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2Mig Terms of Service

Status: draft for counsel review — must not be published as-is Document version: `terms/v2-draft` Effective date: to be set on publication Provider: QAIT Inc., a Delaware C Corporation, `[REGISTERED ADDRESS]`. Contact: `[SUPPORT EMAIL]` · `[SUPPORT URL]`

Note for the team, not for the customer. Every `[BRACKETED]` value is unresolved. Sections 3, 6, 10 and 12 are the ones a lawyer must sign off on. Annex A is a copy of facts held in the corridor manifests in `packages/domain/src/corridors/` — if a manifest changes, this annex is stale. Two copies of one fact are how we have already broken seven screens. This document describes a service that is not yet on sale. No corridor has `available: true` outside demo mode (`apps/api/src/cases/catalogue.ts`), document intake and profile intake are switched off, and there is no payments module — so "order confirmation", which this document treats as the authoritative disclosure surface, does not exist yet. It must exist, and must carry the per-corridor disclosures named here, before a word of this is published.

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1. About these Terms

These Terms govern your use of 2Mig (the "Service") and form an agreement between you and QAIT Inc. ("2Mig", "we", "us"). By creating a case, uploading a document or paying a fee, you accept them.

You must be 18 or older to use the Service on your own behalf. You may create a case for another person — including a child — only if you are lawfully entitled to act for them and you have their information accurately.

2Mig is a private company. We are not an embassy, a consulate, a visa application centre, an immigration authority, an airline or a law firm. We do not decide visa applications, we do not influence them, and we cannot make an authority act faster.

2. What we do

2Mig prepares visa and travel-authorisation applications for a defined set of routes. We call each route a corridor: a country of departure, a destination, and one visa class. What we do differs by corridor, and the annex to these Terms states, for each corridor we offer:

We only sell corridors listed as available in your order confirmation. If a corridor is not listed there, we are not offering it to you, whatever else you may have read on our website or heard from us.

The following is always true and is not a matter of what you paid for:

3. Who lodges the application, and on what authority

Where the rules of the destination country and its official system allow it, and where the annex to these Terms says so for your corridor, we prepare your application and lodge it, acting as your representative. Where they do not, we prepare the application and you lodge it yourself. Which of the two applies to your case is stated in the annex and again in your order confirmation, before you pay.

Read the annex before you read the rest of this section. On every corridor in the annex today, you lodge the application yourself. The rest of section 3 describes how we act when we lodge for you, and it applies to no corridor currently listed.

This is a deliberate structure, and it has limits we will not cross.

### 3.1 Your authorisation

Where we lodge an application for you, we ask you first to grant a written submission mandate. The mandate is specific: it names your case, the actions you authorise, the version of the mandate text you read, and an expiry date. We record it in the case journal, which we do not edit after the fact.

A mandate covers only the actions it names. We ask for the narrowest set the corridor needs — to lodge the application, and where relevant to collect the result from the portal or operator. Authorising one does not authorise the other.

You can revoke the mandate at any time before submission, in the app, in one action. We do not ask why. If the mandate is missing, expired, revoked, or does not cover the action you are looking at, we do not act, and the software enforces that check rather than leaving it to a person to remember.

### 3.1a Accounts we create, and the address notices go to

Some official systems require an account before an application can be lodged, and some let whoever lodges the application name the address that notices are sent to. Where your corridor works that way and you have authorised it, we may:

Each of these is authorised separately, on the same terms as any other mandate in section 3.1: named, recorded, expiring, and revocable in one action. Granting one does not grant the other, and neither is implied by asking us to prepare or lodge your application.

What this means in plain terms, because it is easy to under-state. An account we create for you on an address we operate is an account we can control: a password reset for that account is sent to us, not to you. We do not treat that as ownership. You may ask us at any time to hand the account over by changing its address to your own, and we will. We tell you this before you authorise it, not after.

What it does not change. Using an address we operate does not make us the applicant. The application is yours, the declarations in it are yours, and section 3.2 applies to an account we created exactly as it applies to one you created yourself.

Where notices reach us and not you, we pass them on. We will not keep a decision, a refusal, or a request for further documents to ourselves; you get it from us without being asked, and you may ask us at any time to send the portal's own notices to your address as well.

### 3.2 What a mandate never covers

Even with a valid mandate, we will not:

### 3.2a What we cannot undo

Where you have authorised us to hold your portal credentials, one limit is not a choice of ours but a fact: deleting them here does not remove your password from the portal itself. Your own copy stays with that portal, and only you can change it. We say this before you authorise it, not after.

### 3.3 What we are not claiming

We are not an accredited commercial intermediary under Article 45 of the Schengen Visa Code, and we do not describe ourselves as one. We are not an external service provider under Article 43. Our authority to act comes from you and from nothing else — it does not oblige any consulate or visa centre to accept an application from our hands, and where an operator declines to deal with a representative, you lodge the application yourself.

Your authorisation to us is independent of our standing with any operator. When you authorise us to act, that authorisation is complete between you and us, and it does not depend on our having any agreement, accreditation or arrangement with a visa centre, portal operator or consulate. We do not need their permission to act for you, and we do not claim to have it.

The same fact read the other way, which is the half that matters to you. Because our authority comes from you alone, it binds you and us — and nobody else. It does not oblige any operator to accept an application from us, to recognise an account we created, or to treat our involvement as authorised on their side. An operator's own rules may restrict what a representative may do, and if they do, those rules apply to your application regardless of what these Terms say. Where that happens we tell you and you lodge the application yourself; section 9 covers what that means for your fee.

4. What you are responsible for

You provide information that is complete, accurate and current, and documents you are entitled to share. You review the prepared application before it is lodged — and where we lodge it, your confirmation of that review is what starts the submission.

You attend, in person, anything the authority requires you to attend: appointments, interviews, biometric enrolment.

You respond to our requests about your case. If required information or documents do not arrive, we cannot continue; section 9 explains what happens then.

We check your data against published requirements. We do not verify that your documents are genuine, and we are not able to. Submitting false or misleading information to an authority is your act and can carry consequences — refusal, entry bans, prosecution — that we can neither predict nor mitigate.

5. Readiness checks and what they are not

2Mig shows you which requirements your case meets and which it does not, with the source of each requirement.

This is not a prediction of whether you will get a visa. Today we publish no approval probability, score or odds of any kind. If we ever publish an estimate of likelihood, it will be published with its uncertainty interval and with what it was calibrated against — and no price or refund we offer will ever depend on it. Where a requirement in our rules has not yet been verified against the primary source, we say so on the screen rather than imply confirmation.

Our checks are not legal advice or immigration advice.

6. Fees and payment

Your order confirmation states each amount separately:

How the government fee reaches the authority depends on the route, and your order confirmation says which. There are two ways, and only two:

In neither case are we your agent for payments. We never hold your money to pass on to somebody else: either you pay the authority directly, or you buy a service from us at a price that already covers what it costs us to provide.

A government fee is never refunded, whichever way it was paid. Where you paid it yourself, we never had it. Where it was in our price, it is gone the moment the authority takes it — so our guarantees return a percentage of our service fee and never of the fee we paid on your behalf.

For some corridors the government fee is zero, in which case your entire payment is our service fee and we say so plainly.

We charge for our work, not for an outcome. Payment of a service fee buys preparation, checks and submission where applicable — not a visa.

Payment methods, and the point at which a fee becomes payable, are shown at checkout. `[COUNSEL/FINANCE: payment provider, currency of settlement, VAT treatment, receipt obligations under Kazakhstan law.]`

7. Cancellation and refunds

The Refund & Cancellation Policy applies and is part of these Terms. In short: what is refundable depends on the stage your case has reached and on the specific corridor, and your order confirmation states the outcome before you pay.

A refusal by an authority does not by itself create a right to a refund. We do not offer a "money back if refused" product, and we do not tie any refund to our own assessment of your case.

8. Your documents, and what we may do with them

You keep all rights in everything you upload.

We use your documents and data to run your case: to check requirements, prepare the application, lodge it where applicable, and support you. Section 4 of the Privacy Policy lists who else can receive them.

Improving the Service. You grant us a non-exclusive, worldwide, royalty-free licence to use material you provide, and records of what happened in your case, to operate, test, secure and improve the Service — including to develop and evaluate the rules, models and automated checks we use. Where we use data for improvement rather than for your case, we use aggregated or de-identified data wherever it will do the job.

What this licence expressly excludes. We do not use, and this licence does not cover, identity and financial documents for the development, training, fine-tuning or evaluation of models. That means passport and ID scans and photographs, bank statements and other financial evidence, biometric data, selfies, and any other document listed as excluded in section 5 of the Privacy Policy. Those are used for your case and for nothing else. We do not sell your data, and we do not sublicense it for anyone else's model training.

The distinction is deliberate: what teaches us anything is the outcome of a case against a known set of facts, not the scan of your passport.

Automatic checks of supporting documents. By accepting these Terms you agree that the content of your supporting documents — bank statements, employment and income certificates and similar — is read by an AI model provider, on servers outside Kazakhstan, to check it against your corridor's requirements, as section 5 of the Privacy Policy describes. Your passport, ID, photographs and biometric data are never sent. You can withdraw this consent at any time in your account settings; a specialist then checks those documents by hand, which takes longer.

9. When we pause, decline or cancel a case

We may pause or stop work on a case, and will tell you which of these applies:

We will state the reason and the refund outcome under the Refund & Cancellation Policy. We do not silently abandon a case.

You may stop using the Service at any time. Closing your account does not withdraw an application already lodged with an authority — only the authority can act on that, and we will tell you how to contact it.

10. Limits of our responsibility

We are responsible for our own work: preparing your case with the care we describe, telling you the truth about its status, and keeping your data as described in the Privacy Policy.

We are not responsible for the decision on your application, for an authority's or operator's timing, for entry refused at a border, or for travel and accommodation you booked before you held a visa. Do not buy non-refundable travel on the assumption of an approval.

Where documents move physically, they are handled by couriers and visa centres we do not operate. We will tell you which one, and give you the evidence you need to pursue them, but their loss or delay is theirs.

11. Complaints and corrections

If you believe a piece of data, a fee, a status or a refund decision is wrong, write to `[SUPPORT EMAIL]` with your case ID. We investigate against the case journal and the payment record, and we tell you what we found — including when the answer is that we were wrong.

12. Governing law and disputes

These Terms are governed by the law of the Republic of Kazakhstan. Disputes are subject to the courts of `[CITY]`, Republic of Kazakhstan, after an attempt to resolve the matter directly through the complaints process in section 11.

Nothing here removes a right you have as a consumer under Kazakhstan law.

We do not require you to waive access to the courts, and we do not impose mandatory arbitration or a class-action waiver.

13. Language

These Terms are published in `[LANGUAGES]`.

14. Changes

We may change these Terms. We will publish the new version with its own version identifier and effective date, and give notice of material changes before they take effect. A case in progress is governed by the version you accepted, and the version you accepted is recorded with the case — not replaced by the current one.

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Annex A — What we do, by corridor

Rows one and two are a copy of facts held in the corridor manifests; `submissionMode` and `fees` in the manifest are the source of truth, and this table must be updated in the same commit as a manifest. Row three is a company decision with no manifest behind it.

| Corridor | Covers | Who lodges | Fees payable to others | Offered for sale |
|---|---|---|---|---|
| Kazakhstan → Sri Lanka | ETA — tourism, family visit, transit | You lodge. We prepare the application and check requirements. | Government fee: none for Kazakhstan citizens `[VERIFY against the published country list before publication]` | Not yet. Three conditions are open: a named corridor reviewer with a published rules package, three primary-source facts still unverified, and data residency |
| Kazakhstan → Schengen | Uniform short-stay visa, type C | You lodge. We prepare the application and check requirements. | Government fee EUR 90; EUR 45 reduced for children aged 6–12 and certain categories (Article 16). Children under 6 are exempt `[VERIFY — Article 16(4); this exemption is missing from the manifest and must be added there first]`. Separately, a visa centre may charge its own service fee, capped at EUR 45 by Article 17 — you pay that to the centre, not to us | No. No corridor reviewer and no legal opinion on the corridor |
| Kazakhstan → United States | — | Not offered. | — | No. We do not serve this corridor. It is deferred pending a separate legal opinion, and our public pages do not collect enquiries for it |

Every corridor we currently have is "you lodge". The representative model in section 3 is built in the software and will be switched on one corridor at a time, and only when that corridor's own condition is met. Those conditions differ: for Sri Lanka the portal already permits a third party to lodge — confirmed on 2026-09-19 from the Department of Immigration & Emigration's own site, which names "By Third party" as an official submission method, allows the third party to pay the fee, and sends the acknowledgement to the address requested in the application — so what is missing is a live pilot; for Schengen what is missing is confirmation from the specific visa centre that it accepts a representative — and even then it can only apply to applicants whose biometrics are already on record within the 59-month window of Article 13(3), because otherwise personal appearance is required regardless of who we are.

Until then, section 3 describes a capability that applies to no corridor on this list, and your order confirmation will say "you lodge".

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On section 3.1a, by corridor. Sri Lanka needs no account at all: the contact address is a field on the application form, so naming an address we operate is an ordinary use of the form. VFS Global and TLScontact both require an account before an appointment can be booked, and whether an intermediary may create one is exactly the question left open in section 3.3's counsel note. Section 3.1a is therefore not in force on any corridor in this annex, and must not be switched on for a VFS or TLScontact route before that question is answered.

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Counsel checklist

  1. Section 3: form of power of attorney under Kazakhstan law; whether in-app
  2. confirmation suffices or a notarised instrument is needed.
  3. Section 3.3: wording limits so that we are not holding ourselves out as a
  4. legal adviser, an accredited intermediary, or as acting for a consulate.
  5. Section 6: confirm that not touching government fees keeps us outside
  6. payment-agent and money-transmission characterisation.
  7. Section 8: whether improvement use needs a separate consent record under Law
  8. No. 94-V, and how consent withdrawal interacts with the licence.
  9. Section 10: liability cap against the consumer-law floor.
  10. Section 12: venue enforceability against a consumer; position for
  11. non-resident customers.
  12. Section 13: prevailing language.
  13. Whether any licence, notification or registration is required in Kazakhstan
  14. for handling third parties' identity documents as a business.

Engineering checklist — gaps this document exposed

These are defects in the code or in the product, not drafting problems. The document is accurate as written; the system has to catch up before publication.

  1. `MANDATE_TERMS` does not contain the biometrics undertaking. Section 3.2
  2. promises we will not give your biometrics or attend an interview for you; the
  3. versioned mandate text in `packages/domain/src/schemas/mandate.ts` lists four
  4. exclusions and this is not one of them. Add it and raise the version to
  5. `mandate/v2` — a promise the customer never saw in the text they confirmed is
  6. not evidenced by it.
  7. `COLLECT_RESULT` is now described in section 3.1. Confirm the scope is
  8. actually needed at launch; if not, remove it from `MANDATE_SCOPES` rather than
  9. leave a granted-but-unused authority in a public contract.
  10. **`PAY_GOVERNMENT_FEE` remains in `MANDATE_SCOPES` and in the published
  11. OpenAPI schema.** Section 6 says government money never passes through us. The
  12. decision not to use the scope is written down, not enforced — `checkMandate`
  13. will happily return valid for it. Either remove the enum member or add an
  14. explicit refusal so the code says what the contract says.
  15. The order confirmation still has no consumer. This document names it as
  16. the disclosure surface nine times, and `OrderConfirmation` in
  17. `packages/domain/src/schemas/order.ts` models it — lines, `throughUs`,
  18. refund rule, submission mode, terms version — but nothing in `app.ts` or
  19. `server.ts` constructs one and there is no route. So every sentence here
  20. beginning "your order confirmation states" describes a screen that does not
  21. exist yet. The payments module DOES exist since 2026-09-06 (Stripe checkout,
  22. webhook, refunds) and is unwired for want of keys.
  23. **Section 2 of the Refund Policy refers to "before we begin preparing your
  24. case".** The only comparable recorded event today is `ELIGIBILITY_EVALUATED`.
  25. Decide the event, then write the clause against it.