Privacy Policy

This Privacy Notice for Novarra Immigration Inc ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://www.novarraimmigration.com/ or any website of ours that links to this Privacy Notice
• Use the Novarra Platform, our secure client platform at https://app.novarraos.com, through which we coordinate your immigration matter. Novarra is an immigration consulting and case coordination company that supports individuals and businesses through employment-based immigration processes. We provide operational guidance, case preparation support, document coordination, client communication, and workflow management in collaboration with independent licensed U.S. immigration attorneys who provide all legal advice and legal representation. Services may include support for O-1, EB-1, NIW, P-1, and other employment-based immigration matters.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@novarraimmigration.com.

SUMMARY OF KEY POINTS#

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. Because we support immigration matters, we may process sensitive or special-category information, such as national origin, immigration status, date of birth, and, where relevant, other information necessary for your case. We process this information only as needed to provide our services and in accordance with applicable law and your consent.

Do we collect any information from third parties? Clients may provide information about third parties, such as dependants (spouse or children), for their immigration matter. Where they do, the client confirms they are authorized to provide that information and to consent to its use.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting our contact page at /contact, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS#

• 1. WHAT INFORMATION DO WE COLLECT?
• 1. HOW DO WE PROCESS YOUR INFORMATION?
• 1. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
• 1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
• 1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
• 1. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
• 1. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
• 1. HOW LONG DO WE KEEP YOUR INFORMATION?
• 1. HOW DO WE KEEP YOUR INFORMATION SAFE?
• 1. DO WE COLLECT INFORMATION FROM MINORS?
• 1. WHAT ARE YOUR PRIVACY RIGHTS?
• 1. CONTROLS FOR DO-NOT-TRACK FEATURES
• 1. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
• 1. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
• 1. DO WE MAKE UPDATES TO THIS NOTICE?
• 1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
• 1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?#

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• job titles
• contact preferences
• resume
• LinkedIn profile
• Google Scholar profile

Sensitive Information. Because we support immigration matters, we may process sensitive or special-category information, such as national origin, immigration status, date of birth, and, where relevant, other information necessary for your case. We process this information only as needed to provide our services and in accordance with applicable law and your consent.

Information collected through the Novarra Platform

Where we are coordinating an immigration matter for you, we collect substantially more information than the general categories listed above. Through the Novarra Platform we collect:

• Identity and immigration information about you: full legal name and any other or former names; date and place of birth; current and prior addresses, in the United States and abroad; phone number and email address; passport number; Alien Registration Number (A-Number); I-94 number and expiry; current immigration status; and, where you provide it, your Social Security Number.
• Immigration history: prior applications, petitions, approvals and denials; prior visa refusals; prior removals or deportations; and prior immigration violations.
• Background information relevant to a filing: including, where applicable to your matter, arrest or criminal history.
• Information about your dependants: where your matter includes a spouse or children, we collect their names, dates of birth, passport numbers, Alien Registration Numbers, and relationship to you. This includes information about minor children. This information is provided to us by you, and by providing it you confirm that you are authorized to do so.
• Documents you upload: including passports and other identity documents, I-94 records, civil documents (such as birth and marriage certificates), court or police records, employment and education records, and other supporting evidence for your matter.
• Employer information: where an employer is sponsoring your matter, we collect company details (including Federal Employer Identification Number), contact information, and information relevant to the sponsorship.
• Case and communication records: your questionnaire responses, messages exchanged through the Platform, case status and history, and records of documents prepared on your matter.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with it. Payment data is handled and stored by our payment processor; you may find their privacy notice at https://wise.com/gb/legal/privacy-notices. The Novarra Platform does not itself process payments. Fees for legal services are billed and collected by the independent licensed attorney you engage, directly under your separate engagement agreement with them.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?#

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• To coordinate immigration case preparation, collect supporting documentation, communicate with independent licensed attorneys, schedule consultations, and maintain client records related to immigration support services.

Client case coordination. We use personal information to coordinate immigration support services, manage case preparation workflows, communicate with clients and independent attorneys, and maintain case-related records.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?#

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• Send users information about special offers and discounts on our products and services
• Analyze how our Services are used so we can improve them to engage and retain users
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience
• Provide efficient, secure, and responsive immigration support services and improve client experience.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?#

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• AI Platforms
• Cloud Computing Services
• Communication & Collaboration Tools
• Data Analytics Services
• Data Storage Service Providers
• Finance & Accounting Tools
• Government Entities
• Payment Processors
• Sales & Marketing Tools
• Social Networks
• User Account Registration & Authentication Services
• Website Hosting Service Providers
• Independent licensed immigration attorneys

Independent Attorneys and Experts. We share your information with the independent licensed attorney handling your legal representation, who acts as an independent data controller. Where our staff assist with case preparation, they do so under the attorney's direction as authorized non-attorney assistants.

Our service providers

We use a small number of service providers to operate the Novarra Platform. They process information on our behalf, on our instructions, and for no other purpose. As at the date of this notice, they are:

• Anthropic — artificial intelligence features (see Section 6).
• Supabase — database, file storage, and authentication.
• Vercel — application hosting and server logs.
• Resend — transactional email.
• Sentry — error monitoring.
• Cloudflare — network security.
• Wise — payment processing, where payments are taken.

We maintain a current list of our service providers at https://www.novarraimmigration.com/subprocessors. We may add or change service providers from time to time; that list is kept up to date, and we will notify you of any material change.

We do not sell your personal information, and we do not share it with third parties for their own purposes.

Sponsoring employers

Where an employer is sponsoring your matter, that employer is given access through the Platform to information relevant to the sponsorship — for example, case status, timelines, and documents relevant to their role in the filing. A sponsoring employer does not have access to your complete file.

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?#

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?#

How we use AI

The Novarra Platform uses artificial intelligence to assist our team and the independent licensed attorneys working on your matter — for example, to read information from documents you upload, to organize and analyze the information you provide, to draft and suggest content for human review, and to answer general questions.

Who provides it

Our artificial intelligence service provider is Anthropic.

What is transmitted to our AI service provider

To deliver these features, the following may be transmitted to Anthropic for processing:

• your questionnaire responses, which may include the sensitive information described in Section 1 — including, where you have provided them, your Social Security Number, Alien Registration Number, and any criminal-history information;
• documents you upload, including identity documents such as your passport, where a feature is used to read information from them; and
• case details, such as visa type and case stage.

What is not transmitted

Private messages between you and your attorney are not transmitted to our AI service provider.

How your information is handled by our AI service provider

Anthropic processes this information as our service provider, in order to return a result to us. Anthropic retains transmitted data for a limited period (currently up to 30 days) for operational and safety purposes, and does not use it to train its models.

Human review

Output generated with the assistance of AI is reviewed by a person before it is relied upon. AI does not make decisions about your matter, and AI output is not legal advice, a legal opinion, or a prediction of any outcome. Only the independent licensed attorney engaged on your matter can advise you.

AI is integral to the Platform

Artificial intelligence is not an optional add-on feature of the Platform, and it cannot be separately disabled while you continue to use the Platform. If you do not wish your information to be processed with the assistance of AI, please contact us before proceeding so that we can discuss alternatives with you.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?#

Our servers are located in Canada and United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), including facilities in Canada, United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?#

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than is reasonably necessary to provide our services, comply with legal obligations, resolve disputes, enforce agreements, and maintain business records related to immigration support services.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Retention of case information held on the Platform

• Active case information: retained for the life of the engagement.
• Closed case information: retained for a minimum of seven years after closure.
• Records of AI-assisted interactions: retained as part of your case record.
• Deletion: you may request deletion at any time. Requests are reviewed and processed manually by our team, ordinarily within 30 days. Records we are required by law to retain will be preserved, and we will tell you which.

We do not currently operate an automated deletion schedule. Deletion is performed manually by our team on request. We have described what we actually do rather than commit to a schedule we could not keep.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?#

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Security of the Novarra Platform

Information held on the Platform is encrypted in transit and at rest. Access is restricted by role: you see your own matter; a sponsoring employer sees only information relevant to its sponsorship; our team and the independent attorney engaged on your matter see the matters they are working on. Uploaded documents are held in private storage and are not publicly accessible.

The Platform is built on infrastructure provided by vendors that hold SOC 2 Type II attestation. Novarra Immigration Inc. does not itself currently hold a SOC 2 attestation.

10. DO WE COLLECT INFORMATION FROM MINORS?#

We do not knowingly collect personal information directly from children under 18 years of age (or the equivalent age of majority in your jurisdiction), we do not market to them, and minors do not hold accounts on the Novarra Platform. By using the Services, you represent that you are at least 18 years of age or the equivalent age of majority in your jurisdiction.

However, where your immigration matter includes dependent children — for example, a family-based or derivative filing — we do collect and hold personal information about those children, including their names, dates of birth, passport numbers, and Alien Registration Numbers. That information is provided to us by you, the adult client, and by providing it you confirm that you are authorized to do so on their behalf. We process it only as necessary for the immigration matter, and we retain it in accordance with Section 8.

If you believe we hold information about a child that we should not, please contact us at info@novarraimmigration.com.

11. WHAT ARE YOUR PRIVACY RIGHTS?#

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration of our services to you, to respond to service requests, or for other non-marketing purposes.

Canada's Anti-Spam Legislation (CASL): Where we send commercial electronic messages, we do so in accordance with Canada's Anti-Spam Legislation (CASL). We send such messages only where we have your express or implied consent, we identify ourselves and provide our contact information in each message, and each message includes an unsubscribe mechanism that we honour promptly.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at info@novarraimmigration.com.

12. CONTROLS FOR DO-NOT-TRACK FEATURES#

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?#

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

Category A. Identifiers: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name. COLLECTED: YES

Category B. Personal information as defined in the California Customer Records statute: Name, contact information, education, employment, employment history, and financial information. COLLECTED: YES

Category C. Protected classification characteristics under state or federal law: Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data. COLLECTED: YES

Category D. Commercial information: Transaction information, purchase history, financial details, and payment information. COLLECTED: YES

Category E. Biometric information: Fingerprints and voiceprints. COLLECTED: NO

Category F. Internet or other similar network activity: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements. COLLECTED: YES

Category G. Geolocation data: Device location. COLLECTED: YES

Category H. Audio, electronic, sensory, or similar information: Images and audio, video or call recordings created in connection with our business activities. COLLECTED: NO

Category I. Professional or employment-related information: Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us. COLLECTED: YES

Category J. Education Information: Student records and directory information. COLLECTED: YES

Category K. Inferences drawn from collected personal information: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics. COLLECTED: NO

Category L. Sensitive personal Information: National origin, immigration status, date of birth, and other information necessary for your immigration matter. COLLECTED: YES

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A - For the duration of your engagement with us, plus any period required to meet legal, tax, and immigration-record obligations
• Category B - We retain personal information for as long as reasonably necessary to provide services, comply with legal obligations, maintain immigration-related records, resolve disputes, and enforce agreements.
• Category C - For the duration of your engagement with us, plus any period required to meet legal, tax, and immigration-record obligations
• Category D - For the duration of your engagement with us, plus any period required to meet legal, tax, and immigration-record obligations
• Category F - For the duration of your engagement with us, plus any period required to meet legal, tax, and immigration-record obligations
• Category G - For the duration of your engagement with us, plus any period required to meet legal, tax, and immigration-record obligations
• Category I - For the duration of your engagement with us, plus any period required to meet legal, tax, and immigration-record obligations
• Category J - For the duration of your engagement with us, plus any period required to meet legal, tax, and immigration-record obligations

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category A. Identifiers
• Category B. Personal information as defined in the California Customer Records law
• Category C. Characteristics of protected classifications under state or federal law
• Category D. Commercial information
• Category I. Professional or employment-related information
• Category J. Education information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting our contact page at /contact, by emailing us at info@novarraimmigration.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@novarraimmigration.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?#

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

15. DO WE MAKE UPDATES TO THIS NOTICE?#

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?#

If you have questions or comments about this notice, you may email us at info@novarraimmigration.com or contact us by post at:

Novarra Immigration Inc

Vancouver, British Columbia V4M 0E6

Canada

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?#

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit our contact page at /contact.