Privacy Policy

1. Purpose of This Privacy Policy

Welcome to Bosse Value Network (”BVN,” “we,” “our,” or “us”). This Privacy Policy explains how Bosse Value Network collects, uses, stores, shares, protects, and otherwise processes personal information when individuals and organizations use our website, mobile applications, APIs, software, merchant services, customer support, and any other products or services we provide (collectively, the “Platform”). Privacy is fundamental to the trust our users place in us. We are committed to handling personal information responsibly, transparently, and in accordance with applicable privacy and data protection laws. This Privacy Policy describes:

What information we collect Why we collect it How we use it When we share it How we protect it How long we retain it Your privacy rights How you may contact us regarding privacy matters

By accessing or using the Platform, you acknowledge that you have read and understand this Privacy Policy.

2. Scope of This Policy

This Privacy Policy applies to information collected through:

BVN website BVN mobile applications Merchant Dashboard Business Dashboard Admin Dashboard APIs Customer Support Marketing campaigns Email communications SMS communications Platform notifications Surveys Promotional events Loyalty programs Reward Point services Credit redemption services

This Policy also applies to information collected during account registration, identity verification, fraud investigations, customer support interactions, and participation in promotions sponsored by BVN.

This Policy Does Not Apply To This Privacy Policy does not govern:

Third-party websites linked from the Platform Independent merchants using BVN Third-party payment providers Third-party identity verification providers Social media platforms Other companies that maintain their own privacy policies

Users should review the privacy policies of those third parties before providing personal information.

3. Acceptance of This Privacy Policy

By creating a BVN account, using our Platform, purchasing subscriptions, participating in loyalty programs, or otherwise interacting with BVN, you acknowledge and agree that your information may be collected, used, stored, disclosed, and processed as described in this Privacy Policy. Where required by law, BVN will obtain additional consent before collecting or processing certain categories of personal information. Users who do not agree with this Privacy Policy should discontinue use of the Platform.

4. Information We Collect

BVN collects information to operate the Platform, provide services, improve security, comply with legal obligations, and enhance the user experience. The categories of information we collect depend on how you use the Platform.

4.1 Personal Information

When you create an account, we may collect:

Full legal name Preferred display name Email address Mobile telephone number Date of birth Residential address Country of residence State or province Postal code Profile photo (optional) Language preferences Time zone

This information helps us establish and manage your account, communicate with you, and provide Platform services.

4.2 Account Information

We collect information relating to your use of the Platform, including:

• Username
• Account ID
• Password (stored using secure hashing methods; BVN does not store plaintext

passwords)

• Subscription plan
• Account status
• Verification status
• Security settings
• Two-factor authentication preferences
• Login history
• Account creation date
• Account update history

4.3 Business & Merchant Information

For Business and Merchant Accounts, we may collect:

Legal business name Doing Business As (DBA) name Employer Identification Number (EIN) or other tax identifier Business registration documents Business address Authorized representative information Contact information Industry classification Merchant profile information Banking or payout details, where applicable Supporting compliance documentation

This information is used to verify business eligibility, administer merchant services, comply with applicable laws, and provide enterprise features.

4.4 Payment Information

To process subscriptions, merchant purchases, and other authorized transactions, BVN may collect or receive payment-related information. Depending on the payment method used, this may include:

Payment method type Billing address Transaction identifiers Payment confirmation details Subscription billing history Invoice information Partial payment card information (where applicable) Payment processor reference numbers

Sensitive payment credentials, such as complete payment card numbers, are generally collected and processed directly by our authorized payment processors in accordance with their own security standards and privacy practices. BVN does not store full payment card information unless expressly required and permitted by applicable law.

5. Identity Verification (KYC) Information

To protect users, merchants, and the integrity of the Platform, BVN may collect identity verification information before granting access to certain services or removing account restrictions. Identity verification helps us:

Prevent fraud and identity theft Verify account ownership Comply with applicable laws and regulations Meet the requirements of payment processors and banking partners Detect suspicious activity Protect businesses and users from unauthorized transactions

5.1 Information We May Collect

Depending on the services you use, BVN may collect:

• Government-issued photo identification
• Passport
• Driver’s license

State identification card Selfie or biometric verification Proof of address Date of birth Tax identification information where required Business registration documents Beneficial ownership information Source-of-funds information where legally required

Not every user will be asked to provide every type of information.

5.2 Third-Party Verification

BVN may use trusted third-party verification providers to:

Verify identity Authenticate documents Detect fraud Screen against sanctions lists Validate addresses Perform business verification

Those providers process information solely for authorized verification and compliance purposes.

5.3 Ongoing Verification

Verification is not limited to account creation. BVN may request updated verification information when:

Account information changes Suspicious activity is detected Redemption thresholds are exceeded Regulatory requirements change Fraud investigations require additional review

6. Transaction Information

To operate the Platform and maintain accurate records, BVN collects information about transactions conducted through the Platform. Examples include:

Reward Point issuances Point transfers Point conversions Credit balances Redemption requests Subscription purchases Merchant purchases Business account activity Refunds Chargebacks Administrative adjustments

Transaction records may include:

Date and time Transaction amount Account identifiers Status Payment processor reference numbers Internal audit identifiers

Transaction information helps us maintain platform integrity, detect fraud, and comply with legal obligations.

7. Device Information

When you use BVN, we may automatically collect information about the devices used to access the Platform. This may include:

Device type Operating system Browser type Browser version Screen resolution Device identifiers

Mobile device model Language settings Time zone Network information Platform version

This information helps improve compatibility, diagnose issues, and secure the Platform.

8. Technical Information

BVN may automatically collect technical information necessary for Platform operations. Examples include:

IP address Internet service provider Login timestamps Session identifiers Authentication logs API requests Error reports Performance metrics Crash reports Feature usage Referral URLs

Technical information helps us:

Improve Platform performance Detect malicious activity Investigate security incidents Optimize system reliability Troubleshoot technical problems

9. Fraud Detection Information

To protect our users and business partners, BVN may collect and generate information related to fraud prevention.

This may include:

Device reputation IP reputation Velocity checks Login behavior Geographic inconsistencies Transaction patterns Multiple account detection Payment risk indicators Behavioral analytics Internal fraud risk scores

Fraud detection information is used solely for security, compliance, and risk management purposes.

10. Communications

When you communicate with BVN, we may collect records of those communications. Examples include:

Customer support requests Emails Live chat conversations Telephone call records where legally permitted Survey responses Feedback submissions Bug reports Account appeals Compliance inquiries

These records help us:

Respond to your requests Improve customer service Investigate disputes Train support personnel Maintain quality assurance Meet legal and regulatory obligations

11. Information You Choose to Provide

You may voluntarily provide additional information while using the Platform. Examples include:

Profile photographs Business descriptions Marketing preferences Survey responses Feature requests Testimonials Community participation Support documentation Appeal documentation

Providing this information is generally optional unless required to provide a specific service or comply with applicable law.

Privacy by Design BVN is committed to collecting only the information reasonably necessary to provide our services, protect the Platform, comply with legal obligations, and improve the user experience. We regularly review our data collection practices to minimize unnecessary collection and promote responsible handling of personal information.

12. How We Use Your Information

BVN uses personal information only for legitimate business, operational, legal, security, and customer service purposes. The information we collect allows us to operate the Platform, protect our users, improve our services, and comply with applicable laws and regulations. Depending on your interaction with BVN, we may use your information in the following ways.

13. Platform Operations

We use your information to provide and maintain the BVN Platform. This includes:

Creating user accounts Managing Business and Merchant Accounts Operating Reward Point programs Processing point transfers Processing point conversions Managing Credit Wallet balances Processing redemption requests Managing subscriptions Providing customer support Delivering Platform features Maintaining account preferences Managing notifications Synchronizing account information across devices

Without this information, many Platform features cannot function properly.

14. Identity Verification & Compliance

BVN uses personal information to verify identity and comply with applicable legal and regulatory requirements. Verification activities may include:

Confirming your identity Verifying business ownership Screening against sanctions lists Detecting duplicate accounts Confirming account ownership Verifying withdrawal eligibility Supporting fraud investigations Meeting payment processor requirements

Where permitted by law, verification may occur before or after account creation.

15. Fraud Prevention & Security

Protecting users and businesses is one of BVN’s highest priorities. We use collected information to:

Detect unauthorized account access Prevent account takeovers Identify fraudulent transactions Detect suspicious redemption activity Monitor unusual transfer patterns Identify compromised devices Detect payment fraud Investigate security incidents Prevent abuse of promotional programs Protect Platform integrity

Security monitoring may occur continuously while the Platform is in use.

16. Payment Processing

We use information necessary to process authorized payments, including:

Subscription billing Merchant purchases Business purchases Refunds where applicable Chargeback investigations Payment confirmations Financial reconciliation Invoice generation

Payment processing may involve trusted third-party payment processors. BVN generally does not store complete payment card numbers or card security codes.

17. Customer Support

Information collected during customer interactions helps us:

Respond to support requests Investigate account issues Recover account access Resolve disputes Improve customer service Document communications Process appeals Verify account ownership

Support interactions may be retained for quality assurance, training, and compliance purposes.

18. Product Development & Improvement

BVN continually improves its Platform. Information may be used to:

Improve user experience Enhance platform performance Develop new features Improve accessibility Fix software bugs Improve mobile applications Improve merchant tools Improve fraud detection systems Improve security controls

Where practical, we use aggregated or de-identified information for analytics and product improvement.

19. Communications

BVN uses contact information to communicate with users regarding:

• Account activity
• Security alerts

Login notifications Subscription renewals Redemption updates Transaction confirmations Product announcements Customer support responses Policy updates Legal notices

Users may opt out of promotional communications where required by law; however, operational and security-related communications cannot generally be disabled while maintaining an active account.

20. Marketing

With your consent where required by law, BVN may use your information to:

Send newsletters Share promotions Announce new features Provide educational content Notify users about platform updates Conduct surveys Invite participation in beta programs

Marketing communications may be delivered by:

Email SMS (where consent has been obtained) Push notifications In-app messages

You may opt out of marketing communications at any time by following the instructions included in the communication or by updating your account preferences.

21. Analytics & Performance Monitoring

BVN uses information to better understand how the Platform is used and to improve reliability, performance, and usability. Analytics may include:

Feature usage Session duration Navigation patterns Device performance Crash reports Load times Error rates Aggregate user trends

Analytics are used to improve the Platform and are not intended to identify users unnecessarily.

22. Legal & Regulatory Compliance

BVN may process personal information to:

Comply with applicable laws and regulations Respond to lawful requests from government authorities Enforce our Terms of Service Protect our legal rights Resolve disputes Meet accounting and tax obligations Maintain business records Fulfill court orders Cooperate with law enforcement when legally required

We disclose personal information only when we have a lawful basis to do so.

23. Internal Business Operations

We also use information for legitimate internal business purposes, including:

• Financial reporting
• Risk management

Internal audits Compliance reviews Employee training Vendor management Service quality assurance Business continuity planning Disaster recovery testing Strategic planning

These activities help us maintain a secure, reliable, and sustainable Platform.

Data Minimization BVN is committed to collecting and using only the personal information that is reasonably necessary for the purposes described in this Privacy Policy. We regularly review our data practices to minimize unnecessary collection and ensure that information is processed responsibly and in accordance with applicable privacy laws.

Chapter 4 — Data Sharing & Third-Party Service Providers

24. When We Share Information

BVN does not sell your personal information for monetary compensation. We only disclose personal information when necessary to:

Provide our services Complete transactions Protect users and the Platform Comply with legal obligations Prevent fraud Support business operations Enforce our agreements

Any disclosure is limited to the information reasonably necessary for the intended purpose.

25. Service Providers

BVN works with carefully selected third-party service providers that assist us in operating the Platform. These providers may perform services including:

Cloud hosting Data storage Customer support Payment processing Identity verification Fraud prevention Security monitoring Analytics Email delivery SMS delivery Push notifications Customer relationship management Infrastructure monitoring Backup and disaster recovery

These providers are contractually required to safeguard personal information and may use it only for the services they perform on BVN’s behalf.

26. Payment Processing

To process authorized payments, BVN shares necessary payment information with trusted payment processing partners. Depending on the payment method used, information shared may include:

Name Billing address Payment amount Subscription information Transaction identifiers Payment method details

• Fraud indicators
• Order information

Payment processors maintain their own privacy and security obligations. BVN does not control how independent payment processors handle information once received under their own legal responsibilities.

27. Identity Verification Providers

When identity verification is required, BVN may share necessary information with trusted verification providers. Information shared may include:

Name Date of birth Government-issued identification Address Selfie verification Business documents Tax identification information Other verification documents submitted by the user

Verification providers process information solely for identity verification, fraud prevention, and legal compliance.

28. Fraud Prevention & Security Partners

BVN may disclose limited information to fraud prevention and security providers to:

Detect suspicious activity Prevent account takeovers Verify device reputation Identify fraudulent payment activity Prevent abuse of promotions Investigate suspicious transactions Improve Platform security

These providers may analyze behavioral, technical, and transactional information to help protect the Platform.

29. Cloud Infrastructure Providers

BVN stores and processes information using secure cloud infrastructure operated by reputable service providers. These providers may process information necessary to:

Host the Platform Store databases Maintain backups Deliver application content Improve performance Monitor infrastructure health Support disaster recovery

Cloud providers do not receive ownership of user information.

30. Analytics Providers

BVN may use analytics providers to better understand Platform performance and user interactions. Analytics information may include:

Device type Browser information Session duration Navigation patterns Feature usage Error reports Performance statistics

Where practical, analytics information is aggregated or de-identified before analysis.

31. Business Transfers

If BVN undergoes:

A merger Acquisition Investment transaction Corporate restructuring Bankruptcy Asset sale

personal information may be transferred as part of the transaction, subject to applicable law. Any successor organization will remain responsible for protecting personal information in accordance with this Privacy Policy or a substantially similar policy.

32. Legal Compliance

BVN may disclose personal information when required or permitted by law, including in response to:

Court orders Subpoenas Search warrants Government investigations Regulatory inquiries Law enforcement requests Tax authorities Financial crime investigations

Where legally permitted, BVN may notify affected users before disclosing their information.

33. Protection of Rights

BVN may disclose information when reasonably necessary to:

• Protect user safety
• Protect Platform security

Prevent fraud Enforce our Terms of Service Investigate violations Defend legal claims Protect BVN’s legal rights Protect the rights of other users

34. Business Partners

Where users voluntarily participate in promotions or programs sponsored jointly by BVN and an approved business partner, BVN may share limited information necessary to administer the promotion. Such sharing will be limited to the specific program and conducted in accordance with applicable law.

35. With Your Consent

BVN may share your information with additional third parties when you expressly authorize us to do so. You may withdraw your consent where applicable, although withdrawal does not affect processing that occurred before consent was withdrawn.

36. Information We Do Not Sell

Except where a jurisdiction’s privacy law defines certain disclosures as a “sale” or “sharing,” BVN does not sell personal information for monetary compensation. Where applicable privacy laws provide users with rights regarding such disclosures, BVN will honor those rights as required by law.

Third-Party Due Diligence Before engaging service providers that process personal information, BVN seeks to evaluate their ability to protect data through appropriate technical, organizational, and contractual safeguards. We periodically review our relationships with key providers to help ensure they continue to meet our security and compliance expectations.

Chapter 5 — Payment Processing, Cookies, Analytics, Marketing & Data Retention

37. Payment Processing

37.1 Payment Services

BVN uses trusted third-party payment service providers to process authorized transactions made through the Platform. These services may include:

Subscription payments Business purchases Merchant purchases Platform service fees Refunds where applicable Payment verification Payment fraud monitoring

Payment processors operate under their own privacy policies and regulatory obligations.

37.2 Payment Information

Depending on the payment method selected, payment processors may receive:

Name Billing address Email address Transaction amount Currency Payment method information Transaction identifiers Fraud indicators

BVN generally does not receive or store complete payment card numbers or card verification values (CVV).

37.3 Fraud Screening

To protect users and businesses, payment transactions may be evaluated for fraud using:

Device analysis Velocity monitoring Address verification Behavioral analysis Risk scoring Transaction history Identity verification Payment processor fraud tools

Transactions presenting elevated risk may be delayed, declined, or referred for manual review.

37.4 Payment Security

BVN expects its payment providers to maintain security controls consistent with applicable industry standards, including PCI DSS where required. Although BVN works with trusted providers, no payment system can guarantee absolute security.

38. Cookies & Similar Technologies

BVN uses cookies and similar technologies to improve the functionality, security, and performance of the Platform. Cookies are small text files stored on your device that help websites recognize returning users and remember preferences.

38.1 Essential Cookies

Essential cookies are required for Platform functionality. These cookies may support:

Login sessions Authentication Security Fraud prevention Load balancing User preferences Account settings

Without these cookies, portions of the Platform may not function properly.

38.2 Functional Cookies

Functional cookies help improve your experience by remembering:

Language preferences Time zone Accessibility settings Dashboard preferences Notification preferences

38.3 Performance Cookies

Performance cookies help BVN understand how users interact with the Platform.

Examples include:

Page load times Navigation patterns Session duration Error rates Feature usage

Performance information is generally analyzed in aggregated form.

38.4 Analytics Cookies

Analytics technologies help us improve the Platform by measuring:

User engagement Feature adoption Device compatibility Traffic sources General usage trends

Analytics are intended to improve our services and user experience.

38.5 Marketing Cookies

Where permitted by law, marketing technologies may be used to:

Measure advertising effectiveness Prevent repetitive advertising Deliver more relevant communications Evaluate promotional campaigns

Users may manage cookie preferences through browser settings or available consent tools, where applicable.

39. Analytics

BVN analyzes Platform usage to improve performance, reliability, and usability.

Analytics may include:

Session statistics Device information Feature usage Application performance Crash reports Geographic trends (at a general level) Navigation flows Aggregate reporting

Where possible, BVN uses aggregated or de-identified information for analytical purposes.

39.1 Operational Analytics

Analytics assist BVN in:

Improving user experience Optimizing Platform performance Planning new features Identifying software issues Allocating technical resources Improving customer support

Analytics are not used to make automated decisions with legal or similarly significant effects unless otherwise disclosed and permitted by applicable law.

40. Marketing Communications

BVN may communicate with users regarding products, services, educational content, and promotional opportunities. Marketing communications may include:

Email newsletters Product announcements Promotional campaigns Event invitations Educational resources

• Surveys
• Feature updates

Where required by law, BVN will obtain appropriate consent before sending marketing communications.

40.1 Opt-Out Rights

Users may unsubscribe from marketing communications at any time by:

• Clicking the unsubscribe link in marketing emails
• Updating communication preferences within the Platform
• Contacting Customer Support

Please note that transactional and security-related communications cannot generally be disabled while maintaining an active account.

41. Data Retention

BVN retains personal information only for as long as reasonably necessary to:

Provide services Maintain accounts Process transactions Prevent fraud Resolve disputes Comply with legal obligations Maintain business records Enforce agreements

When information is no longer required, BVN will securely delete, anonymize, or otherwise dispose of it in accordance with applicable law and internal retention policies.

41.1 Typical Retention Periods

Retention periods vary based on the type of information and legal requirements. Examples include:

Information Category

Typical Retention Purpose

Account Information

Maintain active accounts and comply with legal obligations

Transaction Records

Accounting, fraud prevention, audits, and regulatory compliance

Identity Verification Records

Legal compliance, fraud prevention, and dispute resolution

Customer Support Communications

Service quality, dispute resolution, and training

Security Logs

Cybersecurity monitoring and incident response

Actual retention periods may differ where required by law or necessary to protect BVN’s legitimate interests.

41.2 Secure Disposal

When records are no longer required, BVN uses reasonable administrative, technical, and physical measures to securely delete or anonymize personal information to reduce the risk of unauthorized access or recovery.

Privacy Governance

BVN periodically reviews its data collection, storage, and retention practices to help ensure they remain appropriate for the services provided, comply with evolving legal requirements, and support the responsible stewardship of personal information.

Chapter 6 — Security, International Transfers & Your Privacy Rights

42. Security Measures

Protecting personal information is one of BVN’s highest priorities. We maintain a comprehensive information security program designed to protect the confidentiality, integrity, and availability of the information entrusted to us. Our security program is regularly reviewed and updated to address evolving threats, business operations, and legal requirements.

42.1 Administrative Safeguards

BVN maintains administrative controls that may include:

Security policies and procedures Employee confidentiality obligations Security awareness and training Background screening where appropriate Role-based access management Vendor due diligence Incident response planning Business continuity planning Disaster recovery planning Internal compliance reviews

42.2 Technical Safeguards

BVN implements technical safeguards that may include:

Encryption of data in transit using industry-standard protocols Encryption of sensitive data at rest where appropriate Multi-factor authentication for administrative access Secure password hashing Access logging and monitoring Intrusion detection and prevention systems Firewalls and network segmentation Malware protection Automated vulnerability monitoring Security event logging Secure software development practices

Security controls are periodically evaluated and improved as technology and risks evolve.

42.3 Physical Safeguards

Where applicable, BVN and its service providers maintain physical safeguards designed to protect facilities and systems that process personal information. These safeguards may include:

Restricted facility access Visitor controls Environmental protections Equipment security Physical monitoring

42.4 Access Controls

Access to personal information is limited to employees, contractors, and authorized service providers who require the information to perform their responsibilities. Access is granted according to the principle of least privilege and is periodically reviewed.

42.5 Incident Response

If BVN becomes aware of a security incident involving personal information, we will investigate the matter and take appropriate steps to contain, assess, and remediate the issue.

Where required by applicable law, affected individuals and relevant authorities will be notified in accordance with legal requirements.

42.6 No Absolute Security

While BVN strives to maintain strong security practices, no method of electronic transmission, storage, or processing can be guaranteed to be completely secure. Users also play an important role by maintaining strong passwords, protecting their account credentials, enabling available security features, and promptly reporting suspected unauthorized access.

43. International Data Transfers

BVN may process and store personal information in jurisdictions other than the country in which you reside. These transfers may occur because our service providers, infrastructure providers, payment processors, or business operations are located in multiple countries. Where personal information is transferred internationally, BVN will take reasonable steps to ensure that appropriate safeguards are in place consistent with applicable law.

43.1 Transfer Safeguards

Depending on the applicable legal requirements, BVN may rely on safeguards such as:

Standard Contractual Clauses (SCCs) Adequacy decisions issued by competent authorities Contractual confidentiality obligations Technical security controls Organizational security measures

43.2 Storage Locations

Personal information may be stored on secure servers operated by BVN or its authorized service providers. The location of these servers may change over time as business needs evolve.

44. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information. These rights may include:

The right to know what personal information we collect. The right to access your personal information. The right to request correction of inaccurate information. The right to request deletion of eligible information. The right to request portability of your information. The right to object to certain processing. The right to restrict certain processing. The right to withdraw consent where processing is based on consent. The right to appeal certain privacy decisions where required by law.

These rights are subject to applicable legal limitations and exceptions.

44.1 Identity Verification for Privacy Requests

To protect user privacy, BVN may require verification of identity before responding to requests involving personal information. Failure to verify identity may limit our ability to fulfill certain requests.

44.2 Response Time

BVN will respond to verified privacy requests within the timeframes required by applicable law. Where permitted, response periods may be extended when requests are unusually complex or numerous.

45. GDPR (European Economic Area and

United Kingdom) If the General Data Protection Regulation (GDPR) or similar laws apply to your use of the Platform, BVN will process personal information in accordance with those laws.

45.1 Lawful Bases for Processing

Depending on the circumstances, BVN may process personal information based on one or more lawful bases, including:

Performance of a contract. Compliance with legal obligations. Legitimate business interests. Your consent, where required. Protection of vital interests. Performance of a task carried out in the public interest, where applicable.

45.2 GDPR Rights

Individuals protected by the GDPR may have the right to:

Access their personal information. Correct inaccurate information. Request erasure (“right to be forgotten”) where applicable. Restrict processing. Object to certain processing. Receive data portability. Withdraw consent where processing is based on consent. Lodge a complaint with the appropriate supervisory authority.

46. California Privacy Rights (CCPA/CPRA)

California residents may have additional privacy rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). Subject to applicable law, eligible California residents may have the right to:

Know the categories of personal information collected. Know the sources of personal information. Know the purposes for processing. Know the categories of third parties receiving information. Request deletion of eligible personal information. Request correction of inaccurate information. Receive a copy of certain personal information. Limit the use of sensitive personal information where applicable. Be free from unlawful discrimination for exercising privacy rights.

BVN will honor qualifying requests as required by California law.

47. Other U.S. State Privacy Laws

Residents of states with applicable privacy legislation—including, where applicable, Virginia, Colorado, Connecticut, Utah, and other jurisdictions that enact similar laws—may have additional rights regarding their personal information. BVN will comply with applicable state privacy laws and will update this Privacy Policy as new legal requirements become effective.

48. Exercising Your Rights

To exercise your privacy rights, you may submit a request through the methods designated by BVN, including our website or designated privacy contact. We may request additional information to verify your identity before fulfilling your request. We will not unlawfully discriminate against you for exercising your applicable privacy rights.

Privacy Compliance Commitment

BVN is committed to building a privacy program that is transparent, secure, and adaptable to evolving legal and regulatory requirements. We regularly review our policies, practices, and technologies to support responsible data stewardship and maintain user trust.

Chapter 7 — Children’s Privacy, Policy Updates & Contact Information

49. Children’s Privacy

49.1 Age Requirements

The BVN Platform is intended for individuals who are legally permitted to create an account under applicable law. Unless otherwise permitted by applicable law, BVN does not knowingly collect personal information directly from children under 13 years of age. Where local law requires a higher minimum age, BVN will comply with those legal requirements.

49.2 Inadvertent Collection

If BVN becomes aware that personal information has been collected from a child in violation of applicable law, we will take reasonable steps to:

Investigate the matter. Delete the information where appropriate. Close the associated account if necessary. Comply with applicable legal obligations.

Parents or legal guardians who believe their child has provided personal information may contact BVN using the contact information provided in this Privacy Policy.

49.3 Parent Requests

Where applicable law grants parents or legal guardians specific privacy rights, BVN will respond to verified requests concerning a child’s personal information in accordance with those legal requirements.

50. Third-Party Websites & Services

The BVN Platform may contain links to websites, applications, or services operated by third parties. Examples include:

Payment providers Identity verification providers Social media platforms Merchant websites Business partners Customer support tools

BVN is not responsible for the privacy practices, content, or security of third-party services. Users should review the privacy policies of any third-party services before providing personal information.

51. Changes to This Privacy Policy

BVN may update this Privacy Policy from time to time to reflect:

Changes in our services New Platform features Security improvements Business operations Legal or regulatory requirements Industry best practices

When material changes are made, BVN will provide notice through appropriate channels, which may include:

• Email
• In-app notifications
• Website notices
• Account dashboard messages

The updated Privacy Policy becomes effective on the date specified at the beginning of the revised version. Your continued use of the Platform after the effective date constitutes acknowledgment of the updated Privacy Policy.

52. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, you may contact BVN using the following information: Bosse Value Network (BVN) Privacy Team Email: [email protected] Customer Support Email: [email protected] Website https://www.bossevaluenetwork.com Mailing Address Insert Registered Business Address If you believe your privacy rights have been violated, please contact us first so we can investigate and work toward an appropriate resolution.

53. Data Protection & Compliance Contact

BVN has designated personnel responsible for overseeing privacy compliance, information governance, and data protection. Privacy inquiries may include:

• Access requests

Correction requests Deletion requests Data portability requests Consent withdrawal Marketing preferences Security concerns Suspected privacy incidents

Verified requests will be handled within the timeframes required by applicable law.

Appendix A — Categories of Personal Information Collected Depending on your use of the Platform, BVN may collect the following categories of information:

Identification Information

Name Date of birth Email address Telephone number Residential address

Account Information

Username Account ID Subscription plan Verification status Login history

Business Information

Business name EIN or tax identifier Business registration documents Authorized representative details

Financial & Transaction Information

Billing details Subscription history Reward Point activity Credit Wallet activity Redemption history Payment transaction records

Technical Information

Device information Browser information Operating system IP address Session logs Crash reports

Communications

Customer support interactions Survey responses Feedback Appeals Email correspondence

Appendix B — Categories of Third-Party Recipients BVN may disclose information to categories of recipients including:

Payment processors Identity verification providers Fraud detection providers Cloud hosting providers Customer support vendors Analytics providers Email delivery providers SMS providers Security monitoring providers Legal advisors Auditors

• Government authorities where required by law

Appendix C — Data Retention Schedule BVN retains information only as long as reasonably necessary for business operations, legal compliance, fraud prevention, dispute resolution, and security. Typical categories include:

Account records Payment records Identity verification records Security logs Customer support records Audit records Compliance documentation

Retention periods may vary depending on applicable legal and regulatory requirements.

Appendix D — Security Controls Overview BVN’s information security program includes:

Encryption in transit Encryption at rest (where appropriate) Secure password hashing Role-based access controls Multi-factor authentication for administrative access Continuous security monitoring Intrusion detection Security logging Incident response procedures Disaster recovery planning Vendor security reviews Employee security training

Appendix E — Cookie Categories BVN may use:

Essential Cookies Functional Cookies Performance Cookies Analytics Cookies Marketing Cookies (where permitted by law)

Users can manage cookie preferences through supported browser settings and any cookie preference tools made available by BVN.

End of Privacy Policy Enterprise Privacy Program Statement Bosse Value Network is committed to protecting the privacy, security, and trust of our users, merchants, business customers, and partners. We continuously evaluate and improve our privacy and security practices to support responsible data stewardship, comply with evolving legal requirements, and maintain a secure and transparent platform.