Terms of Service

Aion Automation LTD (trading as Aion) · Registered in England and Wales, company no. 17285913 · Registered office: 66 Paul Street, London EC2A 4NA · Contact: contact@immigration.aionautomation.org

Version: 2026‑10‑15 · Effective Date: 15 October 2026 · previous versions available on request

Terms of Service (including the Data Processing Agreement in Schedule 1).

Important — read carefully. Before using the Service you must read and accept these Terms. If you do not agree, do not create an account or use the Service.

1. Acceptance of Terms

1.1 By clicking “I Agree”, creating an account, or otherwise accessing or using the Aion platform and related services (the “Service”), you (“Customer”, “you”, “your”) agree to be bound by these Terms of Service (the “Terms”) and the Data Processing Agreement set out in Schedule 1, which together form the entire agreement between you and Aion Automation LTD (trading as Aion) (“we”, “us”, “our”).

1.2 If you are entering into these Terms on behalf of a company or other legal entity, you represent that you have authority to bind that entity. In that case “Customer” means that entity.

2. Definitions

In these Terms:

  • “Authorised User” means any individual authorised by you to access and use the Service on your behalf, who must be appropriately qualified and supervised in accordance with your professional regulatory obligations.
  • “Application Password” means the password for the specific UKVI/Home Office online application form that you supply to enable a Fill. It is not your full gov.uk account credentials.
  • “Client Data” means all personal data, documents and other information relating to your clients (visa applicants and their family members) that you upload to or process via the Service.
  • “Confidential Information” has the meaning given in clause 10.
  • “Extracted Summary” means the structured data that the AI produces from Client Data after document extraction.
  • “Fill” means the process by which the Service, using a browser session self‑hosted on our own infrastructure, enters Extracted Summary data and your representative details into a UKVI/Home Office online application form. A Fill is “completed” when the AI reaches the Declaration page and stops.
  • “Job” means a single processing instance (extraction and/or Fill) initiated by you.
  • “Output” means any data, text, cover letters, form entries, reports (including missing‑information reports) or other materials generated by the Service, including AI‑generated drafts and Extracted Summaries.
  • “Regulated Professional” means a solicitor regulated by the Solicitors Regulation Authority (SRA), an immigration adviser registered with the Immigration Advice Authority (IAA) (or its successor), or any other person or entity authorised or exempt under applicable UK law to provide immigration advice and services.
  • “Special Category Data” has the meaning given in UK GDPR and includes health data, biometric data, and data relating to criminal convictions and offences.
  • “Usage Ledger” means the internal, append‑only record maintained by us for billing and analytics purposes, as described in clause 3.4 of the DPA.

3. Eligibility and Customer Warranties

You represent, warrant and undertake that:

3.1 You are a Regulated Professional (or a law firm or organisation employing or instructing Regulated Professionals) authorised to provide immigration advice and services under applicable UK law.

3.1A Business customer. You are entering into these Terms wholly or mainly for the purposes of your trade, business or profession and not as a consumer. You acknowledge that consumer protection legislation — including the cancellation, cooling‑off and subscription‑renewal rights available to consumers under the Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, the Consumer Rights Act 2015 and the Digital Markets, Competition and Consumers Act 2024 — does not apply to this agreement.

3.2 You have obtained all necessary consents, authorisations and permissions from data subjects (your clients/applicants) to process their personal data, including Special Category Data, via the Service, and you will maintain records of such consents.

3.3 Every Authorised User is properly qualified, supervised and authorised by you to use the Service in connection with immigration applications.

3.4 You will ensure that all Outputs are thoroughly reviewed by a qualified Regulated Professional before any reliance, use, amendment or submission to UK Visas and Immigration (UKVI), the Home Office or any other authority or third party.

3.5 You are solely responsible for the accuracy, completeness, quality and regulatory compliance of all Client Data you input and all Outputs you use or submit.

3.6 You will comply with all applicable laws, regulations and professional conduct rules (including SRA or IAA requirements) when using the Service.

3.7 You will not use the Service for any unlawful purpose or in any manner that could bring the Service or us into disrepute.

4. Licence Grant and Access

4.1 Subject to these Terms and payment of applicable fees, we grant you a limited, non‑exclusive, non‑transferable, non‑sublicensable, revocable licence to access and use the Service solely for your internal business purposes in connection with providing immigration advice and services to your clients.

4.2 You may authorise Authorised Users to access the Service on your behalf. You are responsible for all activity under your account (including any Jobs initiated) and must maintain the confidentiality of login credentials. You must promptly notify us of any unauthorised use.

5. Use of the Service and Acceptable Use

5.1 You must use the Service only in accordance with these Terms and all applicable laws.

5.2 Prohibited Uses. You must not (and must not permit any Authorised User to):

  • Attempt to submit any application or form to UKVI/gov.uk via automated means using the Service (the Service is designed to stop before submission).
  • Reverse engineer, decompile, disassemble or create derivative works from the Service.
  • Use the Service to process data for any purpose other than legitimate immigration application preparation for your clients.
  • Input any unlawful, infringing or misleading data.
  • Share login credentials or allow access by anyone who is not an Authorised User.
  • Use the Service in any way that violates the rights of any third party or applicable data protection or immigration laws.

5.3 Credential Security. You must keep your sign‑in credentials — your Google account, and any one‑time sign‑in links we email you — and your Stripe billing portal credentials secure. You must also protect the Application Password you supply for each Fill. We will handle that password in accordance with the confidentiality and data processing obligations in these Terms (see clause 10 and Schedule 1). The login link for each application is sent to your email address; the AI agent does not have access to your email and cannot initiate or log in to an application without your action.

6. AI‑Powered Features and Important Disclaimers

The Service uses artificial intelligence, including large language models provided by third parties (such as Anthropic), to extract structured data from documents and to drive a browser self‑hosted on our own infrastructure (no third‑party cloud browser service is involved) that fills in the official gov.uk application form.

YOU ACKNOWLEDGE AND AGREE THAT:

6.1 Outputs are AI‑generated drafts only. They are provided as a starting point to assist you in your professional work.

6.2 AI systems can produce errors, omissions, inaccuracies, hallucinations or content that appears plausible but is factually incorrect or incomplete.

6.3 We make no warranty, representation or guarantee whatsoever regarding the accuracy, reliability, completeness, suitability or fitness for any particular purpose of any Output.

6.4 You must independently and thoroughly verify every Output against the original source documents, applicable law, Home Office guidance and your own professional judgment before any use, amendment or submission.

6.5 The Service does not provide legal advice, immigration advice or any form of professional advice. We are not your lawyer, your client’s lawyer or a regulated immigration adviser.

6.6 You remain solely and fully responsible for all professional, regulatory and legal obligations in respect of any advice given to clients and any applications submitted, regardless of any assistance provided by the Service.

6.7 We exclude all liability for any loss, damage, refusal of application or other consequence arising from your reliance on any Output or your failure to review it properly.

7. Fees, Billing and Payment

7.1 Subscription Plans. Access to the Service requires a paid subscription or Pay‑As‑You‑Go Fill credits (clause 7.1B), unless you are using a time‑limited Demo tier. The available plans and the number of completed Fills included in each billing period are displayed on our pricing page. As at the Effective Date the plans are:

  • Solo – 10 completed Fills per billing period
  • Team – 25 completed Fills per billing period

Larger or bespoke plans are available on request — contact us at contact@immigration.aionautomation.org.

A Fill is counted towards your allowance when it starts. A Fill that you stop more than two minutes after it started still counts; a Fill that fails (ends without reaching the Declaration page for a reason other than you stopping it) is credited back to your allowance automatically. Unused Fills in your allowance roll over to subsequent billing periods for as long as your subscription remains active; Fills included in a free trial do not roll over, and all accrued Fills lapse when your subscription ends (clause 7.3).

The Demo tier is a live environment that performs real Fills against the official UKVI/Home Office application form; it is not a sandbox and all actions have real‑world effect.

7.1A Free Trials. Where we offer a free trial (as displayed at checkout), the trial runs for the advertised period (currently 14 days) from the start of the subscription. A valid payment method is taken at checkout and the first subscription fee is charged automatically when the trial ends, unless you cancel before then via the billing portal. It is your responsibility to cancel before the end of the trial if you do not wish to be charged. Any trial‑ending reminder we send is a courtesy; it is not a condition of the charge, and non‑receipt of a reminder does not entitle you to a refund of a fee properly charged at the end of a trial. A trial includes a fixed allowance of Fills (as displayed at checkout, currently 5), regardless of the plan selected; the plan’s full monthly allowance applies from the first paid billing period. One trial per firm: we may decline, or end early, a trial where the same firm or the same payment card has already been used for one. Client Data uploaded during a trial is handled identically to a paid subscription, including the deletion schedule in Schedule 1.

7.1B Pay As You Go. As an alternative to a subscription, you may use the Service on a pay‑as‑you‑go basis. Each Fill consumes one Fill credit. Credits are purchased individually at the price displayed at checkout (currently £99.99 per Fill). Pay‑as‑you‑go use does not include a free trial or any free credits, and an available credit is required to begin processing an application. A credit is consumed when a Fill starts. A Fill that you stop more than two minutes after it started still consumes its credit; a Fill that fails (ends without reaching the Declaration page for a reason other than you stopping it) has its credit returned automatically. Credits do not expire but are non‑transferable, hold no cash value and are non‑refundable except as required by law. Subscribers may also purchase credits alongside a subscription; such credits are consumed only after the plan's monthly Fill allowance for the period is exhausted, and otherwise carry the same terms. Per‑Fill pricing may change at any time; the price displayed at checkout applies to that purchase.

7.2 Fees. Fees are payable in advance via Stripe (or such other payment processor as we may use) and are non‑refundable except as expressly stated or required by law.

7.3 Auto‑Renewal and Cancellation. Subscriptions automatically renew at the end of each billing period unless cancelled. You can cancel your subscription at any time through the Stripe billing portal (accessible from your account settings); cancellation takes effect at the end of the current billing period. Cancellation stops future renewals only. It does not end the current billing period early, and no refund or pro‑rata credit is given for the unexpired part of a period already paid for or for a period in which you did not use the Service. Unused Fills roll over between billing periods while your subscription remains active (clause 7.1). After cancellation you keep access, and any accrued Fills, until the end of the period already paid for, at which point all remaining Fills lapse. Fills are non‑transferable and hold no cash value.

7.4 Taxes. You are responsible for all applicable taxes, including VAT. We may adjust fees on reasonable notice.

8. Intellectual Property

8.1 Our Intellectual Property. We (and our licensors) retain all right, title and interest in and to the Service, including all software, technology, AI models/prompts (to the extent not specific to your data), documentation, and any improvements, modifications or derivative works. You receive only the limited licence set out in these Terms.

8.2 Your Intellectual Property and Data. You retain all right, title and interest in and to Client Data and in the final Outputs you create and submit (as distinct from the raw AI‑generated drafts).

8.3 Licence to Us. You grant us a non‑exclusive, royalty‑free, worldwide licence to use, reproduce and process Client Data solely as necessary to provide the Service.

9. Data Protection

The processing of personal data in connection with the Service is governed by the Data Processing Agreement set out in Schedule 1, which forms an integral part of these Terms. By accepting these Terms you agree to the Data Processing Agreement.

10. Confidentiality

10.1 Each party (“Receiving Party”) agrees to keep confidential all non‑public information received from the other party (“Disclosing Party”) in connection with the Service (“Confidential Information”) and to use it only for purposes of performing under these Terms.

10.2 Confidential Information includes, but is not limited to, Client Data, the Application Password, business plans, pricing and the provisions of these Terms.

10.3 The obligation of confidentiality does not apply to information that:

  • (a) is or becomes public through no fault of the Receiving Party;
  • (b) was lawfully in the Receiving Party’s possession before disclosure;
  • (c) is independently developed by the Receiving Party without use of Confidential Information; or
  • (d) is required to be disclosed by law, regulation or court order, provided the Receiving Party gives the Disclosing Party prior notice (where legally permitted) and cooperates in any effort to limit the disclosure.

11. Limited Warranties and Disclaimers

11.1 The Service is provided “as is” and “as available” without any warranties of any kind, whether express, implied, statutory or otherwise, including warranties of merchantability, fitness for a particular purpose, title or non‑infringement.

11.2 We do not warrant that the Service will be uninterrupted, error‑free, or free of viruses or other harmful components, or that any Output will be accurate or suitable for your needs.

12. Indemnity

12.1 You agree to indemnify, defend and hold harmless Aion Automation LTD, its officers, directors, employees, agents and affiliates from and against any and all claims, damages, losses, liabilities, costs and expenses (including reasonable legal fees) brought by a third party (including any data subject, client or applicant) arising out of or relating to:

  • (a) your breach of these Terms, including any breach of the warranties in clause 3;
  • (b) any Client Data or content you upload or provide;
  • (c) any advice you give or application you submit using Outputs;
  • (d) your use of the Service in breach of applicable law.

12.2 This indemnity shall not apply to the extent the claim is caused by our breach of these Terms or our negligence.

13. Limitation of Liability

13.1 Nothing in these Terms excludes or limits our liability for: (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; or (c) any other liability that cannot be excluded or limited by applicable law.

13.2 Subject to clause 13.1, our total aggregate liability to you under or in connection with these Terms (whether in contract, tort including negligence, or otherwise) shall not exceed the total fees paid by you to us in the twelve (12) months immediately preceding the claim.

13.3 Subject to clause 13.1, we shall not be liable for any indirect, incidental, special, consequential or punitive damages, or any loss of profits, revenue, data, business opportunity, goodwill or anticipated savings, whether or not advised of the possibility of such loss, and whether arising in contract, tort or otherwise. This exclusion applies in particular to any loss arising from immigration application outcomes, regulatory action against you or claims by your clients.

14. Term, Termination and Suspension

14.1 Term. These Terms commence on the date you first accept them or access the Service and continue until terminated by either party.

14.2 Termination by You. You may cancel your subscription at any time as described in clause 7.3. Upon cancellation your access continues until the end of the prepaid billing period, after which your right to access the Service ceases.

14.3 Termination or Suspension by Us. We may suspend or terminate your access immediately if: (a) you breach these Terms; (b) you fail to pay fees; (c) we reasonably believe your use poses a risk to the Service, other users, or legal compliance; or (d) we are required to do so by law. Where practicable we will give you prior notice.

15. Effects of Termination

Upon termination or expiry, your right to access the Service ceases. We will, in accordance with the Data Processing Agreement, delete or return Client Data as instructed by you (or as otherwise required). Provisions that by their nature should survive (including clauses 8, 9, 10, 12, 13, 16, 17 and Schedule 1) shall survive termination.

16. Governing Law and Dispute Resolution

These Terms and any dispute arising out of or in connection with them shall be governed by and construed in accordance with the laws of England and Wales. The courts of England and Wales shall have exclusive jurisdiction to settle any such dispute.

17. General Provisions

  • Changes to Terms. We may update these Terms from time to time. Material changes will be notified to you by email or in‑app notice. Continued use after the effective date constitutes acceptance. For material adverse changes you may terminate without penalty within 30 days of notice.
  • Notices. Notices under these Terms may be given by email to the addresses in your account or as otherwise agreed. Notices to us must be sent by email to contact@immigration.aionautomation.org and by post to Aion Automation LTD, 66 Paul Street, London EC2A 4NA, marked for the attention of ‘Legal Notices’. Notices are deemed received on the next business day after sending.
  • Entire Agreement. These Terms (including Schedule 1) constitute the entire agreement between the parties and supersede all prior agreements relating to the subject matter.
  • Severability. If any provision is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect.
  • Assignment. You may not assign these Terms without our prior written consent. We may assign to an affiliate or successor.
  • Force Majeure. Neither party shall be liable for delays or failures due to circumstances beyond its reasonable control.
  • Third Party Rights. These Terms do not create any rights enforceable by any third party under the Contracts (Rights of Third Parties) Act 1999.

Acceptance

By clicking “I Agree”, creating an account, or otherwise accessing the Service, you confirm that you have read, understood and agree to these Terms of Service (including the Data Processing Agreement in Schedule 1) and that you are authorised to bind the Customer entity.

Aion Automation LTD
Contact: contact@immigration.aionautomation.org
Version: 2026‑10‑15 · Effective Date: 15 October 2026

Schedule 1 — Data Processing Agreement

This Data Processing Agreement (“DPA”) forms part of the Terms of Service between the Customer (“Controller”) and Aion Automation LTD trading as Aion (“Processor”). It is entered into to comply with Article 28 of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

Schedule 1 · 1. Definitions and Interpretation

Terms defined in the Terms of Service have the same meaning in this DPA. In addition: “Personal Data”, “Processing”, “Controller”, “Processor”, “Data Subject”, “Personal Data Breach” and “Special Categories of Personal Data” have the meanings given in UK GDPR. “Credentials” means the Application Password and any other login details the Controller supplies for a Fill.

Schedule 1 · 2. Processing Details

Subject matter and duration of the processing:

The Processor will process Personal Data for the duration of the Customer’s subscription, but in respect of each Job the relevant Personal Data is retained only as set out below (typically no more than 24 hours). After termination or expiry of the subscription, all remaining Personal Data will be deleted or returned in accordance with clause 9.

Nature and purpose of the processing:

The processing is carried out to enable the Controller (a regulated immigration professional) to prepare UK visa and immigration applications more efficiently. This includes:

  • Uploading and temporarily storing Client Data.
  • Using AI to extract structured data from documents (the Extracted Summary).
  • Generating a missing‑information report.
  • Using a browser self‑hosted on the Processor’s infrastructure to fill in the official UKVI/gov.uk online application form (the Fill) with the Extracted Summary and the Controller’s representative details, while streaming a live view to the Controller.
  • Deleting all Job‑related data within a short automated retention window.

Categories of Data Subjects:

  • Visa and immigration applicants (clients of the Controller) and, where relevant, their family members or dependants.
  • The Controller’s personnel (Authorised Users and others whose representative details are processed).

Types of Personal Data processed:

  • Applicant Data: identity and contact details (name, date of birth, nationality, address, email, phone); passport and travel document details; immigration history and status; employment, education and financial information; family details; photographs and biometric data; health and medical information (Special Category Data); information relating to criminal convictions and offences; and any other supporting documents uploaded by the Controller.
  • Representative Data: Authorised User name, firm name, SRA/IAA registration number, email address, telephone number, firm address.
  • Credentials: the Application Password (processed transiently only).
  • Technical Data: IP address, browser user‑agent, session cookie (HMAC‑signed) and usage logs generated during a Job.

Schedule 1 · 3. Retention and Deletion

3.1 No Permanent Storage. The Processor does not maintain a client database. Client Data is held in ephemeral, per‑Job working folders.

3.2 Immediate Deletion of Original Files. Immediately after successful extraction, the original uploaded documents (PDFs, images, etc.) are permanently deleted. The only retained Client Data is the Extracted Summary.

3.3 24‑Hour Automatic Clean‑up. A scheduled process runs every hour and permanently deletes any Job folder that is older than 24 hours, including the Extracted Summary, screenshots, action/event logs, reports and metadata. Jobs that are still in progress are never deleted mid‑run. At any time the Controller may request earlier manual deletion of a Job. Residual copies of deleted data may persist for approximately seven (7) further days within the hosting provider’s rotating encrypted disk snapshots before expiring.

3.4 Usage Ledger. The Processor maintains an append‑only Usage Ledger for billing and business analytics. This Ledger records, per AI call: a timestamp, an opaque Job identifier, an opaque owner identifier, the account holder’s email address, the plan tier, the model name, token counts and cost. The Usage Ledger contains no applicant documents, no Extracted Summary and no other Client Data. It is accounting‑level metadata only, retained for up to six (6) years after the Customer’s account closes (tax and accounting records); on an erasure request the account holder’s identity is redacted from the Ledger and only the financial figures are retained.

3.5 Credentials. The Application Password (a password the Controller sets on the gov.uk application on behalf of its client) is held in memory solely for the duration of the Fill session, is injected directly into the instructions sent to the AI model and the self‑hosted browser, and is never written to disk or any database; it is masked out of the activity/event logs and the live event stream, and is not stored in the Controller’s browser. It is deleted from memory immediately after the Fill session completes (or fails). The login link for the application is sent to the Controller’s email address; the AI agent does not have access to the Controller’s email and cannot independently initiate or access a session.

Schedule 1 · 4. Processor’s Obligations

The Processor shall:

  • Process Personal Data only on documented instructions from the Controller (including with regard to transfers to a third country), unless required to do so by UK law (in which case the Processor shall inform the Controller of that legal requirement before processing, unless the law prohibits such information on important grounds of public interest).
  • Ensure that persons authorised to process the Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
  • Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, as described in clause 5.
  • Not engage another processor (sub‑processor) without prior specific or general written authorisation of the Controller, in accordance with clause 6.
  • Impose the same data protection obligations as set out in this DPA on any sub‑processor by way of a contract or other legal act, and remain fully liable to the Controller for the performance of the sub‑processor’s obligations.
  • Taking into account the nature of the processing, assist the Controller by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights under Chapter III UK GDPR.
  • Assist the Controller in ensuring compliance with the obligations pursuant to Articles 32 to 36 UK GDPR (security, breach notification, DPIA), taking into account the nature of processing and the information available to the Processor.
  • At the choice of the Controller, delete or return all Personal Data after the end of the provision of services relating to processing (subject to the retention provisions in clause 3), and certify in writing that this has been done, unless retention is required by UK law.
  • Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in Article 28 UK GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller (subject to clause 10).

Schedule 1 · 5. Security Measures

The Processor shall maintain appropriate technical and organisational measures, including, but not limited to:

  • Network and application security: all communications with the Service are encrypted in transit (HTTPS); sessions use a signed (HMAC‑SHA256) cookie to prevent forgery; rate limiting is applied (with stricter limits on login and Job creation); standard security headers (Content‑Security‑Policy, HSTS, X‑Content‑Type‑Options) are set.
  • AI‑Agent Sandboxing: during a Fill, the AI agent’s file system access is confined to its own Job folder. The self‑hosted browser is navigation‑restricted to gov.uk and the specific application URL supplied by the Controller; the agent cannot browse to any other domain.
  • Credential Protection: the Application Password is held only in memory, passed directly to the AI model and browser, never logged to disk or a database, and masked out of the activity/event logs and the live event stream; it is purged from memory upon session termination.
  • Infrastructure security: the hosting providers (Render for the web application; AWS for Job processing) employ physical, network and platform security controls. Each extraction and Fill runs in its own isolated, single‑use container with no inbound network access, destroyed together with its storage when the Job stage ends.
  • Access control: the Service requires sign‑in for paid tiers — Google sign‑in (OAuth) or a single‑use, expiring sign‑in link sent to your verified email address; demo access is password‑gated and time‑limited.

The Processor will review and update the security measures periodically and will make its security policy available on request.

Schedule 1 · 6. Sub‑processors

6.1 The Controller provides general written authorisation for the Processor to engage the following sub‑processors, whose identity, role, and location are listed below.

Sub‑processorProcessing ActivityData ReceivedLocation
Anthropic, Inc. (Claude API)AI extraction from documents and AI agent to drive the Fill.Document text/images (for extraction) and Fill instructions, including the firm’s representative details and the Application Password (transiently).United States
Render Services, Inc.Cloud hosting and infrastructure (web application).Runs the server (Applicant Data passes through transiently during upload and review); holds ephemeral working disks (Job folders) and the Usage Ledger.European Union (Frankfurt region)
Amazon Web Services (AWS) (S3 and ECS Fargate)Job processing infrastructure: per‑Job file storage, and the isolated, single‑use container that runs each extraction and Fill — including the self‑hosted browser that fills the gov.uk form.Uploaded client documents and per‑Job working files (Extracted Summary, screenshots, report) in a private, encrypted, access‑restricted storage bucket — deleted when the processing stage ends, with a 2‑day automatic deletion backstop. The Application Password and the Gov.uk login pass through the container in memory only.United Kingdom (London region)
Stripe, Inc.Payment processing, subscription management and billing.Customer email address, subscription details and payment method. No card data touches the Processor’s servers.United States
Google LLCAuthentication (OAuth)Email address and Google account ID.United States
Resend, Inc.Transactional email (one-time account sign-in links, welcome and subscription-confirmation notices, trial reminders, and the referral programme’s codes, dashboard links and payout notifications).Account and referrer email addresses and referral/payout details. No Client Data or applicant data.United States
Crisp IM SASIn-site support chat (the messenger widget on the website and Service pages).Messages and contact details submitted via the chat. No Client Data or applicant data unless the Controller includes it in a message.European Union

6.2 The Processor will maintain an up‑to‑date list of sub‑processors on its website or in the Service dashboard and will notify the Controller of any intended addition or replacement of a sub‑processor at least 14 days in advance. The Controller may object to a new sub‑processor on reasonable grounds related to data protection within that period. If the Controller objects and the Processor cannot accommodate the objection, the Controller may terminate the affected Service without penalty.

6.3 For each sub‑processor, the Processor has entered into (or will enter into) a written agreement that imposes data protection obligations substantially equivalent to those in this DPA.

Schedule 1 · 7. International Transfers

7.1 The sub‑processors listed above may process Personal Data in the United States and other countries outside the UK. The Controller acknowledges and agrees that such transfers are necessary for the provision of the Service.

7.2 The Processor shall ensure that any transfer of Personal Data to a third country is made in compliance with Chapter V of UK GDPR. The transfer mechanisms used will include, as applicable:

  • The UK International Data Transfer Agreement (IDTA) or the 2021 EU Standard Contractual Clauses together with the UK Addendum;
  • The UK Extension to the EU‑US Data Privacy Framework, where the relevant sub‑processor is certified and the transfer falls within its scope;
  • Where necessary, a documented Transfer Risk Assessment (TRA).

7.3 The Processor will, upon request, provide the Controller with copies of the relevant transfer safeguards.

Schedule 1 · 8. Special Category Data and Criminal Offence Data

8.1 The Controller acknowledges that the Client Data processed via the Service will routinely include Special Category Data and data relating to criminal convictions and offences.

8.2 The Controller is solely responsible for establishing and documenting a valid lawful basis and condition for processing such data under Articles 9 and 10 UK GDPR (and Schedule 1 DPA 2018 where applicable) and for ensuring appropriate safeguards are in place.

8.3 The Processor shall treat all Personal Data as confidential and shall apply enhanced security measures as described in its security policy.

Schedule 1 · 9. Personal Data Breach

9.1 The Processor shall notify the Controller without undue delay after becoming aware of a Personal Data Breach affecting Personal Data processed on behalf of the Controller.

9.2 The notification shall include, to the extent possible: (a) the nature of the breach; (b) the categories and approximate number of data subjects concerned; (c) the likely consequences; and (d) the measures taken or proposed to address the breach. The Processor shall cooperate with the Controller in investigating and mitigating the breach.

Schedule 1 · 10. Data Protection Impact Assessment and Consultation

Where a Data Protection Impact Assessment (DPIA) is required under Article 35 UK GDPR, or where the ICO must be consulted under Article 36, the Processor shall provide reasonable assistance to the Controller, taking into account the nature of the processing and the information available to the Processor.

Schedule 1 · 11. Deletion or Return of Personal Data

11.1 Subject to the automatic retention schedule in clause 3, upon termination or expiry of the subscription, or upon written instruction from the Controller, the Processor shall, at the Controller’s choice, securely delete or return all Personal Data (including any copies) and certify in writing that this has been done, unless retention is required by applicable law.

11.2 The Processor may retain the Usage Ledger for its legitimate business purposes (billing, accounting and tax records). The Usage Ledger contains no Applicant Data or other Client Data; the only Personal Data within it is the account holder’s email address and the opaque identifiers described in clause 3.4, which are retained on the terms of that clause and redacted on an erasure request. The Processor may also retain anonymised/aggregated data derived from the Service provided it cannot identify any data subject.

Schedule 1 · 12. Audit Rights

12.1 The Controller (or its appointed auditor, subject to reasonable confidentiality obligations) may, no more than once per calendar year (or more frequently if required by regulatory obligation or following a Personal Data Breach), audit the Processor’s compliance with this DPA.

12.2 Audits shall be conducted during normal business hours with at least 30 days’ prior written notice and in a manner that minimises disruption to the Processor’s business. The Processor may satisfy the audit request by providing the Controller with an executive summary of an independent third‑party security audit report or other objective evidence of compliance, instead of an on‑site inspection.

Schedule 1 · 13. Liability

Each party’s liability under this DPA shall be subject to the limitations and exclusions set out in the Terms of Service (in particular clause 13), except that nothing shall limit liability for breach of statutory data protection obligations where such limitation is prohibited by law.

Schedule 1 · 14. Contact

For data protection queries or to exercise rights under this DPA, contact the Processor at: contact@immigration.aionautomation.org or by post at Aion Automation LTD, 66 Paul Street, London EC2A 4NA.

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