Legal Document

Privacy
Policy

Puent3 LLC · Effective Date: April 3, 2026 · Version 1.0
Section 1

Introduction

Puent3 LLC ("Puent3," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information about you when you use our cross-border stablecoin payment platform, website (puent3.io), WhatsApp interface, and related services (collectively, the "Services").

By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this policy, please do not use our Services.

Applicable laws: This policy is designed to comply with applicable privacy laws including the US Federal Privacy Act, the Gramm-Leach-Bliley Act (GLBA), Colombia's Law 1581 of 2012 (Ley de Protección de Datos Personales), Argentina's Personal Data Protection Law 25.326, Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable data protection laws in the jurisdictions where we operate.
Section 2

Information We Collect

Identity and Business Information: When you register and complete our onboarding process, we collect:

  • Full legal name, business name, and contact information
  • Government-issued identification documents (passport, national ID)
  • Business registration documents and tax identification numbers
  • Beneficial ownership information
  • Bank statements and source of funds documentation
  • Selfie photographs for identity verification (liveness check)
  • Business activity descriptions and expected transaction volumes

Transaction Information: For each payment processed through our platform, we collect:

  • Payment amount, currency, and destination details
  • Recipient name and bank account information
  • Transaction timestamps and on-chain reference IDs
  • IP addresses and device identifiers associated with payment instructions

Communication Data: We collect and retain records of communications you send through our WhatsApp interface and any email correspondence with our team.

Technical Data: We automatically collect certain technical information when you interact with our platform, including browser type, operating system, referring URLs, and usage patterns.

Section 3

How We Use Your Information

We use the information we collect for the following purposes:

  • Service delivery: Processing payments, verifying recipient details, and completing cross-border transactions on your behalf.
  • Identity verification and compliance: Fulfilling our Know Your Customer (KYC), Know Your Business (KYB), and Anti-Money Laundering (AML) obligations under applicable law.
  • Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account compromise, and other illegal activity.
  • Legal obligations: Complying with sanctions screening requirements, reporting obligations under the Bank Secrecy Act, FinCEN regulations, and equivalent laws in Colombia and Canada.
  • Customer support: Responding to your inquiries, resolving disputes, and providing transaction confirmations.
  • Platform improvement: Analyzing usage patterns to improve our Services, fix bugs, and develop new features.
  • Legal proceedings: Establishing, exercising, or defending legal claims.
Section 4

Information Sharing and Disclosure

We do not sell your personal information to third parties. We share your information only in the following circumstances:

  • Service providers: Identity verification providers (Persona), blockchain infrastructure providers (Circle), partner financial institutions, and cloud hosting services that process data on our behalf under data processing agreements.
  • Legal requirements: Government authorities, regulators, or law enforcement when required by applicable law, court order, or legal process, including mandatory reporting under anti-money laundering statutes.
  • Sanctions compliance: Screening against OFAC, UN, and EU sanctions lists may involve sharing identifiers with third-party screening services.
  • Business transfers: In connection with a merger, acquisition, or sale of substantially all our assets, in which case we will notify clients and ensure the same privacy protections apply.
  • With your consent: For any other purpose with your explicit prior consent.
Section 5

Data Retention

We retain your personal information for as long as necessary to provide our Services and comply with our legal obligations. Specifically:

  • KYC/KYB records: Minimum five (5) years from the date of account closure, as required by US Bank Secrecy Act and equivalent regulations.
  • Transaction records: Minimum five (5) years from the date of each transaction.
  • Communications: Minimum three (3) years, or longer if required by law or ongoing legal proceedings.
  • Identity documents: As required by applicable law in each jurisdiction, typically five (5) years.

When retention periods expire, we securely delete or anonymize personal information in accordance with our data destruction policies.

Section 6

Your Rights

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

  • Access: The right to request a copy of the personal information we hold about you.
  • Correction: The right to request correction of inaccurate or incomplete information.
  • Deletion: The right to request deletion of your personal information, subject to our legal retention obligations.
  • Portability: The right to receive your data in a structured, machine-readable format.
  • Objection: The right to object to certain processing activities.

To exercise any of these rights, contact us at legal@puent3.io. We will respond within thirty (30) days. Note that certain rights may be limited where we are required to retain data by law or where data is necessary for a legitimate ongoing purpose.

Colombian residents: You have additional rights under Law 1581 of 2012, including the right to file complaints with the Superintendencia de Industria y Comercio (SIC) if you believe your data rights have been violated.

Canadian residents: You have rights under PIPEDA to access and correct personal information and to file complaints with the Office of the Privacy Commissioner of Canada.
Section 7

Data Security

We implement reasonable technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, access controls, and regular security reviews.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

Section 8

International Data Transfers

Puent3 operates across multiple jurisdictions. Your personal information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. We take appropriate safeguards to ensure that your personal information receives an adequate level of protection regardless of where it is processed.

Section 9

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify clients of material changes by email or platform notification at least seven (7) days before the effective date. The current version is always available at puent3.io/privacy.

Section 10

Contact

For privacy-related questions, requests, or complaints, contact us at:

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