-training terms, and limited provider-side retention. While in the United States, that information is subject to United States law. If no document is uploaded to a case and no AI feature is run on it, no content from that case is sent to Anthropic. Messages sent to the in-product assistant are processed in the same way.
- Address lookup (United States): when a person types an address into a client-portal field that offers autocomplete, the characters typed in that field are sent to Google's Places service in the United States to return suggestions. Only that address text is sent — no documents and no other case content. While in the United States, it is subject to United States law.
- Outbound email (United States): unless your firm or you configure your own SMTP server, email the platform sends — portal invitations, notifications, invoices, sign-in and account emails — is delivered through our transactional email provider, which is based in the United States. The recipient's address and the content of the message are processed there, and a copy is retained for a limited period for delivery troubleshooting. While held there, that content is subject to United States law. Configuring your own SMTP server keeps outbound email within your own infrastructure.
Your firm's own obligations: under PIPEDA's accountability principle, your firm remains the organization accountable to its clients for personal information handled on their behalf. If your firm uses the AI features, informing your clients about cross-border processing — for example through your retainer or service agreement — is your firm's responsibility. Migrawise provides a ready-made disclosure clause in the system "Retainer & Service Agreement" template that you may adopt, adapt, or remove. That template is provided as a convenience so you can see how the platform works, described accurately. It is not legal advice, and we do not warrant that it satisfies your professional, regulatory or privacy-law obligations. Your retainer is your agreement with your client and your responsibility; have it reviewed by your own counsel and adapt it to your practice.
Other than the transfers described in this Section and in Section 5, personal information stored in the Service remains within Canada. If our transfer practices change, we will update this Policy, its version number and its "Last updated" date.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Each version carries a version number and an effective date, shown at the top of this page, and we record the version you accepted.
- Material changes — changes that materially affect how we collect, use, disclose or safeguard your personal information — will be published with a new version number and effective date, and we will give at least thirty (30) days' advance notice by email to the address on your account before they take effect. You will be asked to accept the updated Policy within the Service, and we will record that acceptance and its version, and where PIPEDA requires it we will seek your renewed consent
- Other changes — clarifications, corrections, updated contact details, and changes to the list of service providers that do not alter the categories of information shared or the purposes for which it is used — will be posted with a new version number and a revised "Last updated" date, without individual notice. This does not displace Section 11.5 of the Terms of Service, which gives your firm at least thirty (30) days' notice before we add or replace a service provider that will handle your clients' information
- Urgent changes — where a change is required by law, by a regulator, or is necessary to address a security issue, it may take effect immediately. We will tell you as soon as we reasonably can and explain why
- We retain a copy of each published version and will provide the version you accepted on request. The version in force at the time of an event governs that event.
We encourage you to review this Policy periodically.
14. Contact
If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your personal information is handled, please contact our Privacy Officer:
Venusian Tech Inc. — Privacy Officer
Office 732, 145 1/2 Church Street, Unit 5
Toronto, Ontario M5B 1Y4, Canada
Email: [email protected]
The Privacy Officer is the individual designated as accountable for our compliance with this Policy and with PIPEDA. Email reaches them directly.
If you are a client of a firm that uses Migrawise, please contact that firm first — they are the organization accountable for your information (Section 1.2).
If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada
Website: www.priv.gc.ca
Phone: 1-800-282-1376