Privacy Policy

1. Information we collect

The information we collect depends on how you use the Services. It may include:

• Contact and booking information: your name, email address, phone number, billing or signing address, guest details, hotel or travel booking details, order references, and communications with us. You or the agent arranging your booking may provide this information.
• Bank information: when you choose to connect a bank account, information provided through Plaid and your financial institution, such as account holder names, contact details, account names and types, account and routing numbers, balances, and connection or verification status.
• Payment and authorization records: amounts, payment status, transaction references, limited card details returned by our payment processor, refunds, signed ACH authorization documents, signatures, and related signing and audit records.
• Identity verification information: when verification is requested, identifying details such as your name, date of birth, nationality, and address; government-issued identification document images and details; selfies or video captured for liveness checks; facial features used for identity matching; and verification results, fraud indicators, and consent records. The verification flow identifies the information required for your check.
• Technical and usage information: IP address, approximate location derived from IP address, browser and device information, request times, and activity related to bank connections, payments, authorizations, and identity verification.

2. How we use information

We use personal information to manage booking and payment orders; verify bank accounts and account ownership; prepare and record payment authorizations; process payments and refunds; send service messages and signing invitations; provide customer support; and maintain transaction records. We also use information to investigate errors, prevent fraud and misuse, secure the Services, resolve disputes, and meet applicable legal and recordkeeping obligations.

When identity verification is requested, we use the information to confirm who is making a booking or payment, assess whether an identification document is genuine and belongs to the person presenting it, and detect impersonation or fraudulent verification attempts.

3. Identity verification through Sumsub

If we ask you to verify your identity, we use Sumsub for document verification and selfie or liveness checks. We may send you a verification link by email. You submit the requested identification and camera captures in the linked verification flow. Please use that flow rather than sending identity documents or selfies to our support email.

Bonums determines why verification is requested and how the results affect your booking or payment. Sumsub processes information on our behalf to carry out the checks. Authorized Bonums personnel may review the verification outcome and supporting information available through the service, including submitted identity information and media where needed to review a check. The final service decision rests with Bonums.

Checks may involve automated document analysis, facial comparison, liveness detection, and fraud indicators. If a result appears incorrect, you can contact us to request a review or correction.

Sumsub also describes processing for certain purposes of its own, including security, fraud prevention, and service development, which may include AI model training where permitted. Its roles, recipients, and practices are explained in the Sumsub Privacy Notice (Service Delivery) and Notice of Personal Data Processing. Requests about processing controlled by Bonums should be directed to us; requests about Sumsub's independent processing can be directed to Sumsub using its notices.

4. Biometric privacy and consent

Selfie and liveness verification can involve extracting a scan of face geometry or a facial template and comparing it with the photograph on your identification document. These derived features may constitute biometric identifiers or biometric information under applicable law. Photographs and videos are not automatically biometric identifiers under every law, but remain personal information covered by this policy.

For Bonums, the purposes of this processing are to match you to your document, check that a live person is present, and detect impersonation, manipulated media, or other fraudulent verification attempts. Relevant data may be disclosed to Sumsub and service providers assisting with these checks, or as required or otherwise permitted by applicable law. We do not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information.

Before the relevant information is transferred to Sumsub, the verification process must present the applicable processing notices and obtain the required affirmative consent. For U.S. biometric verification, this includes the Sumsub Biometrics Processing Consent (U.S. Residents) and any separate consent required for Bonums' processing. The purpose and applicable retention term must be explained before biometric collection. Acceptance must be recorded with the time and information that connects it to your verification.

Receiving an email, opening a verification link, or reading this policy does not by itself provide biometric consent. You may decline the check or contact us to withdraw consent for future processing based on that consent. This may prevent us from completing a required verification or the related service. Contact us to discuss whether another verification method is available; an alternative is not guaranteed. Withdrawal does not undo prior lawful processing. The retention and deletion requirements below continue to apply.

5. Bank connections and payment providers

Plaid. We use Plaid to connect to financial institutions and obtain the bank information you authorize us to access. Bonums does not receive or store your online banking password. While a connection remains authorized, we may retrieve updated account information, including balances and connection status, for payment verification and administration. Plaid's own handling of information is described in the Plaid End User Privacy Policy.

Stripe. Card details are entered through Stripe's payment form and processed by Stripe. Bonums does not receive or store your full card number or card security code from that form. We receive payment identifiers, status, and limited payment details needed to manage payments and refunds. See Stripe's Privacy Policy.

DocuSeal. We use DocuSeal for electronic signing of ACH authorizations. We provide the information needed to prepare and deliver your authorization, which can include your name, selected email address or phone number, address, bank details, order amount, and bank connection timeline. The signed document and associated audit records are retained as evidence of authorization. See DocuSeal's Privacy Policy.

These providers process information under their own applicable privacy notices as well as their arrangements with us. Please review their notices when using their services.

6. How we share information

We share information with payment, bank connection, identity verification, electronic signature, hosting, communications, and other service providers as needed to operate the Services. Authorized staff and agents handling your order may access relevant booking, payment, bank verification, and authorization information; access to identity verification information is limited to personnel who need it for the purposes described above. We may also disclose information when required by law, to respond to lawful requests, to protect rights and prevent fraud, or in connection with a merger, acquisition, or transfer of our business, subject to applicable safeguards. Disclosures of biometric data remain subject to the consent and other restrictions imposed by applicable biometric privacy laws.

We do not use this payment website to sell personal information or share it for cross-context behavioral advertising.

7. Cookies and third-party website features

We use cookies and browser session storage to maintain sessions, protect requests, recognize a checkout, and resume a bank connection. You can manage cookies in your browser, but blocking them may prevent checkout or signing from working.

The website loads fonts from Google and may offer Google address suggestions when enabled. These features can send your IP address, browser information, and, for address suggestions, the text you enter to Google. See Google's Privacy Policy. Payment, signing, and identity verification services may also use their own cookies and similar technologies. A verification flow can collect device and network information to maintain the session and detect fraud, and request camera access for document capture, selfies, or liveness checks.

The Services do not currently change their behavior in response to a browser's Do Not Track signal. This does not limit any rights you have under applicable law.

8. Retention, deletion, and security

We retain information for as long as reasonably needed for the purposes described here, including completing services, maintaining authorizations and financial records, meeting legal obligations, preventing fraud, and resolving disputes. Retention depends on the type of record and the applicable requirements. Disconnecting a bank account stops future access through that connection but does not automatically delete information or authorizations already obtained.

For identity document images, selfie or liveness media, and verification records, the relevant criteria include whether a check or related review is still open, whether the information is needed for a specific fraud investigation or dispute, and whether a legal retention requirement applies. Keeping an order, payment record, or verification result does not by itself require retaining the underlying biometric data. Where Sumsub holds data on our behalf, Bonums is responsible for setting retention instructions and requesting deletion when the applicable purpose or retention period ends.

Biometric retention and destruction

The following requirements apply to biometric data under Bonums' control, including data held on our behalf. They take precedence over the general retention criteria above wherever the relevant law applies, subject to exceptions expressly provided by that law:

• Illinois: permanently destroy biometric identifiers and biometric information when the original collection purpose has been satisfied or within three years of your last interaction with Bonums, whichever occurs first.
• Texas: destroy biometric identifiers within a reasonable time after their collection purpose ends, and no later than one year after that purpose expires, subject to the specific statutory exception for legally required records.
• Washington: retain biometric identifiers no longer than reasonably necessary to provide the requested service, address fraud or security risks, or meet the legal requirements permitted by the applicable law.

These are legal limits, not default periods for keeping every verification record. A shorter applicable period takes precedence. Deletion must address copies controlled by Bonums and instructions to processors holding the data on our behalf. Sumsub's independent processing and retention are described in its own notices.

We use access controls and other technical and organizational measures to protect information. No internet transmission or storage system can be guaranteed to be completely secure.

9. Your choices and privacy rights

You can choose whether to connect a bank account and may use another payment method when available. To request that we disconnect a bank connection, or to request access to, correction of, or deletion of your information, contact us using the details below. You may also manage supported connections through Plaid Portal. A request to disconnect or delete data does not itself cancel a booking, payment obligation, or an authorization already given.

Depending on your location and which laws apply, you may have rights to know about and obtain a copy of your personal information, correct inaccuracies, request deletion, restrict or object to certain processing, or withdraw consent where processing is based on consent. California residents may also have rights to opt out of sale or sharing, limit certain uses of sensitive personal information, and receive equal service when exercising applicable privacy rights. These rights are subject to legal conditions and exceptions.

For identity verification requests, include enough information to locate your booking or verification, such as the email address used and an order reference. You can request a review of a verification result, withdraw biometric consent, or ask us to arrange deletion of data processed on our behalf. We will explain any applicable reason that prevents us from granting a request. Where a right to appeal applies, you can ask us to reconsider by replying to our response; you may also contact your state's privacy regulator or attorney general.

We may need to verify your identity and, where relevant, an authorized agent's authority before fulfilling a request. We will respond as required by applicable law. Please do not send banking passwords, full card numbers, or other unnecessary financial information in a privacy request.

10. International processing

Bonums is based in the United States. Information may be processed in the United States and other countries where our service providers operate. Privacy laws in those countries may differ from those in your location. Where applicable law requires safeguards for international transfers, those requirements apply to our processing.

Using a verification link from the United States does not mean that all verification information remains in the United States. Sumsub's notices describe processing locations and transfer safeguards, including standard contractual clauses or other lawful mechanisms where applicable. You may contact us for information about safeguards relevant to your data.

11. Children's privacy

Our payment, bank connection, and identity verification Services are intended for adults and are not directed to children under 13. If you believe a child has provided personal information directly through these Services, please contact us so we can investigate and address it.

12. Changes to this policy

We may update this policy to reflect changes to our Services, practices, or legal requirements. We will post the revised policy on this page and update the date above. Where required by law, we will provide additional notice or obtain consent for material changes.