Data Processing Addendum

Data Processing Addendum (DPA) for ImmiCan
This Data Processing Addendum ("DPA") applies to the processing of Customer Data (as defined below) provided by the Customer to ImmiCan through ImmiCan's services, including but not limited to MyUnimo and ImmiAI, under the terms of the ImmiCan Business Terms or other agreements between Customer and ImmiCan governing the use of the Services (the “Agreement”). This DPA is incorporated into the Agreement. In case of any conflict, the terms of this DPA shall prevail. For the purpose of this DPA, “Customer” includes any affiliate of the Customer that uses ImmiCan's services. Both ImmiCan and the Customer agree to comply with applicable data privacy and protection laws ("Data Protection Laws") in connection with the Services.

1. Processing Requirements
ImmiCan, as a Data Processor, will:
• Process Customer Data solely to provide and support its Services.
• Not sell or share Personal Data as defined by U.S. Privacy Laws.
• Employ confidentiality agreements with personnel processing Customer Data.
• Engage Subprocessors, listed on ImmiCan’s Subprocessor List, for processing Customer Data, subject to Customer’s consent.
• Provide necessary information to demonstrate compliance with this DPA upon request.
• Assist Customer in ensuring compliance with Data Protection Laws.
2. Notice to Customer
ImmiCan will inform the Customer of:
• Any legal requests for disclosure of Customer Data by law enforcement authorities, unless prohibited by law.
• Any complaint or request received directly from Customer’s data subjects.

3. Assistance to Customer
ImmiCan will assist the Customer with:
• Responding to data subjects' requests under Data Protection Laws.
• Investigating and mitigating any Personal Data Breach.

4. Security
ImmiCan will maintain appropriate technical and organizational security measures to protect Customer Data.

5. Obligations of Customer
The Customer agrees to:
• Ensure all necessary rights and consents for providing Customer Data to ImmiCan.
• Comply with applicable Data Protection Laws.
• Not provide Customer Data through unagreed mechanisms.
6. Standard Contractual Clauses
For data originating from the European Economic Area, Switzerland, and the United Kingdom, data transfers will be governed by relevant standard contractual clauses.

7. Term; Data Return and Deletion
This DPA remains effective as long as ImmiCan processes Customer Data on behalf of the Customer. Upon termination, ImmiCan will delete or return Customer Data as per the Agreement.
Exhibit A
• Data exporter: The Customer using ImmiCan services.
• Data importer: ImmiCan.
• Categories of data subjects, personal data, and processing activities will be as per the nature of services availed by the Customer.
Exhibit B
• Description of technical and organizational security measures implemented by ImmiCan,
including access control, data encryption, physical security, and incident response procedures.

Privacy Policy - (EEA), Switzerland, or UK

Privacy Policy
This Privacy Policy applies if you reside in the European Economic Area (EEA), Switzerland, or UK. If you live outside of the EEA, Switzerland, or UK, this version of our Privacy Policy applies to you. This Privacy Policy describes our practices with respect to Personal Data we collect from or about you when you use our website, applications, and services (collectively, “Services”).
1. Data controller If you live in the EEA or Switzerland, ImmiCan Ireland Limited, with its registered office at 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland, is the controller and is responsible for the processing of your Personal Data as described in this Privacy Policy.
If you live in the UK, ImmiCan OpCo, LLC, with its registered office at 3180 18th Street, San Francisco, California 94110, United States, is the controller and is responsible for the processing of your Personal Data as described in this Privacy Policy.
2. Personal Data we collect
• Account Information: When you create an account with us, we collect information associated with your account, including your name, contact information, account credentials, payment card information, and transaction history.
• User Content: When you use our Services, we collect Personal Data that is included in the input, file uploads, or feedback that you provide to our Services.
• Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send.
• Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, X, YouTube, and LinkedIn. When you interact with our social media pages, we collect Personal Data that you choose to provide to us.
• Technical Information: We automatically collect information when you visit, use, or interact with our Services, including log data, usage data, device information, and information collected through cookies and similar technologies.
3. How we use Personal Data We use Personal Data to provide and maintain our Services; improve and develop our Services and new features; communicate with you; prevent fraud, criminal activity, or misuses of our Services; and comply with legal obligations.
4. Disclosure of Personal Data We may disclose your Personal Data to vendors and service providers, in connection with business transfers, to government authorities or other third parties in compliance with the law, to our affiliates, and to business account administrators.
5. Retention We retain your Personal Data for as long as necessary to provide our Service to you, or for other legitimate business purposes.
6. Your rights You have statutory rights in relation to your Personal Data, including access, deletion, rectification, transfer, restriction, withdrawal of consent, and objection to processing.
7. Children Our Services are not directed to children under 13. We do not knowingly collect Personal Data from children under 13.
8. Legal bases for processing We process your Personal Data based on the necessity to perform a contract with you, our legitimate interests, and compliance with legal obligations.
9. Data transfers We transfer Personal Data outside of the EEA, Switzerland, and the UK in accordance with applicable data protection laws.
10. Changes to the privacy policy We may update this Privacy Policy from time to time.
11. How to contact us If you have any questions or concerns about this Privacy Policy, please contact us at privacy@immican.ai or the address provided in Section 1.

Privacy Policy - Non (EEA), Switzerland, or UK

Privacy Policy
Last Updated: November 14, 2023
Effective: January 31, 2024

Introduction
ImmiCan Inc. ("ImmiCan", "we", "us", or "our") values your privacy and is dedicated to safeguarding the information we collect from you or about you. This Privacy Policy outlines our practices regarding the Personal Information we gather when you use our website, applications, and services (collectively, “Services”). This Privacy Policy does not cover information processed on behalf of our business customers, such as data from our AI assistant services, which is governed by our customer agreements.
This Policy does not apply to individuals in the European Economic Area, UK, and Switzerland, where a different version of our Privacy Policy applies.

1. Personal Information We Collect
• Provided by You: Includes account details, contact information, payment data, transaction history, content you input into our Services, communication records, and social media interactions.
• Automatically Collected: Encompasses log data, usage statistics, device information, and cookies. We may also utilize analytics tools.
2. Usage of Personal Information
We employ Personal Information for various purposes, including service provision, improvement, communication, fraud prevention, compliance with legal obligations, and more.
3. Disclosure of Personal Information
Your Personal Information may be shared with vendors, service providers, during business transfers, for legal requirements, with affiliates, and with business account administrators.
4. Your Rights
You may have rights to access, delete, rectify, transfer, restrict, or object to the processing of your Personal Information, depending on your location.
5. U.S. State Disclosures
We detail the categories of Personal Information we collect and disclose. We do not "sell" or "share" Personal Information for certain advertising purposes and do not process sensitive Personal Information for inferring characteristics about consumers.
6. Children’s Privacy
Our Services are not intended for children under 13. We do not knowingly collect data from children under this age.
7. Links to Other Websites
Our Service may contain links to third-party sites, which are governed by their own privacy policies.
8. Security and Retention
We implement measures to protect your data but remind users that no system is entirely secure. Retention periods depend on various factors.
9. International Users
Users outside the U.S. should be aware that their information will be processed in the United States and potentially in other jurisdictions.
10. Changes to This Policy
We reserve the right to update this Privacy Policy and will notify users of significant changes.

Terms of Use

Terms of Use
Effective: January 31, 2024 (Previous Version)
Welcome to ImmiCan!
These Terms of Use apply to your use of MyUnimo, ImmiAI, and other services offered by ImmiCan, including any associated software applications and websites (collectively, "Services"). These Terms form an agreement between you and ImmiCan Inc., a company incorporated under the laws of [Jurisdiction], and include our Service Terms and important provisions for resolving disputes.
By using our Services, you agree to these Terms.
If you reside in the European Economic Area, Switzerland, or the UK, your use of the Services is governed by these terms.
Our Business Terms govern the use of our services for businesses and professionals.
Our Privacy Policy explains how we collect and use personal information and is an integral part of these Terms.
Who We Are
ImmiCan is dedicated to accelerating the economic integration of immigrants in Canada. Our mission is to provide a transparent and accountable platform for immigrants and professionals. Visit our website for more information.
Registration and Access • Minimum Age: You must be at least the minimum age required in your country to use our Services. If under 18, parental or guardian consent is required.
• Registration: Accurate and complete information is required for account registration. Account sharing is prohibited.
Using Our Services • Permitted Use: Comply with all applicable laws, our policies, and guidelines.
• Prohibited Use: Illegal, harmful, or abusive activities are forbidden. This includes infringing on rights, modifying our Services, reverse engineering, data extraction, misrepresentation, and interference with our Services.
Content
• Your Content: You are responsible for the content you input into our Services.
• Ownership of Content: You retain ownership of your input and the output generated.
• Our Use of Content: We may use your content to improve our Services, comply with the law, and ensure safety.
• Opt Out: Instructions are available if you choose not to have your content used for training our models.
Paid Accounts
• Billing: Accurate billing information is required for paid Services.
• Cancellation: Subscriptions can be canceled at any time, but payments are non-refundable except as required by law.
Termination and Suspension
We reserve the right to suspend or terminate accounts in breach of these Terms or as required by law.
Disclaimer of Warranties
OUR SERVICES ARE PROVIDED "AS IS." WE DISCLAIM ALL WARRANTIES TO THE MAXIMUM EXTENT PERMITTED BY LAW.
Limitation of Liability OUR LIABILITY IS LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW.
Indemnity
You agree to indemnify us against claims related to your use of our Services.
Dispute Resolution
• Arbitration: Disputes will be resolved through arbitration, except as specified.
• Class and Jury Trial Waivers: Disputes must be brought individually.
Copyright Complaints
Contact us if you believe your intellectual property rights have been infringed.
General Terms
• Assignment: These Terms cannot be transferred by you.
• Changes: We may update these Terms and will notify you of significant changes.
• Governing Law: These Terms are governed by [Jurisdiction's] law.
Research and Development
We are continuously improving our Services for better accuracy and user experience.