Imigos Inc. (“Imigos,” “we,” “us,” or “our”), a Delaware corporation, provides this Privacy Policy to inform you about our practices concerning the collection, use, disclosure, and protection of your Personal Information. Except as otherwise stated, this Privacy Policy applies to information we collect when you access or use our websites, web and mobile portals, applications, interactive features, eligibility tools, consultations, case portal, and related services (collectively, the “Services”), or when you otherwise interact with us where we post or link to this Privacy Policy.
By using the websites located at imigos.com (including all subdomains) and any other websites we own or control that link to this Privacy Policy (collectively, the “Sites”), or by using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you may not access or use the Sites or the Services.
This Privacy Policy is incorporated into our Terms of Use. If you choose to engage a Partner Attorney through the Services, your relationship with that attorney will be governed by a separate engagement agreement; however, your use of the Sites and Services continues to be governed by the Terms of Use and this Privacy Policy, where and as applicable.
As used here, “you” and “your” refer to all individual users of the Sites and Services and each individual whose Personal Information is submitted to our Services. If you are a dependent or family member whose information is provided to us in connection with another user’s case (for example, a spouse listed on a family-based application), this Privacy Policy applies to your information; however, you should also contact the primary applicant or their attorney regarding additional information practices.
Imigos is not a law firm. Imigos provides technology, software, and informational services. We do not provide legal advice. Your use of the Sites and Services and your communications with Imigos do not create an attorney-client relationship with Imigos. If you choose to engage a licensed immigration attorney through the Services (a “Partner Attorney”), your relationship with that attorney will be governed by a separate engagement agreement and applicable rules of professional conduct.
Certain jurisdictions require us to provide additional information regarding our privacy practices and your privacy rights. If you are a resident of California, Nevada, or another U.S. state that has enacted a consumer privacy law (collectively, the “Applicable U.S. States”), please refer to Section 13 (“Your Privacy Rights Under U.S. State Privacy Laws”). If you are located outside the United States, including in the European Economic Area, the United Kingdom, Switzerland, Brazil, India, Türkiye, or other jurisdictions with data protection laws, please also refer to Section 14 (“For Users Outside the United States”).
1. Information We Collect
1.1 Data Controller
Imigos Inc., a Delaware corporation with its principal place of business at 8 The Green, STE B, Dover, DE 19901, United States, is the data controller for personal information processed under this Privacy Policy. You can contact us regarding privacy matters at privacy@imigos.com.
1.2 Identity Information
When you use the Sites or Services, we collect certain Personal Information that can be used to contact or identify you, including but not limited to your name, gender, date of birth, country of birth, country of residence, citizenship(s), telephone number, postal address, and email address (“Identity Information”).
1.3 Billing Information
If you place an order for paid Services, we collect additional payment and billing information, including but not limited to your billing name, billing address, the last four digits of your payment card, card brand, and transaction identifiers (“Billing Information”).
For the avoidance of doubt, we do not store or retain full credit or debit card numbers, CVV codes, or bank account credentials. Payments are processed by PCI DSS-compliant third-party payment processors under their own terms and security standards. We store only transaction tokens and limited information necessary to retrieve transaction history, issue receipts, process refunds, and comply with tax and accounting obligations.
1.4 Application Information
When you complete the eligibility quiz, upload documents to your case portal, or engage a Partner Attorney through the Services, we may collect or receive information necessary to assess immigration pathways and to support the preparation or filing of forms or applications with U.S. or foreign government agencies. If you file an application, we may also receive from the relevant government agency a unique receipt number or case identifier assigned to your application (collectively, “Application Information”).
Depending on the Services you request and the immigration pathway you pursue, Application Information may include sensitive personal information such as: information about your age, race, disability, sexual orientation, religion, national origin, or racial or ethnic origin; your Social Security number, driver’s license, state identification card, passport number, or other government identification number; your immigration status and history (including prior visa denials); birth, marriage, divorce, and adoption certificates; criminal history extracts where required for a specific visa category; medical certificates where required for a specific visa category; biometric photos; employment status, employer information, and employment history; financial account details and source-of-funds documentation where required for a specific visa category; and educational records such as transcripts, diplomas, and certifications.
Together, your Identity Information, Billing Information, Application Information, Usage Data (defined below), and other information that (i) can be used to identify you and (ii) qualifies as “personal data,” “personal information,” or “Personally Identifiable Information” under applicable data privacy laws, are referred to as “Personal Information.”
You are responsible for verifying the accuracy of the Personal Information you submit to Imigos and for keeping it up to date. Inaccurate information may affect the eligibility assessment, the Services we are able to provide, and our ability to communicate with you. For example, your email address should be kept current because that is one of the primary methods we use to communicate with you about your account, case, and applications.
1.5 Usage Data
We also automatically collect certain Personal Information regarding your access to and use of the Sites and Services. This information includes your computer or device hardware and software, IP address, approximate geolocation derived from your IP address, browser type and version, referring website URLs, domain names, time zone, language settings, access times, log files, the pages of the Sites you visit, the features you use, the links you click, search queries on the platform, and other information about how you interact with the Sites or Services that is linked to information that directly relates to or could be used to identify you (“Usage Data”).
1.6 Communications and Sensory Data
We may collect information generated through your communications with us and through your use of features that involve audio, video, or recorded content. This includes:
- Scheduling information you submit through our booking tools;
- Call recordings: if you book a consultation with an Imigos specialist, the call may be recorded, transcribed, and processed using automated tools, subject to your consent and applicable two-party consent laws (see Section 4);
- Messages exchanged between you and Imigos staff, between you and your chosen Partner Attorney through the Platform (where enabled), and email correspondence and support tickets;
- Customer-service interaction records, including chat transcripts, voicemails, and customer-survey responses.
1.7 Cookies and Similar Technologies
Like many websites, we use technologies to recognize you when you visit the Sites or use the Services, track your interactions, personalize your experience, and analyze use. These technologies include cookies, web beacons, pixels, software development kits (SDKs), session replay scripts, fingerprinting scripts, local storage, and similar mechanisms (collectively, “Cookies”). See Section 12 for details on the categories of Cookies we use and your choices.
2. Sources of Personal Information
We collect Personal Information from the following categories of sources:
- Directly from you: when you create an account, complete the eligibility quiz, upload documents, book a consultation, or communicate with us.
- Automatically: through your use of the Services, using Cookies and similar technologies described in Section 12.
- From service providers: such as analytics, fraud-prevention, hosting, and payment providers acting on our behalf.
- From AI Service Providers: third-party AI tools that process your Personal Information at our direction to assist with the functions described in Section 3.
- From Partner Attorneys: when an attorney you have engaged transmits information regarding your case.
- From public or third-party sources: where necessary for fraud prevention, identity verification, or platform security.
3. How We Use Your Information
3.1 Account Creation and Management
We use Personal Information you submit at the time of account registration (such as your name and email address) and any updated information you subsequently submit to create, maintain, and secure your account.
3.2 Providing and Operating the Services
We use your Personal Information to operate our business and provide the Services to you, including:
- Operating the eligibility engine and presenting pathway results based on the information you provide;
- Enabling consultations and hosting your case files in the case portal;
- Transmitting documents and case information you choose to share with a Partner Attorney you have engaged;
- Facilitating payments for Platform Fees, Attorney Fees (where applicable), and Government Fees (where applicable);
- Sending you transactional communications about your account, case status, scheduled consultations, payments, and security;
- Periodically retrieving your application’s status from publicly available government systems (using your government receipt number, where applicable) and providing related notifications.
3.3 Improvement and Personalization of the Services
We use Personal Information to personalize and improve the Services, for example by remembering account settings, recently visited pages, and language preferences. We may use your Personal Information to verify your identity, prevent fraud, enforce our Terms of Use, protect the integrity of the Services, develop new features, and improve service quality. As part of these activities, we may create aggregated, de-identified, or anonymous data, as described in Section 3.5.
3.4 Use of Artificial Intelligence and Automated Tools
In providing the Services, we may use artificial intelligence, machine learning, and other automated tools (collectively, “AI Tools”) to assist with certain functions, including: document processing and optical character recognition (OCR); document drafting assistance for Partner Attorneys; form-field auto-population (with attorney review); case summarization and timeline estimation; consultation call transcription and summarization (where you have consented to recording); customer-support assistance; translation; fraud detection; and search and retrieval across your case files. AI Tools process Personal Information only as necessary to perform these functions and only in accordance with this Privacy Policy.
We may expand or change our use of AI Tools over time. Where new AI features materially change how your Personal Information is processed, we will update this Privacy Policy and, where required by applicable law, obtain your consent before using your Personal Information for the new purpose.
(a) Human review before action
Every output of an AI Tool that materially affects your case is reviewed by a qualified human, a Partner Attorney (for legal assessments, filings, and case advice) or qualified Imigos personnel (for operational and platform decisions), before any action is taken. AI Tools do not make legal decisions about your case, do not determine your eligibility for immigration benefits, and do not replace attorney review.
(b) No solely automated decisions with legal or similarly significant effect
Imigos does not make decisions that produce legal effects concerning you, or that similarly significantly affect you, based solely on automated processing of your Personal Information, except as expressly permitted by applicable law. The eligibility engine produces informational pathway suggestions only, these are not legal eligibility determinations and are not a guarantee of any visa or immigration outcome.
(c) Use of data to train and improve our AI models
Imigos is building immigration-specific AI capabilities to improve pathway analysis, document processing, and case workflow over time. Because the Services concern immigration, some of the Personal Information we process inherently includes sensitive categories such as nationality, ethnic origin, and immigration status (for example, passport data used to train document-verification models). We may use data we collect to train, evaluate, and improve our own AI models, subject to the following protections:
- Anonymized and aggregated data (default): We may use anonymized and aggregated data derived from your use of the Services (including case outcomes, timing patterns, and structural pathway data with direct and indirect identifiers removed) to train and improve our AI models and to develop new features. You may opt out of having your anonymized data used for AI training at any time through your account settings or by contacting privacy@imigos.com.
- Identifiable data (explicit consent required): Where the use of identifiable or sensitive Personal Information for AI model training is necessary to provide, maintain, or improve our core immigration Services, we will do so only (i) with your explicit consent obtained at or before the point of collection, (ii) using appropriate technical safeguards including de-identification, access controls, and data-minimization techniques, and (iii) in accordance with applicable data protection laws. We may offer an enriched training program with eligible program benefits (such as platform credits or extended access) in exchange for participation; participation is always voluntary.
- Sensitive carve-outs (never used for training): Regardless of consent, the following information is never used to train AI models: (i) government-issued identifier numbers (passport, Social Security, driver’s license, national ID); (ii) communications between you and a Partner Attorney (which may be subject to attorney-client privilege); (iii) health, medical, biometric, or criminal record information; (iv) information about minors under 18; and (v) data from users who have opted out of training.
- Withdrawal of consent: You may withdraw your consent at any time by contacting privacy@imigos.com. Upon withdrawal, we will cease using your Personal Information for model training on a going-forward basis. Your data will be removed from future training datasets at the next retraining cycle, and we will not use your Personal Information for new training thereafter.
(d) AI Service Providers and contractual safeguards
When we share Personal Information with third-party AI providers (“AI Service Providers”), we do so under written agreements that require them to:
- Process your Personal Information only as directed by Imigos and solely for the purpose of providing services to Imigos;
- Maintain appropriate technical and organizational security measures;
- Refrain from using your Personal Information to train, develop, or improve their own or any third party’s AI models, algorithms, or products, unless such data has been anonymized or aggregated such that it no longer constitutes Personal Information;
- Delete or return your Personal Information upon termination of the service relationship; and
- Not disclose your Personal Information to any subprocessor without Imigos’s prior approval.
AI Service Providers may process your Personal Information in the United States and other jurisdictions. See Section 14 for information about international transfers.
(e) Data minimization for AI processing
When sharing Personal Information with AI Service Providers, we provide only the information necessary for the specific function being performed. For example, when AI Tools are used to process a document, we transmit only the relevant document and the minimum metadata required for the task, rather than your entire case file.
3.5 Aggregated and De-Identified Data
We may create aggregated, de-identified, or anonymous data from Personal Information we collect (for example, by removing identifiers and combining responses into statistical summaries or by training AI models on data with identifiers removed). We may use and share such data for any lawful business purpose, including improving the Services, conducting research, publishing platform statistics, and improving our AI models, provided we do not attempt to re-identify the data and do not share it in a manner that could identify you.
3.6 Communications With You
We may contact you using the contact information you provide in order to: respond to inquiries you send us; communicate about your account, case, payments, and security; and, with your consent where required, market our Services or those of our partners. You may opt out of marketing communications using the unsubscribe link in each email or by emailing privacy@imigos.com.
3.7 Internal Research
We may use information about you (including Personal Information) and other users, typically in aggregated, de-identified form, for our own internal research and analytical purposes, including to understand which features of the Services are being used most frequently and to identify areas for improvement.
3.8 Security, Fraud Prevention, and Legal Compliance
We use Personal Information to: authenticate users and secure accounts; detect, investigate, and prevent fraud, abuse, security incidents, and prohibited activity; comply with legal, tax, accounting, and regulatory obligations; enforce our Terms of Use; and protect the rights, property, or safety of Imigos, our users, attorneys, or others.
4. Call Recording and Sensory Data
If you book a consultation with an Imigos specialist or otherwise participate in a recorded session, the audio and/or video of the call may be recorded, transcribed, and processed using AI Tools, subject to your consent.
4.1 Notice and Consent
When you book a consultation through our scheduling tool, you will be informed that calls may be recorded and given an opportunity to consent. At the start of any recorded call, you will also be reminded that the call is being recorded. By proceeding with the call after these notices, you consent to the recording, transcription, and processing of the call as described in this Section.
Two-party consent jurisdictions. In certain U.S. states and other jurisdictions that require all parties to consent to recording, we will not record a call unless we have obtained your affirmative consent.
4.2 Illinois Residents: BIPA Notice
Imigos does not currently collect biometric identifiers such as voiceprints or facial recognition data from Illinois residents. If we introduce features that would involve such collection, we will provide separate notice and obtain a written release as required by the Illinois Biometric Information Privacy Act (740 ILCS 14/15).
4.3 Use of Recordings
Recordings and transcripts may be used for: providing the consultation Service to you; quality assurance, training, and improvement; AI-assisted transcription, summarization, and search; dispute resolution; and compliance with legal obligations. Recordings and transcripts are stored in accordance with our security and retention practices (see Sections 9 and 10) and are subject to the same access controls as other case data.
4.4 Your Choices
If you do not wish your call to be recorded, you may decline at the time of booking or at the start of the call. If you decline recording, we may still be able to provide the consultation but may not be able to provide certain follow-up functions (such as written summaries) that rely on recording or transcription.
5. How We Share Your Personal Information
5.1 No Sale of Personal Information
Imigos does not sell your Personal Information in exchange for money. We disclose Personal Information only as described in this Section. Some of our disclosures of Personal Information for purposes of cross-context behavioral advertising may be considered “sharing” or “sale” under certain U.S. state privacy laws. See Section 13.
5.2 With Your Consent
We may share your Personal Information with third parties if you provide us with authorization to do so. For example, if you choose to engage a Partner Attorney through the Services and authorize transmission of your file, the relevant case information you select will be made available to that attorney.
5.3 With Partner Attorneys You Choose
Imigos displays profiles of licensed immigration attorneys available on the Platform so that you may independently choose to engage one of them. Imigos does not match, refer, or recommend specific attorneys and does not receive any fee that is contingent on or paid in exchange for directing users to any particular attorney. When you choose to engage a Partner Attorney and authorize transmission of your file, the relevant case information you select becomes available to that attorney. From that point forward, the Partner Attorney is an independent controller of your Personal Information for purposes of the attorney-client relationship, and that relationship is governed by a separate engagement agreement and applicable rules of professional conduct.
5.4 Service Providers (Subprocessors)
We may share your Personal Information with vetted third-party service providers that perform services on our behalf, under written agreements that require confidentiality and appropriate safeguards. The categories of subprocessors we use, or expect to use as the Services launch and grow, include:
| Category of Subprocessor | Purpose |
|---|---|
| Hosting, database, and authentication providers | Operating the Platform, storing user data and case files, authenticating users |
| Payment processors | Processing payments from users; facilitating payouts where applicable |
| Scheduling tools | Booking and managing consultations between users and Imigos specialists or Partner Attorneys |
| Email and communication delivery providers | Sending transactional and marketing emails, in-platform messages, and notifications |
| AI service providers | Document processing/OCR, drafting assistance for attorneys, case summarization, search, translation, and similar functions described in Section 3.4 |
| Speech-to-text and transcription providers | Transcribing and summarizing recorded consultation calls |
| Analytics providers | Measuring product usage, debugging, performance monitoring, and product improvement |
| Internal productivity and document collaboration tools | Internal email, file storage, and collaboration among Imigos personnel |
| Security, fraud prevention, and customer-support providers | Detecting and preventing fraud, providing customer support, and protecting the security of the Services |
We will notify users of material changes to our subprocessors in advance, as and where required by applicable law.
5.5 Marketing and Advertising Partners
Where permitted by applicable laws, we use various third-party tracking technologies and share limited Personal Information (often hashed) with marketing and advertising partners to promote our Services across the web, including through retargeting. The categories of partners we work with include advertising networks, social-media platforms, and measurement providers (such as Meta, Google, LinkedIn, and similar services).
Sensitive immigration data is never used as an audience- targeting parameter. We restrict our advertising activities to top-of-funnel marketing based on website visits, general interests, and lookalike modeling that does not rely on sensitive case attributes.
Where applicable, we treat these disclosures as “sharing” for cross-context behavioral advertising under U.S. state privacy laws and provide opt-out mechanisms as described in Section 13.
5.6 Analytics Partners
We share device, usage, and aggregated data with analytics providers to understand how users engage with the Services and to improve them. Where required by law, we obtain consent before using non-essential analytics cookies.
5.7 Academic Research and Aggregated Data
We may share aggregated and de-identified data based on Personal Information provided by you and other users with academic researchers and policy organizations, provided that such researchers are required by contract to use the data only for non-commercial research purposes and not to attempt to re-identify any individual.
5.8 Legal, Regulatory, and Safety Disclosures
We may disclose Personal Information when we believe in good faith that disclosure is necessary to: comply with applicable law, court order, subpoena, or regulatory request; cooperate with law enforcement; enforce our Terms of Use; protect the rights, property, or safety of Imigos, our users, attorneys, or others; or detect, prevent, or address fraud, security, or technical issues. Where legally permitted and feasible, we will provide you notice and a reasonable opportunity to object before responding to a request for your Personal Information.
5.9 Business Transfers
Your Personal Information may be included in the event that some or all of our assets are sold, assigned, or transferred in connection with a merger, acquisition, reorganization, financing, sale of assets, or in the event of bankruptcy. As a general matter, an acquiring party cannot retroactively change the Privacy Policy that was in place when Imigos collected your Personal Information.
5.10 No Attorney-Client Privilege With Imigos
Your communications with Imigos are not protected by attorney-client privilege. If you choose to engage a Partner Attorney through the Services, your communications with that attorney are governed by a separate engagement agreement and applicable rules of professional conduct, which may include privilege protections. Privileged communications between you and a Partner Attorney are not used by Imigos for training AI models and are accessed by Imigos personnel only as strictly necessary to operate the Platform.
6. Policy Regarding Children
Our Sites and Services are intended for adults aged 18 and older. We do not knowingly process Personal Information from persons under 18 except to the extent necessary to provide our Services to the parent, guardian, or other family member of such persons (for example, dependents listed on a family-based application). If you are a parent or guardian and believe that your child has provided us with Personal Information directly without your consent, please contact us at privacy@imigos.com. If we learn that a person under 16 has provided us Personal Information for any reason other than to enable us to provide the Services, we will delete such Personal Information promptly.
7. Data Retention
We retain Personal Information only as long as is necessary for the purposes set out in this Privacy Policy and to comply with our legal, accounting, and reporting obligations. The retention periods set out below are indicative and may vary based on legal obligations, contractual requirements, ongoing case needs, the technical configuration of our systems, and operational considerations. As our Services and retention procedures are formalized, these periods may be refined and this Privacy Policy may be updated accordingly.
| Category | Retention Period (indicative) |
|---|---|
| Anonymous quiz responses (no account) | Up to 12 months for analytics, then aggregated only |
| Account data | Duration of the account + 12 months |
| Case files and uploaded documents | Duration of the case + 3 years (or longer where required by law or your attorney’s professional obligations) |
| Call recordings and transcripts | Up to 24 months (shorter where you request earlier deletion and we are not required to retain) |
| Payment, billing, and tax records | 7 years (tax, accounting, anti-fraud obligations) |
| Marketing data | Until you unsubscribe or 24 months of inactivity, whichever is sooner |
| Server and security logs | 12–18 months |
| Records of consent (including consent to AI training) | Duration of the relationship + 3 years |
| AI training datasets containing your data | As long as the relevant model is in active use; if you withdraw consent, your data is removed from training datasets at the next retraining cycle |
When Personal Information is no longer needed, we delete or irreversibly anonymize it. Backups containing Personal Information are deleted on a rolling basis according to our backup-retention schedule. We may retain certain information longer where required by law or for legitimate business purposes (for example, to defend legal claims or to comply with tax obligations).
8. Data Security
We implement appropriate physical, electronic, and managerial procedures designed to protect the security of the Personal Information we collect, both during transmission and once received. These include but are not limited to:
- Encryption of data in transit (TLS) and at rest;
- Role-based access controls and the principle of least privilege;
- Multi-factor authentication for administrative access;
- Regular backups and disaster-recovery testing;
- Logging, monitoring, intrusion detection, and audit logging of Personal Information as appropriate;
- Confidentiality obligations and security training for personnel and contractors;
- Periodic security reviews and third-party assessments where appropriate.
AI Service Providers and other subprocessors that process your Personal Information are required by contract to maintain appropriate technical and organizational security measures. Data processed by AI Tools is subject to the same encryption and access-control standards as other Personal Information.
No method of transmission or storage is 100% secure. You play an important role in protecting your account: use a strong, unique password, enable multi-factor authentication where available, and notify us promptly of any suspected unauthorized access. Except as expressly set forth in a binding agreement between Imigos and you, Imigos disclaims liability for the theft, interception, loss, or unauthorized access of or damage to your information.
9. International Data Transfers
Imigos is based in the United States. Depending on your location and the Services you use, your Personal Information may be transferred to, stored in, or processed in the United States, the European Union, and other jurisdictions where our service providers and AI service providers operate. Our hosting infrastructure may include European Union data residency for certain categories of data, where designated.
Where we transfer Personal Information to third-party service providers in jurisdictions outside your country of residence, we apply contractual safeguards designed to protect your information at a level consistent with this Privacy Policy. For users outside the United States, additional information about your rights and the transfer mechanisms we use is available in Section 14.
10. Third-Party Analytics
We use third-party analytics services to collect information about use of the Sites and to help us improve them. These services may collect information sent by your browser or device, including pages you visit, time on page, and other usage information. You may opt out of certain analytics tracking by adjusting your browser cookie settings or by using opt-out tools provided by the relevant analytics provider. To opt out of Google Analytics specifically, you may install the browser add-on available at https://tools.google.com/dlpage/gaoptout.
11. Third-Party Links and Sites
This Privacy Policy does not apply to third-party websites, applications, or social-media features accessible through links we provide for your convenience or information. Accessing those links may cause you to leave the Imigos website and may result in the collection of information about you by a third party. We do not control, endorse, or make representations about those third parties’ privacy practices. We encourage you to review the privacy notice of any site or service you interact with before providing them with Personal Information.
12. Cookies and Tracking Technologies
We use cookies and similar technologies for the categories described below. Where required (for example, for EU/UK visitors), we obtain consent through our cookie banner before placing non-essential cookies. You can change your preferences at any time using the “Cookie Settings” link in the footer of our website, or by adjusting your browser settings. Disabling certain cookies may affect functionality.
| Category | Purpose |
|---|---|
| Essential / Strictly Necessary | Required for core platform functionality (authentication, security, load balancing, fraud prevention). Cannot be disabled. |
| Functional | Remember your preferences and choices (language, region, recently visited pages, in-product settings). |
| Performance / Analytical | Help us understand how the Services are used so we can improve them. Includes counts of visitors, pages viewed, time on page, and aggregated engagement metrics. |
| Advertising / Targeting | Used (with consent where required) to deliver relevant ads, measure campaign performance, and limit ad repetition. May be set by third-party advertising networks (such as Meta, Google, LinkedIn). We do not target advertising based on sensitive immigration data. |
12.1 Global Privacy Control (GPC)
Global Privacy Control (GPC) is a browser-based signal that allows you to communicate your privacy preferences. Imigos does not currently engage in activities that constitute a “sale” or “sharing” of Personal Information for cross-context behavioral advertising. If and when we begin such activities, we will honor GPC signals from supported browsers and extensions as a valid request to opt out, and we will update this Privacy Policy accordingly. Where applicable, opt-out preferences are limited to the browser or device on which they are set.
12.2 Do Not Track (DNT)
Because there is no industry consensus on how to interpret DNT signals, the Services do not currently respond to DNT signals.
13. Your Privacy Rights Under U.S. State Privacy Laws
13.1 Categories of Personal Information
The California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), as well as privacy laws in other Applicable U.S. States, provide consumers residing in those states certain additional rights with respect to their Personal Information. This Section also applies to residents of Applicable U.S. States who interact with Imigos in a business or commercial capacity.
In the preceding twelve months, or since the launch of our Services (whichever is shorter), we have collected and used the following categories of Personal Information for the purposes described:
| Category | Examples | Shared With | Business Purpose |
|---|---|---|---|
| A. Identifiers | Name, alias, postal address, email, phone, account name, IP, device ID | Service providers, AI Service Providers, marketing partners, government entities | Yes |
| B. Customer Records (Cal. Civ. Code § 1798.80(e)) | Real name, postal address, telephone, education, employment, financial info | Service providers, Partner Attorneys, government entities | Yes |
| C. Protected Classifications | Age, race, disability, sexual orientation, religion, national origin, marital status | Service providers, Partner Attorneys, government entities | Yes |
| D. Commercial Information | Records of Services purchased, considered, or used; account history | Service providers, marketing partners | Yes |
| E. Internet / Network Activity | Browsing and search history on the Sites, interaction info | Service providers, analytics partners, marketing partners | Yes |
| F. Geolocation Data | Approximate location derived from IP | Service providers | Yes |
| G. Sensory Data | Call recordings, transcripts, photos provided as part of case files | Service providers, AI Service Providers, Partner Attorneys | Yes |
| H. Professional / Employment | Employer, job title, role, employment history, references | Service providers, Partner Attorneys, government entities | Yes |
| I. Education Information | Transcripts, diplomas, certifications | Service providers, Partner Attorneys, government entities | Yes |
| J. Inferences | Pathway-strength scores, preferences, and predispositions derived from Personal Information | Service providers, AI Service Providers | Yes |
| K. Sensitive Personal Information | SSN, driver license, state ID, passport numbers; racial or ethnic origin; religious or philosophical beliefs; immigration status; birth certificate info; health/medical info; criminal record extracts (where required) | Service providers, AI Service Providers (subject to Section 3.4 carve-outs), Partner Attorneys, government entities | Yes |
We do not use or disclose Personal Information in Categories C, G, or K for any purpose other than to provide the Services you have requested and as expressly described in this Privacy Policy. We do not use sensitive Personal Information (Category K) or sensory data (Category G) to train AI models without your explicit consent as described in Section 3.4(c), and we never use Categories K (i) government-issued identifier numbers, (ii) attorney-privileged communications, (iii) health/medical/biometric/criminal information, or (iv) information about minors for AI model training under any circumstances.
13.2 Notice of “Sale” or “Sharing”
Under CCPA, “sale” means the disclosure of Personal Information to third parties for monetary or other valuable consideration, while “sharing” means the disclosure of Personal Information to a third party for cross-context behavioral advertising. Imigos does not currently sell Personal Information for money and does not currently “share” Personal Information for cross-context behavioral advertising. If we begin to share Personal Information for cross-context behavioral advertising in the future, we will update this Privacy Policy and provide an opt-out mechanism, including a “Do Not Sell or Share My Personal Information” link in the footer of our website and honoring of Global Privacy Control signals.
13.3 Your Consumer Rights
Subject to certain limitations under State Privacy Laws, residents of Applicable U.S. States have the right to:
- Know / Access: request information about the categories of Personal Information we collect, the sources, the business or commercial purposes, the categories of third parties with whom we share it, and the specific pieces of Personal Information we have collected about you.
- Correct: request correction of inaccurate Personal Information.
- Delete: request deletion of Personal Information we hold about you, subject to legal exceptions.
- Opt out of future “Sale” or “Sharing”: opt out of having your Personal Information used for cross-context behavioral advertising or sold for monetary or other valuable consideration, if and when we engage in such activities.
- Limit Sensitive PI: California residents may limit the use and disclosure of sensitive Personal Information to what is necessary to perform the Services.
- Portability: receive a copy of your Personal Information in a portable, machine-readable format.
- Non-discrimination: we will not discriminate against you for exercising your rights.
13.4 California “Shine the Light”
California Civil Code §§ 1798.83-84 permits California residents to request a list of the categories of Personal Information disclosed to third parties for those third parties’ own direct marketing purposes. To submit a request, email privacy@imigos.com with “California Shine the Light Request” in the subject line.
13.5 Nevada Residents
Nevada residents have the right to opt out of the sale of certain personal information to third parties who intend to license or sell that information. Imigos does not sell personal information, but you may submit a do-not-sell request by emailing privacy@imigos.com with the subject line “Nevada Do Not Sell Request.”
13.6 Other U.S. State Residents
If you reside in a U.S. state that has enacted a comprehensive consumer privacy law (such as Virginia, Colorado, Connecticut, and others), you may have rights similar to those described above, including the right to access, correct, delete, and port your Personal Information, and to opt out of targeted advertising, sale of Personal Information, and certain profiling activities. The specific scope of these rights and applicable exemptions vary by state. To exercise these rights, contact us using the methods below.
13.7 How to Exercise Your Rights
To exercise any of the rights described in this Section, email privacy@imigos.com with “Privacy Request” in the subject line, or submit a request through your account settings. We may need to verify your identity before fulfilling certain requests. You may designate an authorized agent to act on your behalf, subject to verification. We will respond within the timeframes required by applicable law (generally 30 days for GDPR-style requests, 45 days for CCPA requests, with permitted extensions).
If we deny your request, you have the right to appeal that decision by replying to our response or contacting privacy@imigos.com with the subject line “Privacy Appeal.” If we deny your appeal, you may also have the right to file a complaint with your state attorney general or, where applicable, your data protection regulator.
14. For Users Outside the United States
Imigos is based in the United States and our Services are primarily directed at users located in or migrating to the United States, and at users exploring or migrating to other countries to which we expand our coverage over time. If you access the Services from outside the United States, including from the European Economic Area, the United Kingdom, Switzerland, India, Brazil, Türkiye, Canada, or other jurisdictions, you acknowledge that your information will be transferred to and processed in the United States and other countries where our service providers and AI Service Providers operate. Data protection laws in those countries may differ from those in your country of residence.
Where applicable, we use contractual safeguards (such as Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Agreement) and supplementary technical and organizational measures to protect Personal Information transferred internationally.
We respect privacy rights regardless of where you are located. If you have rights under applicable data protection law in your jurisdiction, including under the EU/UK General Data Protection Regulation, the Brazilian General Data Protection Law (LGPD), the Indian Digital Personal Data Protection Act, the Türkiye Personal Data Protection Law (KVKK), or other applicable laws, please contact us at privacy@imigos.com and we will respond in accordance with applicable law.
Future EU/UK expansion. As we expand the Services to support residents of the European Economic Area, the United Kingdom, and Switzerland, we will update this Privacy Policy with additional disclosures and mechanisms specific to those jurisdictions, including the appointment of an EU/UK Representative under Article 27 of the GDPR where required.
15. Changes to This Privacy Policy
Imigos may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. If we make material changes, we will post the revised Privacy Policy on the Sites or Services prior to or upon any changes becoming effective and update the “Effective Date” and “Last Updated” dates above. Where required by law, we will notify you of material changes through the Services or by email. Your continued use of the Sites or Services after the updated Policy takes effect constitutes acceptance of the changes.
16. Contact Us
If you have any questions about this Privacy Policy or Imigos’s information privacy practices, please contact us at:
Imigos Inc.
8 The Green, STE B, Dover, DE 19901, United States
Email (Privacy and Data Requests): privacy@imigos.com
Email (General Support): support@imigos.com
Email (Legal Notices): legal@imigos.com