Privacy Notice — Elboniel Immigration Consultancy Inc.
This Privacy Notice explains how Elboniel Immigration Consultancy Inc. collects, uses, discloses, protects, retains and responds to requests concerning personal information provided through its website, preliminary assessment system and related communications.
1. Scope and accountability
Elboniel Immigration Consultancy Inc. ("Elboniel") is responsible for personal information under its control. This notice applies to information collected through Elboniel's website, free preliminary assessment, contact and privacy-request functions, email communications, and related pre-engagement interactions.
Elboniel is based in Alberta, Canada. Alberta's Personal Information Protection Act (PIPA) applies to provincially regulated private-sector activities in Alberta. Federal privacy law may also apply to personal information involved in interprovincial or international commercial transactions.
2. Personal information we may collect
The information requested depends on the service or assessment selected. It may include your name, contact details, date of birth, citizenship, country of residence, immigration status and history, education, language testing, employment, family and relationship information, travel history, refusal or decision information, sponsorship information, and high-level financial information relevant to an immigration assessment.
If secure document upload is enabled, you may also provide documents that contain personal information. Do not provide documents or sensitive information that the assessment does not request. Elboniel may ask for additional documents only when they are reasonably required for the stated purpose.
3. Why we collect and use personal information
Elboniel collects and uses personal information only for purposes that are reasonable in the circumstances, including to:
• receive and manage your inquiry or preliminary assessment;
• understand your Canadian immigration or citizenship objective;
• identify information that may require professional review or clarification;
• prepare, review and deliver a preliminary assessment report;
• communicate with you about your inquiry, consultation or requested service;
• arrange a consultation or professional engagement where requested;
• maintain appropriate operational, security, audit and professional records;
• respond to access, correction, privacy or complaint requests; and
• comply with applicable legal, regulatory and professional obligations.
4. Automated tools and human professional review
Elboniel uses software and an artificial-intelligence-assisted service to organize applicant information, examine submitted answers and permitted uploaded documents, identify possible inconsistencies or missing information, and prepare an internal draft professional review and Preliminary Assessment Report. This processing may involve transmitting the information and documents provided in the assessment to an authorized technology service provider.
The AI-assisted service does not make Elboniel's professional decision, determine eligibility, approve an application, predict success, or send a report to an applicant. Its output is treated as an unverified draft. An authorized Elboniel professional must independently review the applicant's information and documents, verify material facts and current requirements, edit the draft, complete the professional checklist, and separately approve the report before it can be sent.
5. Consent and your choices
Before submitting an online assessment, the applicant must confirm the required assessment consent. That consent covers Elboniel's collection, use and necessary disclosure of the submitted answers and documents, including processing by the AI-assisted service provider described in this notice, for the purpose of preparing an internal draft assessment for human professional review. An applicant who does not agree should not submit the online assessment and may contact Elboniel to ask whether another intake method is available.
Marketing consent is separate and optional. You do not need to agree to marketing to receive a preliminary assessment. You may withdraw optional marketing consent at any time. You may also withdraw other consent, subject to legal, regulatory, professional or contractual limits; doing so may prevent Elboniel from continuing an inquiry or service that requires the information.
6. When information may be disclosed
Elboniel does not sell personal information. Personal information may be accessed by authorized Elboniel personnel and may be disclosed to service providers that support functions such as website hosting, secure storage, email delivery, security, backups, communications or other necessary business operations. Access should be limited to what is reasonably required for the service provider's function.
Information may also be disclosed where you authorize it, where it is necessary to provide a service you request, or where disclosure is required or permitted by law, regulation, court process, professional obligation or a lawful investigation.
7. Service providers and processing outside Canada
The AI-assisted service and some other technology or communications providers may process or store personal information outside Alberta or outside Canada. When personal information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement or other authorities in accordance with applicable law.
Elboniel remains responsible for personal information under its control and uses reasonable contractual, administrative and technical measures appropriate to the service and sensitivity of the information. You may contact Privacy Officer to ask about Elboniel's policies and practices relating to service providers outside Canada, including the countries in which the service provider may process or store information.
8. Security safeguards
Elboniel uses reasonable administrative, technical and physical safeguards appropriate to the sensitivity of the information. The assessment system is designed to restrict administrative access, keep uploaded assessment documents outside the public WordPress Media Library, record significant actions, and require human approval before substantive reports are released.
No internet transmission or information system can be guaranteed to be completely secure. Elboniel therefore cannot promise absolute security, but it will maintain and review safeguards that are reasonable for the information in its custody or control.
9. Retention and secure disposal
Elboniel retains personal information only for as long as reasonably required for the purpose for which it was collected and for applicable legal, regulatory, professional, security and records-management requirements.
For the preliminary assessment system, the proposed production retention schedule is:
• abandoned, unsubmitted assessment drafts: securely purged after 30 days of inactivity;
• closed preliminary assessments that do not become retained-client matters: personal assessment content de-identified after 365 days, unless a retention hold applies; and
• retained-client matters: excluded from automatic assessment-engine deletion and retained in accordance with applicable professional and legal record-retention requirements.
Where professional rules require a longer retention period, those rules prevail. Information no longer required will be securely destroyed, deleted or de-identified as appropriate.
10. Access, correction and privacy requests
Subject to applicable law, you may request access to personal information Elboniel holds about you and ask that inaccurate or incomplete information be corrected. You may also ask questions about Elboniel's privacy practices or raise a privacy concern.
Elboniel may require a written request and enough information to verify your identity before disclosing or changing personal information. A request for deletion does not necessarily require immediate deletion where Elboniel is permitted or required to retain records for legal, regulatory, professional, security, contractual or dispute-resolution purposes.
Privacy requests may be submitted through https://elboniel.ca/privacy-request/ or by contacting Privacy Officer at assessment@elboniel.ca.
11. Privacy incidents
Elboniel maintains procedures for responding to suspected privacy or security incidents. Where an incident creates a risk that requires notification under applicable privacy law, Elboniel will take the steps required by law, which may include reporting the matter to the appropriate privacy regulator and notifying affected individuals.
12. Information about minors
Some Canadian immigration matters involve children or other minors. A parent, legal guardian or person with appropriate authority should provide a minor's personal information where consent or authority is required. Elboniel may request evidence of authority before disclosing information or acting on a privacy request involving a minor.
13. Website technical information and cookies
The website may collect limited technical information needed for security, functionality and administration, such as IP address, browser or device information, timestamps and server logs. Essential cookies may be used to operate website and assessment functions. If Elboniel enables non-essential analytics, advertising or marketing technologies, it will provide appropriate notice and consent choices where required.
14. Preliminary assessment and professional engagement
Submitting a preliminary assessment does not by itself mean that Elboniel has agreed to represent you, prepare an application or act as your authorized representative. If Elboniel provides a professional consultation or otherwise agrees to provide immigration or citizenship consulting services, additional professional obligations may apply. Representation or application-preparation services will be governed by the applicable engagement process and written agreement.
15. Privacy contact
Privacy inquiries are handled by Privacy Officer.
Email: assessment@elboniel.ca
Privacy request form: https://elboniel.ca/privacy-request/
If you are not satisfied with Elboniel's response to a privacy concern, you may have the right to contact the Office of the Information and Privacy Commissioner of Alberta or another applicable privacy regulator.
16. Changes to this notice
Elboniel may update this Privacy Notice when its practices, service providers, technology or legal obligations change. Material changes will be reflected in a new version. The assessment system records the privacy-policy version associated with a submitted assessment.
Version: draft-2026-09-26-ai-v1