This Privacy Policy for CSI Visa Processing ("we," "us," or "our"), describes how and why we might access, collect, store, use, share, transfer or otherwise process your personal information when you use our mobile application Okolabor (the "App"), as well as any other related products and services (collectively, "Services").

Questions or concerns? Reading this Privacy Policy 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.

Okolabor is a platform operated by CSI and is not affiliated with any government or immigration authority. We provide links to official publicly available sources where applicable.

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by using our Table of contents below to find the section you are looking for.

What personal information do we process?
When you use or navigate our Services, we may process different types of personal information depending on how you interact with us and the Services, the choices you make, and the features you use.

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, health information, religious beliefs, etc. We process certain types of sensitive personal information with your consent for the purposes described in the Privacy Policy below.

Do we collect any information from third parties?
We do collect some types of personal information from third parties as further described in the Privacy Policy. We do not collect information from public databases, marketing partners, or social media platforms.

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 applicable 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.

In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties as mentioned below.

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.

How do you exercise your rights?
The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. INTRODUCTION
2. WHAT INFORMATION DO WE COLLECT?
3. HOW DO WE COLLECT PERSONAL INFORMATION?
4. HOW DO WE PROCESS YOUR INFORMATION?
5. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS AS NON-US RESIDENTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

This Privacy Policy sets forth the types of personal information that may be collected from individuals acting in the capacities of Workers, Employers, or Recruiters, as defined in our Terms and Conditions, when using our Services. It also describes our practices regarding the collection, use, maintenance, protection, and disclosure of such information.

For the purposes of this Privacy Policy, the terms “you,” “your,” and “users” collectively refer to Workers, Employers, and Recruiters, except where specific sections of this Privacy Policy address each category of user separately.

This Privacy Policy applies to information we collect:

• On the App.
• Through any account you create via the App.
• In email and other electronic messages between you and us or other users of the App, as applicable.

This Privacy Policy does not apply to information collected by:

• Us through any other means, including on any other website or app operated by CSI or any third party (including our affiliates and subsidiaries); or
• Any third party, including through any application or content that may link to or be accessible from or through the App.

For the purposes of this Privacy Policy "personal data" or “personal information” means any information relating to an identified or identifiable individual.

In Short: We collect personal information that you provide to us or through certain third parties as further mentioned below.

We collect personal information that you voluntarily provide to us when you register on the Services, 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 or interact with our App. A detailed breakdown of the categories and corresponding types of personal information we collect from you is set out in the table below:

All personal information collected by us may be categorized into the following three types:

1. Information You Provide to Us – Personal data that you actively submit, such as when creating a profile, completing forms, or communicating with us.
2. Information Automatically Collected – Personal data gathered automatically when you use our App, including Device Data, Usage Data, Online Identifiers, and Log Data.
3. Information Obtained from Third Parties – Personal data received from third- party sources, such as business partners, service providers, or other entities relevant to the Services we provide.

1. Information You Provide to Us

Depending on the user category, we collect personal information from you in several ways:

1. As a Worker: When you create a profile on the App, you provide personal information including Identity Data and Contact Data, Professional Information, and Visual and Audio Data uploaded to your profile. You also provide Communications Data when interacting with Employers or Recruiters, or when submitting requests or inquiries to us.
2. As an Employer: When you use our Services, such as by registering for an account, we collect Identity Data (e.g., first and last name) and Contact Data (e.g., email address). This includes information provided during account creation, as well as Communications Data when engaging with Recruiters or Workers, or when submitting requests or inquiries to us.
3. As a Recruiter: When you register for an account, we collect Identity Data (e.g., first and last name), Contact Data (e.g., email address), and Communications Data when interacting with Employers or Workers, or when submitting requests or inquiries to us.

Sensitive Information: From Workers, we collect certain Sensitive Information required by Employers or Recruiters, as described in this Privacy Policy. We do not collect any information relating to criminal convictions or offenses.

2. Information Automatically Collected

In addition to the personal information you provide directly, we collect certain details automatically about your interactions with our Services. This information helps us enhance your experience, provide personalized insights, and improve our offerings. We collect the following types of information:

• Device Data. We automatically collect information from your device, such as device type, device token, and operating system version. This information is used to ensure that our Services function correctly and efficiently.
• Usage Data. When you use our App, we automatically collect information about your interactions and online activities, including button clicks, screen views, session length, menu navigation, and similar usage metrics. This data is used to improve your user experience, enhance the design and functionality of our Services, and resolve any technical issues.
• Online Identifiers. When you use our App, we utilize services that generate random identifiers to distinguish between different users, sessions, and devices (e.g., App Instance ID). These identifiers help us associate multiple interactions (such as page views and events) from the same device with a single user profile.
• Log Data. When you use our Services, we automatically collect system-generated records related to the operation of our App and APIs, including access logs, error logs, and IP addresses. This information is used for diagnostics, security monitoring, performance analysis, and troubleshooting.

3. Information From Third Parties

We may obtain Personal Information about you from third-party sources, including data and service providers and business partners. This may include information collected from publicly available sources, such as public APIs or general internet content.

If you provide us with Personal Information relating to another individual, you represent and warrant that you have the authority to disclose such information to us and to permit us to process it in accordance with this Privacy Policy and any other applicable agreements between you and us.

In Short: 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 personal information for various purposes, depending on how you interact with our Services, including but not limited to the following:

• Account Creation and Management: We process your personal information to facilitate the creation and authentication of your account, enable you to log in, and maintain your account in good working order.
• Service Delivery: We process your information to deliver and facilitate the provision of the Services you have requested.
• Service Communications: We process your information to inform you about resources related to migration safety and other relevant topics, respond to your inquiries, and notify you of changes to our Services and products. Such communications may be sent via email or push notifications.
• Customer Support: We use your information to assist you when you contact us with complaints, grievances, or support requests, whether submitted anonymously or personally.
• Direct Communication: The App allows users to send and receive messages directly to one another, either under their own name or anonymously, in order to protect privacy where applicable.
• Accomplishing Our Legitimate Interests: We use Information Automatically Collected to support our legitimate interests, including:
1. Data Analysis: To improve our Services, develop new products, and enhance existing offerings.
2. Security: To safeguard our App from fraud, cyberattacks, identity theft, and unauthorized use.
3. Usage Trends: To understand which features of our App are most popular and focus on areas of high user interest.
• Legal Compliance: We process your personal information to comply with applicable laws and regulations, respond to lawful requests from courts or law enforcement authorities, address legal disputes, and meet regulatory and industry standards.
• Consent-Based Processing: We may process your personal information for additional purposes based on your explicit consent. Such purposes will be clearly communicated to you at the time your consent is sought.

In Short: We may share information in specific situations described in this section and/or with the following third parties.

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

1. Service Providers: We engage a limited number of trusted third-party service providers (“data processors”) to support the delivery, security, and improvement of our Services. We remain the data controller in relation to all personal data processed, and each processor acts solely on our documented instructions in accordance with applicable data protection laws. The key service providers we currently use are:
1. Google Cloud Vision API (Google LLC) – processes images of user documents uploaded to the App to extract Identity Data for verification purposes.
2. Google Analytics (Google LLC) – collects and analyzes App Usage Data to help us understand and improve user experience.
3. Google Firebase Cloud Messaging (Google LLC) – delivers push notifications to users’ devices, enabling timely updates and service-related communications.
4. Google Cloud Platform (GCP) (Google LLC) – provides secure cloud hosting for our App infrastructure and stores related user data.
2. Other Users: If you are a Worker, your profile information, including any documents, videos, or other materials you upload, will be visible and searchable by other users of the App, specifically Employers and Recruiters. These users may process your personal information for job-related purposes and may contact you directly through the App with job opportunities.
3. Legal and Regulatory Compliance: We may disclose your personal information when required or permitted by applicable law, which may include laws and regulations of jurisdictions outside your country of residence. Such disclosure may occur: (i) to comply with applicable legal obligations; (ii) to protect the rights, safety, and property of our users; (iii) to respond to lawful requests, orders, or directives from courts, law enforcement agencies, or regulatory authorities, including those located outside your country of residence.
4. Business Transfers: We may share or transfer your personal information in connection with, or during negotiations relating to, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another entity.

Our servers are located in the United States. If you access our Services from outside the United States, please be aware that your personal information may be transferred to, stored, and processed in the United States and other countries where we or our third- party partners operate.

Some of the third parties referenced in this Privacy Policy, which provide services to us under contractual arrangements, are located in jurisdictions that may not offer the same level of privacy and data protection as the country in which you reside.

For transfers of personal data from individuals in the European Economic Area (EEA), Switzerland, or the United Kingdom to such third parties, we implement a variety of legal mechanisms to safeguard the transfer, including reliance on the European Commission- approved Data Privacy Framework, Standard Contractual Clauses, and, where appropriate, additional safeguards. For transfers to or from Canada, we utilize Standard

Contractual Clauses and remain subject to the regulatory authority of the Office of the Privacy Commissioner of Canada. Similarly, for transfers of personal data from residents of Brazil, we rely on Standard Contractual Clauses to ensure adequate protection.

If you would like more information about the legal mechanisms we use to transfer personal data outside of the EEA, Switzerland, Canada, the United Kingdom, and Brazil, please contact us.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Privacy Policy will require us to keep your personal Information for longer than six (6) months past the termination of the user's account.

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.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

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.

Our security measures include, but are not limited to:

1. Certified Cloud Infrastructure
1. We use certified cloud infrastructure services that meet globally recognized security assurance frameworks and certifications, including: ISO 9001:2015, ISO/IEC 27001, ISO/IEC 27017, ISO/IEC 27018, ISO 50001:2018, ISO/IEC 27110, ISO/IEC 27701 other certifications validated by independent third-party assessors.
2. All data is automatically encrypted at rest, and distributed for high availability and reliability
2. Protection of Stored Data
1. Passwords are encrypted before being stored in our database.
2. Access to stored data is strictly limited to authorized personnel who require it to perform their job duties.
3. User Identification and Authorization
1. When you log in, we issue a secure access token.
2. This token is required to access most areas of the App.
3. Without logging in, users cannot access the majority of App features.
4. Data Protection During Transmission
1. All data transferred between your device and our servers is encrypted using HTTPS (TLS/SSL) protocols.
5. Accountability and Audit Trails
1. We maintain an audit log for every record in our system.
2. This allows us to identify who last edited a record and when the change occurred.

In Short: We do not knowingly collect data from, or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@okolabor.com.

In Short: This section outlines your rights as a non-U.S. resident of certain jurisdictions and our corresponding obligations to protect your personal data in accordance with applicable laws. Depending on your country of residence, you may have specific rights that afford you greater access to, and control over, your personal information. For further details regarding these rights, please refer to the applicable regional notices below.

10.1 Notice to Residents of all Other Countries

Regardless of where you live, you can exercise the following choices:

1. Manage In-App Notifications: You may adjust your notification preferences by accessing the App’s settings through your device’s settings menu. From there, you can enable or disable alerts at any time.
2. Access Your Personal Information: If you would like to review the personal information associated with your account at any time, you may do so by logging into your account settings and viewing the recorded information. You also have the right to request a copy of the personal information we hold about you by contacting us directly.
3. Correct Your Personal Information: If your personal information is incorrect or outdated, you have the right to request that it be updated or corrected to ensure its accuracy. You may also update or modify the information in your account at any time by logging into your account settings and making the necessary changes.
4. Delete Your Personal Information: You may request the deletion of your personal information at any time by contacting us. You may also delete your data manually through the App’s available settings. Upon receiving your request to terminate your account, we will deactivate or delete your account and remove your personal information from our active databases. Please note, however, that we may retain certain information as necessary to prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce our legal terms, and comply with applicable legal requirements.
5. Submit Complaints: If you believe your privacy rights have been compromised, please contact us using the details provided below. We will investigate and address any concerns promptly.

We generally do not charge fees for processing or responding to your requests unless exceptional circumstances apply. If we are unable to fulfill a request, we will explain the reason for our decision.

To exercise any of these rights, please contact us as outlined in the Section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”. We will handle your request in accordance with applicable laws and respond as soon as reasonably possible. To ensure your privacy, we will verify your identity using the information linked to your account, such as your name and email address.

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 Policy.

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.

In Short: Depending on your U.S. state of residence, you may have certain rights in relation to the personal information we collect, use, or disclose, as described in this section. These rights may be subject to limitations or exceptions under applicable law. More information is provided below.

Categories of Data that We May Hold about You

You can learn more about:

1. What personal information we collect in Section 2, “WHAT INFORMATION DO WE COLLECT?”, and its sources in Section 3, “HOW DO WE COLLECT PERSONAL INFORMATION?”, of this Privacy Policy;
2. Why we collect this information in Section 4, “HOW DO WE PROCESS YOUR INFORMATION?”;
3. With whom we share your information and for what purposes in Section 5, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”.”

Depending on your state of residence, and subject to the applicability of the relevant U.S. state privacy laws to the Company, you may have the following rights:

• Right to Access: To request access to the categories of personal information we process about you.
• Right to Data Portability/Transfer: To request a copy of your personal information in a portable and, where technically feasible, readily usable format that enables you to transmit the data to another entity without hindrance.
• Right to Disclosure of Third Parties: To request a list of the categories of third parties with whom we have shared your personal information.
• Opt Out of Processing for Targeted Advertising, the Sale of Personal Data, or Profiling: We do not sell or share your personal information with third parties for purposes of targeted advertising. We also do not engage in profiling that produces legal or similarly significant effects about you.
• Right to Non-Discrimination: To not be discriminated against for exercising any of your privacy rights. You have the right to be free from discrimination for exercising any of the above privacy rights, and we are committed to upholding and honoring this right at all times.

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at info@okolabor.com, by visiting https://www.csivp.com/index.html 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 by 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 U.S. state privacy laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at arodriguez@lampforum.org. 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.

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised” date at the top of this Privacy Policy. 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 Policy frequently to be informed of how we are protecting your information.

In short: You can find our contact details in this section if you have any questions regarding this Privacy Policy or its contents.

If you have questions or comments about this Privacy Policy, you may email us at info@okolabor.com.