Privacy Policy

This Privacy Policy explains how MigrationPulse Incorporated, the company that operates MigrationPulse ("MigrationPulse," "we," "us," or "our"), collects, uses, discloses, keeps and protects information in connection with the MigrationPulse platform (the "Service"). MigrationPulse is case management software for immigration offices. The offices that use it hold some of the most sensitive information a person has: their identity documents, their immigration status and their family's history. Protecting it is central to our Service.

1. Who This Policy Covers

This policy describes our practices for (a) the immigration offices and the people at them who hold accounts with us ("Customers" or "you"), and (b) visitors to our website.

If you are a client of an office that uses MigrationPulse: the office decides what it collects about you and how it uses it. The office is the controller of your information and we process it only on the office's behalf, under our Data Processing Agreement with it. The office is responsible for its own privacy practices toward you, so please take questions and requests about your information to the office first. If you write to us instead, we will pass your request to the office and help it answer.

2. Information We Collect

• Account information: name, email, phone number, office details, the role the office declares (attorney, accredited representative or non-attorney form preparer) with any bar or accreditation details it gives, and billing information you provide when registering.
• Client and case information offices enter or upload: names, contact details, dates and places of birth, addresses and family relationships of clients and the people on their cases; identity and immigration documents and the numbers in them, such as passport and other identity document numbers, Alien Registration Numbers (A-Numbers) and USCIS receipt numbers; immigration status and history; documents and their translations; signatures; messages and appointments; and, where an office imports them from another system, Social Security numbers. We process this only to provide the Service to the office.
• Information clients give through the Service: documents uploaded and messages sent through the client portal, corrections a client reports, and, when a client signs a document, the name they type, the time, and the network address and browser they signed from.
• Identity verification information: where an office verifies a client's identity, the information described in section 5.
• Usage data: log data, device and browser information, records of each sign-in session (including its network address and browser), and activity within the Service, used to operate, secure, and improve the platform.
• Communications: messages you send through the Service and your correspondence with our support team.

3. How We Use Information

We use information to:

• Provide, maintain, and secure the Service;
• Authenticate users and prevent fraud or abuse;
• Process payments and manage plans;
• Provide customer support and respond to your requests;
• Send service, security, and administrative communications; and
• Comply with legal obligations.

We do not sell personal information. We do not use the client and case information offices put in the Service for our own purposes, and we do not combine one office's client information with another's: we process it only to provide the Service to the office it belongs to, as our Data Processing Agreement sets out. We use account information and usage data, not client information, to understand and improve how the Service is used.

4. How Identity and Immigration Information Is Protected

• Encryption. All information is encrypted in transit and at rest. On top of that, the most sensitive fields are encrypted again, one field at a time, with AES-256-GCM and keys kept apart for each kind of number: passport numbers, A-Numbers, USCIS receipt numbers, immigration status, identity document numbers recorded in an in-person check, and the full result of a remote identity check. A short fragment, such as the last four characters, is kept beside an encrypted number so staff can tell records apart without opening it.
• Documents. Uploaded documents are stored encrypted, and the Service refuses to store a document it cannot encrypt.
• Numbers we do not keep. A USCIS online account number, or a Social Security number typed in for a single form, is written onto that form and not stored.
• Sign-in and access. Every person who signs in to an office account must use two-step sign-in, with a code from an authenticator app. Each office's information is kept separate from every other office's, and within an office each person's access follows the role the office gives them. Clients reach the client portal through a private link that expires after 30 days.
• Records that cannot be altered. The audit trail of each electronic signature, an office's role declarations and completed identity checks are kept as records that cannot be changed after they are made.
• Our program. We maintain a written information security program, with administrative, technical, and physical safeguards, access controls and monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your information or your clients' information, we will notify you without undue delay and provide the detail you need to meet your own notification obligations.

5. Identity Verification

An office may verify a client's identity in one of two ways.

• In person: someone at the office records the type of ID they saw, who issued it, its expiry date, its number (encrypted), whether the photo and details matched, and who checked it and when, and may attach a copy of the ID.
• Remotely: the client opens a link, photographs the front and back of a photo ID and takes a selfie. An identity verification provider compares the selfie with the photo on the ID, checks the client's details against official records, and screens for fraud. We send the provider the client's name, email, phone number, date of birth and address, and never a Social Security number or bank details.

When a remote check is completed we keep its result, the type of document, who issued it, its expiry date and the last four characters of its number, the ID images and the selfie (a photo or a short video), a record of the check as a document, and an encrypted copy of the full result, which includes the network address the client used and the fraud signals. MigrationPulse does not itself make the face comparison; it keeps the images and the provider's result. These records are seen only by the office's staff, never in the client portal.

A completed check's record is kept until the later of three years after the check and 15 October of the fourth year after the year of the check. Until then it cannot be changed or deleted, even if the client is deleted. We do not yet delete these records automatically when the period ends; they are deleted on the office's written request once it has. The office is responsible for telling its client about the check and for any consent the law requires, including for comparing a face with an ID.

6. AI-Assisted Features

Parts of the Service use artificial intelligence: the in-app assistant, drafting a translation of a document, summarizing a meeting an office has chosen to transcribe, and drafting messages and documents. Where you use one of these features, the information needed to answer that request is sent to our AI provider. For a translation that is the text of the document, or the image or PDF of the document itself. For the assistant it can include details from the office's own client records that the question is about.

Our AI provider acts as our service provider and processes this information only to return the result you asked for. Under its terms with us it may not use it to train its models, and we do not use client information to train models of our own. On immigration questions the assistant answers only from official government sources, which it cites with the date each was read, and it does not give legal advice. An AI translation is labelled as a draft and is not certified until a named person has reviewed and approved exactly that text.

Data obtained from Google APIs is not sent to any AI or machine learning service. The Google Calendar connection described in section 7 is separate from the features above: the appointment records it creates are not readable by the in-app assistant or by any other AI feature, and no Google user data, raw or derived, is transferred to an AI provider for any purpose, including model training.

7. Connecting Google Calendar

You may choose to connect a Google account so that appointments booked through MigrationPulse appear in your calendar. This is optional, and the Service works without it.

When you connect, we request a single Google Calendar scope (https://www.googleapis.com/auth/calendar.events) and use it for two things only: to create and update calendar events for appointments booked through MigrationPulse, and to read the events already on the calendar you selected so that your schedule in MigrationPulse matches your real day and we do not offer a client a booking slot when you are not free.

Please read this part before you connect. The synchronisation runs in both directions, so the events we read are copied into your MigrationPulse schedule, not only checked for availability. For each event on the connected calendar within roughly seven days behind and thirty days ahead of today, we store its title, start time, length, cancellation state and Google event identifier as an entry in your MigrationPulse schedule. That includes personal events, under whatever name you gave them, and those entries can be seen by people at your office who are permitted to view your schedule in MigrationPulse. If your calendar holds appointments you would rather your colleagues not see, connect a calendar you keep for work instead of your personal one, or leave the integration switched off. You can disconnect at any time, as described below.

Beyond those entries we store only what is needed to keep the connection working: an access token, a refresh token, the identifier of the calendar you selected, and the time we last synced. We do not use Google user data for advertising, we do not sell or transfer it, and we do not use it to train artificial-intelligence or machine-learning models. MigrationPulse's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

You can disconnect at any time from Calendar Manager inside MigrationPulse, or by removing MigrationPulse at myaccount.google.com/permissions. When you disconnect through MigrationPulse we revoke the token with Google and delete the stored tokens from our systems. Events already written to your calendar remain yours and are not removed.

8. Video Meetings

Offices can hold video meetings with their clients in the Service. The person hosting a meeting can record it; when they do, everyone in the meeting is shown that recording has started. The Service does not ask for or record anyone's consent, so the office is responsible for telling participants and obtaining any consent the law requires. Transcription is off for every office until its owner turns it on. When it is on, the audio is sent to a transcription provider, and an office may have a summary drafted by AI from the transcript and its own notes. Recordings, transcripts and summaries are kept until someone at the office deletes them, or until a retention period set for the office ends.

9. Cookies and Similar Technologies

We use cookies that are necessary for the Service to work, such as keeping you signed in and protecting against fraud. These cannot be switched off without breaking the Service.

On our public pages, meaning our marketing site and our pricing, contact, sign-in and sign-up pages, we may also use a web analytics service and an advertising measurement pixel to understand how people find us, which pages they read, and which advertisements bring them here. These record the pages viewed, the site or advertisement you arrived from, an approximate location derived from your IP address, and basic device and browser information. We read them in aggregate to improve the site and to measure our advertising.

Neither is loaded on the booking pages offices share with their clients, inside the signed-in application, in the client portal or on the signing pages. Addresses in those areas can identify a particular office, client, case or portal session, and we do not send them to any analytics or advertising provider. Nothing you or your clients enter into a case, a document, a message or the portal is ever sent to them.

On every page we also measure page performance, recording which kind of page was viewed rather than its address, and we use an error-monitoring service. When something goes wrong it can record a replay of the page with all text, typed input and images hidden, so we can see what failed without seeing what was on the screen.

You can limit analytics and advertising cookies at any time through your browser's settings or a content blocker. Declining them does not limit your use of the Service.

10. How We Share Information

• Service providers / subprocessors: we use trusted third parties to host, secure, and operate the Service, in these categories: cloud hosting and storage, payment processing, email delivery, identity verification, video meetings and transcription, AI, and error monitoring. They process information only on our instructions and under confidentiality obligations. A current list of subprocessors is available on request.
• Legal and safety: we may disclose information if required by law, subpoena, or court order, or to protect the rights, safety, or security of users or the public. If a government agency or anyone else asks us for an office's client information, we refer them to the office where the law allows, tell the office before we disclose anything where the law allows, and disclose only what the law requires.
• Business transfers: in connection with a merger, acquisition, or sale of assets, subject to this policy.

We do not share client information with any government agency on our own initiative, and MigrationPulse files nothing with any agency.

11. Data Retention

We keep account information and the client and case information offices put in the Service for as long as the account is active.

When an account ends, its data is not deleted automatically. We keep it, protected as before, so the office can renew or ask us for an export, and we delete it when the office's owner asks us to in writing, except information the law requires us to keep and the records below that are kept for a fixed period.

Fixed periods the Service applies:

• Records of sign-in sessions, with their network address and browser: deleted 90 days after the session was last active.
• Conversations with the in-app assistant: deleted 30 days after the last message.
• Security audit records and email delivery records: deleted after one year.
• Completed identity checks: kept for the period in section 5, and not deleted before it ends.
• Signature records with their audit trails, and an office's role declarations: kept for as long as the account's data is kept, because they are the evidence of what was signed and declared.
• Meeting recordings, transcripts and summaries: as section 8 describes.
• An account export: available to download for 30 days after it is built.

Deleting within an account. Removing a client archives the record rather than erasing it. Deleting a client erases the client record and the case records attached to it, but files uploaded for that client stay in storage until the office asks us to delete them. Deleting a single document removes its file. Deleted data may remain for a limited time in backups before they are overwritten.

12. Your Choices and Rights

You may access, correct, export, or request deletion of your account information by contacting us. Depending on your state of residence, you may have additional rights under applicable privacy laws. Requests concerning an office's client information are handled by the office, as section 1 explains, and under the Data Processing Agreement.

13. Children's Privacy

Our website and accounts are for immigration offices and are not directed to children under 18, and we do not knowingly collect personal information from children for our own purposes. Immigration cases often include children, and an office may enter information about a child who is its client or is a family member on a case. That information is the office's, collected under its own responsibility, including any consent from a parent or guardian the law requires, and we process it only on the office's behalf, with the same protection as all client information.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or in-app notification. Your continued use of the Service after changes take effect constitutes acceptance.

15. Contact Us

MigrationPulse Incorporated
Fajardo, Puerto Rico
Email: support@migrationpulse.app
Phone: (787) 468-3300