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Privacy Policy

This document applies to the BOUSOL website, mobile application, wallet, and related services.

Effective dateAugust 31, 2026

Paon Bleu Inc., doing business as Bousol ("Bousol," "we," "us," or "our"), operates the website bousolapp.com and the Bousol mobile application (collectively, the "Platform"). This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you access or use our Platform and services.

By using our Platform, you agree to the collection and use of information as described in this Privacy Policy. If you do not agree, please do not access or use the Platform.

1. Who We Are

Paon Bleu Inc. is a registered Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN), Registration #31000274011519, headquartered in the United States. We provide digital financial services including remittances, savings circles (sòl/ROSCA), stablecoin wallet management, bulk disbursements, collections, treasury management, and compliance reporting, primarily serving the Haitian diaspora in the United States and Canada.

Contact Information:

2. Information We Collect

2.1 Information You Provide Directly

  • Account Registration: Full legal name, email address, phone number, date of birth, nationality, residential address
  • Identity Verification (KYC): Government-issued identification (passport, driver's license, national ID), selfie/photo for biometric verification, Social Security Number or Tax Identification Number (where required), proof of address
  • Transaction Information: Sender and recipient details, transaction amounts, payment method details, purpose of remittance
  • Financial Information: Bank account details, mobile money wallet information, payment card details (processed by our payment partners), ACH routing information, PayPal account identifiers
  • DeFi Activity: Deposit and withdrawal amounts, yield earned, pool participation data related to DeFi Savings features
  • Credit Activity: Credit requests, repayment history, cross-group lending participation
  • Communications: Messages, support requests, feedback, and other communications you send to us

2.2 Information Collected Automatically

  • Device Information: Device type, operating system, browser type, unique device identifiers
  • Usage Data: Pages visited, features used, time spent on the Platform, click patterns, navigation paths
  • Location Data: IP address, approximate geographic location (used for regulatory compliance and fraud prevention)
  • Cookies and Tracking Technologies: See Section 8 (Cookie Policy) below

2.3 Information from Third Parties

  • Identity Verification Providers: Results from KYC/AML screening services
  • Payment Partners: Transaction confirmation data from MoneyGram, Stripe, PayPal, banking partners (including UNIBANK), ACH networks, and other payment processors
  • Blockchain Data: Public transaction data on the Stellar blockchain network
  • Credit and Fraud Prevention Services: Risk scoring and fraud detection data

3. How We Use Your Information

We use the information we collect for the following purposes:

  • Provide Services: Process remittances, manage your wallet, facilitate sòl/ROSCA savings circles, execute disbursements and collections
  • Identity Verification: Comply with Know Your Customer (KYC), Anti-Money Laundering (AML), and Counter-Terrorism Financing (CTF) requirements
  • Regulatory Compliance: Meet obligations under FinCEN, state money transmitter laws, FINTRAC (Canada), and other applicable regulations
  • Fraud Prevention: Detect, investigate, and prevent fraudulent or unauthorized transactions
  • Communication: Send transaction confirmations, account alerts, security notifications, and (with your consent) marketing communications
  • Improve the Platform: Analyze usage patterns, troubleshoot issues, develop new features, and enhance user experience
  • Legal Obligations: Respond to legal process, enforce our terms, and protect our rights and the rights of others

4. Legal Bases for Processing

We process your personal information based on the following legal grounds:

  • Contractual Necessity: To perform our obligations under our Terms of Service and provide the services you requested
  • Legal Obligation: To comply with applicable laws, including AML/KYC requirements, tax reporting, and regulatory mandates
  • Legitimate Interest: To prevent fraud, ensure Platform security, improve our services, and conduct internal analytics
  • Consent: For marketing communications, non-essential cookies, and optional data processing activities. You may withdraw consent at any time.

5. How We Share Your Information

We do not sell your personal information. We share it only in the following circumstances:

5.1 Service Providers and Partners

  • Payment Processors: MoneyGram, Stripe, PayPal, and other payment partners that facilitate transactions on your behalf
  • Blockchain Infrastructure: Stellar Development Foundation and Stellar network validators (note: blockchain transactions are public by design)
  • DeFi Protocol Providers: Third-party lending protocols (e.g., Blend) used to facilitate DeFi Savings features
  • KYC/AML Providers: Identity verification and compliance screening services
  • Wallet Infrastructure: Privy, our embedded wallet provider, which facilitates non-custodial key management and user authentication
  • Cloud and Hosting Providers: Secure infrastructure providers that host our Platform
  • Analytics Providers: Aggregated, anonymized usage analytics

5.2 Legal and Regulatory Disclosures

We may disclose your information to:

  • Law enforcement agencies, regulators, or government authorities when required by law or legal process
  • FinCEN, FINTRAC, or other regulatory bodies as part of suspicious activity reporting (SAR) obligations
  • Courts or tribunals in response to valid subpoenas, court orders, or other compulsory legal process

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change.

5.4 With Your Consent

We may share your information for other purposes with your explicit consent.

6. Data Retention

We retain your personal information for as long as your account is active and as required to fulfill the purposes described in this policy. Specific retention periods include:

  • Account and Transaction Records: Minimum 5 years after account closure or last transaction, as required by FinCEN and applicable state and federal regulations
  • KYC/AML Records: Minimum 5 years after the relationship ends, per BSA/AML requirements
  • Communications: Retained for the duration of the business relationship plus 3 years
  • Technical Logs: Up to 2 years for security and troubleshooting purposes

When retention periods expire, we securely delete or anonymize your data.

7. Data Security

We implement industry-standard security measures to protect your information, including:

  • Encryption of data in transit (TLS/SSL) and at rest (AES-256)
  • Multi-factor authentication for account access
  • Regular security audits and penetration testing
  • Access controls limiting employee access to personal data on a need-to-know basis
  • Non-custodial wallet architecture on the Stellar blockchain, meaning you retain control of your digital assets. Key management is powered by Privy, ensuring secure, user-controlled authentication without Bousol holding your private keys.

No system is 100% secure. While we take reasonable measures to protect your data, we cannot guarantee absolute security.

8. Cookie Policy

8.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. We use cookies and similar technologies to operate the Platform, remember your preferences, and analyze usage.

8.2 Types of Cookies We Use

  • Strictly Necessary Cookies: Required for basic Platform functionality (authentication, security, load balancing). These cannot be disabled.
  • Analytics Cookies: Help us understand how visitors use the Platform (page views, navigation patterns). Set only with your consent.
  • Functional Cookies: Remember your preferences (language, region). Set only with your consent.
  • Marketing Cookies: Used to deliver relevant communications and measure campaign effectiveness. Set only with your consent.

8.3 Managing Cookies

When you first visit our website, a cookie consent banner will appear allowing you to:

  • Accept all cookies
  • Reject all non-essential cookies
  • Customize your preferences by category

You can change your cookie preferences at any time by clicking the "Cookie Preferences" link in our website footer. You can also control cookies through your browser settings.

8.4 Third-Party Cookies

Some cookies are placed by third-party services we use (such as analytics or payment providers). These third parties have their own privacy policies governing the use of cookies.

9. Your Rights

Depending on your jurisdiction, you may have the following rights:

9.1 All Users

  • Access: Request a copy of the personal information we hold about you
  • Correction: Request correction of inaccurate or incomplete information
  • Deletion: Request deletion of your personal information, subject to legal retention requirements
  • Opt-Out of Marketing: Unsubscribe from marketing communications at any time

9.2 California Residents (CCPA/CPRA)

  • Right to Know: What personal information we collect, use, and disclose
  • Right to Delete: Request deletion of your personal information
  • Right to Opt-Out: We do not sell your personal information. If this changes, we will provide a "Do Not Sell or Share My Personal Information" link.
  • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights
  • Global Privacy Control (GPC): We honor GPC signals as a valid opt-out request

9.3 Canadian Residents (PIPEDA)

  • Right to Access and Correct: Access and correct your personal information held by us
  • Right to Withdraw Consent: Withdraw consent for non-essential data processing
  • Right to Complain: File a complaint with the Office of the Privacy Commissioner of Canada

9.4 European Economic Area, UK, and Swiss Residents (GDPR/UK GDPR)

If you are located in the EEA, UK, or Switzerland:

  • Right to Access, Rectification, Erasure, Restriction, Portability, and Objection as provided under the GDPR
  • Right to Withdraw Consent at any time for consent-based processing
  • Right to Lodge a Complaint with your local Data Protection Authority

To exercise any of these rights, contact us at info@bousolapp.com. We will respond within 30 days (or as required by applicable law).

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States and Canada. We ensure appropriate safeguards are in place for such transfers, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Data Processing Agreements with all service providers
  • Compliance with applicable cross-border data transfer regulations

11. Children's Privacy

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we discover that we have inadvertently collected information from a child under 18, we will promptly delete it. If you believe a child has provided us with personal information, please contact us at info@bousolapp.com.

12. Third-Party Links

Our Platform may contain links to third-party websites or services (e.g., MoneyGram, Stellar, payment processors). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing them with your information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

  • Update the "Last Updated" date at the top of this page
  • Notify you via email or in-app notification for significant changes
  • Obtain renewed consent where required by law

Your continued use of the Platform after changes are posted constitutes acceptance of the updated policy.

14. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal data, contact us at:

Paon Bleu Inc. (DBA Bousol)

Email: info@bousolapp.com

Address: 14826 SW 19th Ct, Miramar, FL 33027, USA

For privacy-specific inquiries, please include "Privacy Request" in your subject line.

DISCLAIMER: This Privacy Policy is a draft template and should be reviewed by qualified legal counsel before publication. It does not constitute legal advice. Ensure all details are verified and the policy is tailored to your specific operations, data processing activities, and applicable regulatory requirements.