Privacy notice

EasyVisaFlow is software sold to immigration agencies. That means the same company holds personal data in two capacities, and the rules are different in each.

• For an applicant’s case data — passports, identity numbers, family relationships, everything in a visa file — the agency is the controller. They decide why the data is held and what is done with it. We are their processor: we store and process it on their documented instructions and for no purpose of our own.
• For the agency’s own account data — staff names, email addresses, sign-in records, support correspondence, billing — we are the controller.

If you are a visa applicant and want to know what is held about you, ask the agency handling your application. They can answer directly, and we assist them under the data processing agreement between us. If you contact us instead we will pass the request on rather than answer it ourselves, because it is not ours to answer.

MU(x) Consulting, represented by Robin Wolters, Hasenweg 4, 85521 Riemerling, Germany. Contact: privacy@easyvisaflow.com.

We have not appointed a data protection officer. German law requires one only above thresholds we are well below, and saying otherwise would be theatre.

Some of this is sensitive by any ordinary reading and some of it is special category data under Article 9 GDPR — a supporting document in a visa file can disclose health, religion or family circumstances. The agency decides what to upload; we hold it under the same restrictions as everything else and never use it for anything but running the service.

When a passport page is uploaded, the image is sent to Anthropic’s Claude API to read the fields from it. The extracted values are then checked against the passport’s machine-readable zone, and staff confirm every field before it is saved — nothing is written to a case on the model’s say-so.

Anthropic processes the image as a processor, does not train models on it, and retains it only briefly for abuse monitoring. The transfer to the United States is covered by Standard Contractual Clauses. If an agency would rather not use this, passport data can be typed by hand and the feature left unused.

• Article 6(1)(b) — performing the contract, for account data and for providing the service to an agency.
• Article 6(1)(f) — legitimate interests, for security logging, fraud prevention and keeping the service working.
• Article 6(1)(c) — legal obligation, for records we are required to keep, such as invoices.
• For applicant case data, the lawful basis is the agency’s to establish, not ours. Their own privacy notice governs it.

That is the whole list. There is no analytics provider, no advertising network and no data broker, and we do not sell or share personal data with anyone for their own purposes. We disclose data to a public authority only where the law compels it, and where we are permitted to tell the agency, we will.

• Applicant case data — for as long as the agency keeps it. Deletion is their instruction to give; when they give it, we carry it out.
• Agency account data — deleted within 30 days of the account closing.
• Invoices and accounting records — 10 years, because German commercial and tax law requires it.
• Server and security logs — 90 days.

Under the GDPR you can ask for access to your data, correction of it, erasure, restriction of processing, a portable copy, and you can object to processing based on legitimate interests. Where processing rests on consent, you can withdraw it at any time without affecting what was done before.

Send a request to privacy@easyvisaflow.com. We answer within one month. If your data is in a case file, see the first section — the agency is the right address, and we will tell you so rather than leave you waiting.

You may also complain to a supervisory authority. Ours is the Bayerisches Landesamt für Datenschutzaufsicht in Ansbach; you may equally complain to the authority where you live or work.

Where an agency operates in South Africa, its clients’ data is also personal information under POPIA, and the agency is the responsible party. POPIA rights are exercised with them. We support them in meeting those obligations under our agreement, including the security safeguards in section 19 of that Act.

Traffic is encrypted with TLS 1.2 or better, and data is encrypted at rest. Each agency’s data is separated by row-level security in the database, so isolation does not depend on application code getting a query right. Uploaded documents are never publicly addressable and are served only through short-lived links after an access check. Every write to a case is recorded with the person who made it.

No system is beyond reach. If a breach occurs that is likely to result in a risk to people’s rights, we notify the affected agency without undue delay and, where we are the controller, the supervisory authority within 72 hours.

Only what is needed to keep you signed in. There is no tracking and no advertising cookie — the detail is on the cookie page.

The service is used by immigration professionals, not by the public, so nobody signs in as a child. Case files routinely contain data about children, because families apply together; that data is the agency’s to collect and is held under the same protections as everything else.

If this notice changes materially, agencies are told by email before the change takes effect. The date at the top always reflects the current version.