Privacy policy.

1. Who is the controller

MigrationProvision B.V. (in registration), Bezuidenhoutseweg 30, 2594 AV The Hague — privacy@migrationprovision.com. We are the data controller for all personal data processed through the platform.

2. What we collect

• Account data — email, name (or chosen handle), password (hashed with Argon2id), preferred language, communication preferences.
• Case data — answers to the 10-question assessment; the authority concerned; application reference number; key dates; uploaded supporting documents (passport scans, IND correspondence, etc.).
• Generated documents — the PDFs and DOCX files we generate on your behalf.
• Communication — messages between you and our caseworkers in the portal; emails you send to contact@, cases@, privacy@.
• Payment metadata — Mollie transaction reference, method, amount. We do not see or store full card numbers.
• Technical data — IP address, user agent, log timestamps. Used for security and abuse-prevention.

3. Why we process it (legal bases under GDPR Art. 6)

• Performance of contract (Art. 6(1)(b)) for the bulk of case-file handling.
• Legal obligation (Art. 6(1)(c)) for tax-record retention (seven years per the Algemene wet inzake rijksbelastingen).
• Legitimate interest (Art. 6(1)(f)) for security logging and abuse-prevention.
• Consent (Art. 6(1)(a)) for optional newsletters or research participation.

Special categories of data (Art. 9 GDPR — e.g. data revealing race, ethnicity, health status that may appear in immigration files) are processed where strictly necessary for the substantial public interest of access to justice (Art. 9(2)(g) GDPR, UAVG Art. 23(e)).

4. Encryption

All personally identifying fields are encrypted at rest with AES-256-GCM using per-record envelope keys. The master key is stored in a hardware-protected key vault separate from the application database. Uploaded documents are encrypted with the same scheme. TLS 1.3 in transit, HSTS preload, certificate pinning at the API layer.

5. Sub-processors

Sub-processor	Purpose	Location	Safeguard
Mollie B.V.	Payment processing	NL	PSD2-licensed, GDPR-compliant DPA
Hetzner Online GmbH	Application hosting	DE / FI (EU)	DPA, ISO 27001
Postmark (ActiveCampaign)	Transactional email	EU region	SCCs, DPA
PostNL	Registered-mail handling (opt-in only)	NL	DPA, addresses only
Plausible Analytics	Privacy-friendly analytics	EU	No cookies, no personal data

No data is transferred outside the EU/EEA except where you explicitly initiate a submission to the OHCHR (Geneva, Switzerland — an Art. 45 GDPR adequate-protection jurisdiction).

6. Retention

• Account & case data: while your account is open. Upon deletion, removed within 14 days.
• Generated documents: 24 months after case closure, unless you delete sooner.
• Anonymised case statistics: indefinitely, in the Administrative Stagnation Registry. These cannot be reverse-engineered to identify you.
• Tax-related records: 7 years (statutory).
• Server logs: 90 days.

7. Your rights

Under GDPR Articles 15–22 you have the right to access, rectification, erasure, restriction, portability and objection. Most rights can be exercised directly from Account → Privacy in the portal; otherwise write to privacy@migrationprovision.com. Response within 30 days.

You also have the right to lodge a complaint with the Autoriteit Persoonsgegevens (Dutch DPA) — autoriteitpersoonsgegevens.nl.

8. Cookies

We use one strictly necessary cookie for the login session. No third-party analytics or advertising cookies are set. Plausible Analytics runs cookieless. A cookie banner is therefore unnecessary; if regulatory practice changes, we will add one.

9. Children

The service is not directed at children under 16. Where a minor's immigration case is the subject, the account is held by a parent or legal guardian.

10. Changes

Material changes notified at least 14 days in advance by email and portal banner. Version history available on request.