Terms & Policies
Terms of Services
Last updated on March 15, 2026
General
These Terms of Service (“Terms”) govern your access to and use of the Broco website, mobile applications, and any related products and services (collectively, the “Broco Platform” or “Services”) provided by or on behalf of BROCO TECHNOLOGIES and its affiliates, including Broco Technologies .Inc — Delaware and BROCO CANADA INC — BC (each, “Broco”, “we”, “us”, or “our”).
By creating an account, accessing, or using the Services, you agree to these Terms.
If you do not agree, do not use the Services.
CONSUMER NOTICE — NOT A BANK
Broco is not a bank. Unless expressly stated otherwise in a Service Schedule and disclosed to you, the Services are not bank accounts and may not be covered by deposit insurance or depositor protection schemes.
CONTRACTING ENTITY / AFFILIATE
1.1 Contracting party. Your contracting party depends on your location and the product you use. The “Broco Contracting Entity” will be shown to you during onboarding and in your account settings.
1.2 Placeholder table :
Users located in the United States or served commercially via US entity: BROCO INC — Delaware
Users located in Canada or served commercially via Canadian entity: BROCO CANADA INC — BC
1.3 Affiliate performance. Some elements of the Services may be performed by affiliates or third-party partners (including regulated financial partners, payout partners, billers, and logistics carriers). Where a third party provides a regulated or carrier service to you, you may also be subject to that third party’s terms.
DEFINITIONS
DEFINITIONS
“Account” means your Broco user account.
“Agent” means a third-party cash-in/cash-out location or merchant that provides certain Agency Services (as defined below), operating under its own business and subject to Broco’s agent program requirements.
“Agency Services” means cash-in, cash-out, onboarding assistance, bill payments facilitation, and other services offered through Agents, as described in the applicable Service Schedule.
“Broco Cash” means Broco’s cash-in/cash-out network features, as described in Schedule 3.
“Broco Agent Program” means Broco’s onboarding and management of Agents, as described in Schedule 4.
“Business Day” means a day when banks are open in the relevant processing or settlement location (Broco may publish Business Day calendars per corridor).
“Compliance Hold” means a hold, delay, rejection, reversal, or freezing of a transaction or funds due to legal, regulatory, fraud, sanctions, AML/CFT, operational risk, or partner requirements.
“Fees” means any fees, charges, FX margin/spread, delivery fees, agent service fees, card fees, or other amounts payable in connection with the Services, as shown to you before you confirm a transaction (unless otherwise stated).
“Global Account” means a multi-currency ledger and associated features described in Schedule 2. Depending on your corridor and partner setup, it may be provided by Broco and/or by a regulated partner disclosed in the app.
“Local Wallet” means a local-currency stored-value balance or payment account balance offered in certain corridors, as disclosed in-app.
“Payment Instrument” means any funding source you use, such as a bank account, card, transfer, or cash.
“Send Money” means the money transfer/remittance service described in Schedule 1.
“Supported Countries” means the list of countries and corridors where Broco offers one or more Services. The list is published in-app and may change.
“Transaction” means any instruction to send money, convert currency, deposit/withdraw, pay a bill, recharge, or pay for delivery/forwarding via the Broco Platform.
“User Content” means content you submit, upload, or provide through the Services (excluding required KYC data).
“You” or “User” means the person or entity using the Services.
SCOPE OF THESE TERMS
3.1 These Terms cover:
(a) general website/app access and use; and
(b) product-specific terms set out in the Service Schedules.
3.2 If there is a conflict between the General Terms and a Service Schedule, the Service Schedule controls for that product.
3.3 Additional terms. Additional terms may apply to specific features (e.g., cards, promotions, referral programs). We will present them to you when you enable those features.ELIGIBILITY
4.1 Age. You must be at least 18 years old (or the age of majority where you live) to use the Services.
4.2 Capacity. You must have legal capacity to enter into a binding contract.
4.3 Sanctions/ineligibility. You may not use the Services if you are located in, ordinarily resident in, or acting for a person in a sanctioned or prohibited jurisdiction, or if you are on applicable denied-party/sanctions lists.
4.4 Business use. If you use the Services on behalf of a business, you represent that you have authority to bind that business, and “you” includes the business.
SUPPORTED COUNTRIES
Corridors cibles initiaux (non exhaustifs ; susceptibles de modification) : France → Algérie, Maroc, Tunisie, Côte d'Ivoire, Sénégal. La disponibilité et les fonctionnalités varient selon le corridor et peuvent être limitées.
ACCOUNT REGISTRATION AND SECURITY
Account creation. To use certain Services, you must create an Account and provide accurate, complete, and up-to-date information.
5.2 One person, one Account. You may not create multiple Accounts to circumvent limits or enforcement.
5.3 Credentials. You must keep your password, PIN, OTPs, and device access secure. Do not share one-time passcodes with anyone.
5.4 Device and telecom risks. You are responsible for maintaining the security of your device, email, and phone number used for authentication.
5.5 Account activity. You must promptly notify Broco of unauthorized access or suspected fraud.
VERIFICATION, KYC/AML, AND COMPLIANCE
Identity verification. We may verify your identity and eligibility at onboarding and at any time, including by requesting personal information, identity documents, selfies/liveness checks, proof of address, proof of income or source of funds, and information about transaction purpose.
6.2 Risk-based checks. We may apply enhanced due diligence depending on corridor, product, amount, patterns, risk indicators, or regulatory requirements.
6.3 Screening. We may screen Users, recipients, transactions, devices, and counterparties against sanctions, watchlists, adverse media, and fraud indicators.
6.4 Compliance Holds and refusals. We may refuse, delay, cancel, reverse, or freeze a Transaction or funds, or suspend your access, if:
(a) required by law, a court order, regulator, or partner rule;
(b) we suspect fraud or unauthorized activity;
(c) we suspect money laundering, terrorist financing, or other prohibited activity;
(d) information you provided is false, inconsistent, or cannot be verified; or
(e) risk limits are exceeded.
6.5 Information duty. You must provide requested information promptly. Failure may result in declined Transactions, limits, holds, or Account closure.
6.6 Reporting. We may report suspicious activity to competent authorities where required.
PRIVACY AND DATA PROTECTION
Privacy Notice. Our processing of personal data is described in the Broco Privacy Notice: [LINK TO PRIVACY NOTICE].
7.2 Data sharing. You consent to sharing your data with affiliates, regulated partners, payment processors, banking partners, Agents, payout partners, billers, logistics providers, identity verification providers, and authorities as necessary to provide Services, prevent fraud, and comply with law.
7.3 Cross-border transfers. Your data may be processed in countries other than your own, subject to appropriate safeguards as required by applicable law.
USER OBLIGATIONS
Accurate information. You must provide accurate transaction details (recipient name, phone, bank details, delivery address, customs declarations).
8.2 Lawful use. You must use the Services only for lawful purposes and in compliance with these Terms.
8.3 Authorized funds. You must only use Payment Instruments and funds you are authorized to use.
8.4 Cooperation. You must cooperate with investigations, chargeback disputes, complaints processes, and compliance checks.
PROHIBITED USES
You must not, directly or indirectly:
(a) use the Services for illegal activity or prohibited goods/services;
(b) engage in money laundering, terrorist financing, sanctions evasion, fraud, scams, or deception;
(c) submit transactions on behalf of another person without authorization or where prohibited;
(d) manipulate pricing, FX, limits, promo codes, or referrals;
(e) use bots, scrapers, or automated access that burdens the Services;
(f) attempt to reverse engineer, hack, exploit, or disrupt the Services;
(g) use or ship prohibited items (see Schedule 6);
(h) misuse chargebacks or payment disputes.
FEES, FX, AND PRICING
Fees and disclosures. Fees and exchange rates (where applicable) will be shown before you confirm a Transaction, unless otherwise stated.
10.2 Changes. Fees may change. Where required, we will notify you in advance; otherwise changes may apply immediately to future Transactions.
10.3 Third-party fees. Third parties (banks, mobile money operators, billers, carriers, customs) may impose fees, taxes, or deductions outside our control.
TAXES
You are responsible for determining and paying any taxes, duties, and governmental charges applicable to your use of the Services, except where Broco is legally required to collect them.
INTELLECTUAL PROPERTY
Our IP. The Broco Platform, software, trademarks, logos, designs, and content are owned by Broco or licensors.
12.2 License to you. We grant you a limited, revocable, non-exclusive, non-transferable license to use the Services for personal or internal business purposes as permitted.
12.3 Restrictions. You may not copy, modify, create derivative works, reverse engineer, or exploit the Services except as permitted by law.
12.4 Feedback. If you submit suggestions/feedback, you grant Broco a perpetual, worldwide, royalty-free right to use it without obligation.
THIRD-PARTY SERVICES AND LINKS
Third parties. The Services may use third-party providers (e.g., payment processors, identity verification, carriers). Your use may be subject to their terms.
13.2 External links. We are not responsible for third-party websites, content, or services.
SUSPENSION, TERMINATION, AND ACCOUNT CLOSURE
By you. You may request closure of your Account, subject to:
(a) completion of pending Transactions;
(b) compliance holds; and
(c) legal retention obligations.
14.2 By us. We may suspend or terminate your Account immediately if you breach these Terms, violate law, present unacceptable risk, or as required by partners/regulators.
14.3 Post-termination. You remain liable for outstanding Fees, chargebacks, reversals, and obligations incurred before termination.
14.4 Funds on closure. Subject to law and compliance holds, remaining balances will be returned or made available via permitted withdrawal methods. Some corridors may require payout only to verified bank accounts.
DISCLAIMERS
“As is”. The Services are provided “as is” and “as available”.
15.2 No guarantee of availability. We do not guarantee uninterrupted service, delivery times, or that every Transaction will be completed.
15.3 No warranty. To the maximum extent allowed by law, we disclaim implied warranties (merchantability, fitness, non-infringement).
15.4 Not advice. We do not provide legal, tax, or investment advice.
LIMITATION OF LIABILITY
Indirect damages excluded. To the maximum extent permitted by law, Broco is not liable for indirect, incidental, special, consequential, or punitive damages (lost profits, lost data, business interruption).
16.2 Cap. To the maximum extent permitted by law, Broco’s total liability for any claim arising out of or related to the Services is limited to the lower of:
(a) the Fees you paid to Broco for the specific Transaction giving rise to the claim; or
(b) [LIABILITY CAP AMOUNT] in the local currency.
16.3 Exceptions. Nothing limits liability for fraud, willful misconduct, or non-excludable statutory rights.
16.4 Compliance and partner actions. Broco is not liable for delays, refusals, or holds resulting from compliance obligations or partner requirements, provided Broco acted reasonably.
INDEMNIFICATION
You agree to indemnify and hold Broco, its affiliates, directors, officers, employees, and agents harmless from claims, damages, and expenses (including reasonable legal fees) arising from (a) your breach of these Terms, (b) your unlawful activity, (c) prohibited shipments, or (d) your misuse of payment disputes/chargebacks.
COMPLAINTS AND DISPUTE RESOLUTION
Customer support first. Contact us at [SUPPORT EMAIL] with your complaint and transaction reference.
18.2 Investigation. We may request additional information and you agree to cooperate.
18.3 Escalation. If unresolved, escalation routes depend on your corridor and product:
GOVERNING LAW
Governing law is UNSPECIFIED. These Terms will be governed by Laws of the State of Delaware, United States, and disputes will be submitted to Courts of the State of Delaware or the federal courts located in Delaware unless mandatory consumer law provides otherwise.
CHANGES TO THESE TERMS
We may update these Terms. We will post the updated Terms, update the “Last updated” date, and where required provide advance notice. Continued use after the effective date constitutes acceptance.
NOTICES
Electronic communications. You consent to receiving notices electronically (in-app, email, SMS).
21.2 Delivery. Notices are deemed delivered when sent or posted in-app.
FORCE MAJEURE
Broco is not liable for failures or delays caused by events beyond reasonable control (network outages, strikes, government actions, war, pandemics, carrier disruption, customs delays).
ASSIGNMENT
You may not assign these Terms. Broco may assign to an affiliate or successor.
CONTACT
Broco support: support@broco.app
Phone: +33 753 56 26 52
SERVICE SCHEDULES
Schedule 1 — Send Money
Schedule 2 — Global Account (multi-currency wallet/ledger)
Schedule 3 — Broco Cash (cash-in/cash-out)
Schedule 4 — Broco Agent Program
Schedule 5 — Pay Bills & Recharge
Schedule 6 — Package Delivery Europe↔Africa & Package Forwarding
SCHEDULE 1 — SEND MONEY
Definitions
“Sender” means the user initiating a transfer.
“Recipient” means the intended beneficiary.
“Payout Method” means bank deposit, mobile wallet deposit, cash pickup, cash delivery, or other method shown in-app.
“FX Rate” means the exchange rate applied to a transfer, shown before confirmation.
“Transfer Amount” means the amount the Sender pays; “Payout Amount” means the amount the Recipient receives.How Send Money works
2.1 Quote. Before you confirm, we show the Fees, FX Rate (if applicable), expected payout time, and payout method.
2.2 Acceptance. You submit a transfer request; we may accept or reject it in our discretion (including for compliance or risk reasons).
2.3 Completion. A transfer is “Completed” when the payout partner confirms delivery to the Recipient.Funding methods
3.1 You may fund a transfer using supported Payment Instruments (bank transfer, card, wallet balance, cash at Agents, etc.).
3.2 Card payments may be processed by our payment processor(s) (e.g., Stripe) and may be subject to chargebacks and reversals.FX and pricing
4.1 The FX Rate may include a margin/spread and may change until the Transaction is accepted and funded.
4.2 If we offer a “rate lock” or “guaranteed rate”, it applies only for the time shown to you and may be withdrawn if funding is late or risk triggers occur.Limits, holds, and compliance
5.1 Limits. We may impose per-transaction and aggregated limits, which vary by corridor, verification level, and risk.
5.2 Compliance Holds. We can delay or cancel transfers to verify identity/payment instruments, comply with law, or manage risk.Cancellations and refunds
6.1 Pending transfers. You may cancel a transfer while it is still pending, subject to limits and payout partner capability.
6.2 Completed transfers. Once completed, transfers are generally final and may not be reversed unless required by law or in case of fraud/technical error.
6.3 Refund method. Refunds are returned to the original funding source where possible.
6.4 Non-refundable items. Promotional credits, some third-party fees, and carrier/customs charges may be non-refundable.Chargebacks and disputes
7.1 If you fund by card, you agree not to initiate a chargeback except for unauthorized use or where Broco materially breached these Terms.
7.2 If a chargeback occurs, we may recover the amount from you (including from your wallet balances) and may suspend your Account.Sample operational targets (non-binding)
Card-funded transfers: processing target within minutes after successful verification; payout timing depends on corridor and partner.
Bank transfers: processing begins after funds are received; typical 1–3 Business Days (corridor dependent).
Cash pickup/cash out: only during partner/Agent operating hours.
SCHEDULE 2 — GLOBAL ACCOUNT (MULTI-CURRENCY)
Definitions
“Global Account Balance” means your balance(s) displayed in-app by currency.
“Account Details” means local receiving details (if offered), which may route to pooled accounts held by Broco or partners.Nature of the Global Account
2.1 Not a bank account. Unless explicitly stated, the Global Account is not a bank account.
2.2 Funds protection. Where required by law and depending on licensing/partner setup, customer funds may be safeguarded/segregated.
2.3 No overdraft. You may not have a negative balance unless caused by reversals/chargebacks/fees.
2.4 Interest. If interest or yield is offered, it will be governed by separate terms and disclosures and may be provided by a partner product. Interest rates can change and may be taxable.Deposits, withdrawals, and conversions
3.1 Deposits are credited only after we receive cleared funds.
3.2 Withdrawals may be subject to compliance review and limits.
3.3 Currency conversion rates and fees are shown before you confirm.Statements and records
4.1 You can view transaction history and statements in-app.
4.2 You must review statements and notify us promptly of errors.Linked cards. If a card is issued or linked, card terms apply and may be issued by a third party.
SCHEDULE 3 — BROCO CASH (CASH-IN / CASH-OUT)
Definitions
“Cash-in” means depositing cash with an Agent to fund your wallet/balance.
“Cash-out” means withdrawing cash from an Agent against a confirmed wallet/balance debit.
“Float” means cash the Agent keeps to satisfy cash-out requests.Agent role and user obligations
2.1 Agents are independent businesses, not Broco employees. They act under their own obligations and may have corridor-specific mandates.
2.2 You must verify Agent identity (as shown in-app), request a receipt, and confirm amounts before leaving.
2.3 Counterfeit/short payment risk. You are responsible for counting cash and checking receipts at the time of the transaction.How cash-in works
3.1 Cash-in is completed only when the Agent submits the transaction and it is confirmed in your Account.
3.2 Agents may be required to transfer collected funds to Broco/partner accounts promptly; timing may vary by corridor and banking cutoffs.How cash-out works
4.1 Cash-out is available only if you have sufficient cleared balance and the Agent has sufficient Float.
4.2 Cash-out may require OTP/ID checks and may be declined for compliance reasons.Limits and compliance
Cash-in/out limits may apply by verification level, corridor, and Agent type. Limits are shown in-app.Disputes
You must report cash disputes within [24–72 hours] (replace with policy). We may request receipts, CCTV evidence, or Agent logs.
SCHEDULE 4 — BROCO AGENT PROGRAM (FOR AGENTS)
IMPORTANT: This Schedule supplements (and does not replace) an Agent Agreement signed between Broco and each Agent. If there is a conflict, the signed Agent Agreement controls.
Eligibility and onboarding
1.1 Agents must be eligible merchants/businesses with verifiable identity, address, and bank account.
1.2 Broco may perform due diligence, background checks, and ongoing monitoring.Agent obligations (minimum)
2.1 Provide services only at approved locations and hours.
2.2 Follow KYC/AML procedures for transactions as instructed by Broco and as required by law.
2.3 Provide receipts, display pricing, and treat customers fairly.
2.4 Maintain adequate Float for cash-out (if offering cash-out).
2.5 Deposit/transfer collected cash to the designated account within the required timeframes.
2.6 Maintain accurate records and allow audits.Commissions and fees
3.1 Commissions are specified in the Agent Agreement or fee schedule.
3.2 Broco may adjust commissions with notice as allowed by law/contract.Audits and monitoring
Broco may audit transaction logs, reconcile settlements, inspect locations, and require corrective action.Liability and termination
5.1 Agents are responsible for employee misconduct, cash handling losses, and policy violations, subject to mandatory consumer protection law.
5.2 Broco may suspend or terminate Agents for risk, compliance, fraud, or poor performance.
SCHEDULE 5 — PAY BILLS & RECHARGE
Definitions
“Biller” means a third-party merchant/utility/telecom operator integrated into the Service.
“Recharge” means airtime/data/top-up transactions.
Service characteristics
2.1 We transmit your payment instruction to the Biller or aggregator.
2.2 Posting times vary. We do not guarantee that a Biller will post instantly.Failed payments and refunds
3.1 If a payment fails before being posted, we will attempt to reverse and refund, subject to partner rules.
3.2 If a payment is successfully posted, it may be irreversible; contact the Biller for service disputes.Disputes
You must provide transaction references and screenshots. We may investigate with the aggregator.
SCHEDULE 6 — PACKAGE DELIVERY EUROPE↔AFRICA & PACKAGE FORWARDING
Definitions
“Shipment” means the package(s) sent using this Service.
“Sender” means the user who ships.
“Recipient” means the delivery recipient.
“Carrier” means the transport provider (may be a professional carrier or other provider disclosed in-app).
“Traveller” means a private individual offering transport capacity (only if enabled and lawful).
“Customs Duties” means duties/taxes/fees imposed by authorities.Roles and responsibilities
2.1 Marketplace vs carrier. Broco may act as:
(a) a marketplace facilitating matching between Sender and Carrier/Traveller; and/or
(b) a booking/label/intermediation layer for a third-party carrier.
Broco is not the carrier unless explicitly stated on your shipping label/waybill and in-app.
2.2 Customs. Sender and/or Recipient remain responsible for accurate customs declarations, prohibited items compliance, and payment of Customs Duties unless otherwise stated in writing.
2.3 Inspection. Shipments may be inspected by carriers or authorities.Prohibited items
3.1 You must not ship prohibited, restricted, or dangerous goods, including (non-exhaustive): firearms/ammunition, explosives, narcotics, counterfeit goods, cash/bullion, hazardous materials, and items restricted under sanctions/export-control regimes.
3.2 If you ship prohibited items, Broco and/or carriers may refuse, destroy, dispose of, or hand over items to authorities, and you may be liable for costs and penalties.Packaging, labeling, and accuracy
You are responsible for safe packaging, correct labeling, accurate description/value, and providing required documents.Delivery times and tracking
5.1 ETAs are estimates only. Delays may occur due to customs, weather, carrier constraints, or force majeure.
5.2 Tracking is provided where supported; gaps may exist.Fees, duties, and insurance
6.1 Fees include shipping charges and may exclude Customs Duties.
6.2 Optional insurance may be offered. If you want higher protection, you must purchase insurance where available.Claims and liability
7.1 Claims window. You must report loss/damage within [X] days and in any case within the carrier’s claim deadlines.
7.2 Liability cap. Where Broco is not the carrier, the carrier’s liability limitations apply. Where Broco is liable, liability is limited to direct loss only and capped at [CAP] or [SDR/kg REFERENCE], excluding indirect losses.Traveller deliveries. If enabled, you acknowledge:
(a) Travellers are independent and not Broco employees or agents;
(b) Broco does not guarantee Traveller performance;
(c) you must not use Traveller delivery to evade customs, tax, or transport laws;
(d) identity verification and security checks may be required; and
(e) additional restrictions and dispute processes apply.
Privacy Policy
Last updated on April 1, 2026
IMPORTANT: This Privacy Policy is a DRAFT for legal review. It contains placeholders and jurisdiction modules. It must be reviewed and adapted by qualified counsel before publication.
WHO WE ARE (DATA CONTROLLER)
This Privacy Policy explains how we collect, use, disclose, and protect personal data when you use:
(a) our websites, mobile apps, and customer support channels (the “Platform”); and
(b) our services (payments, wallets, cash-in/cash-out, bill pay, and logistics/forwarding, as applicable) (the “Services”).
Controller: BROCO INC — Delaware
Affiliates: BROCO CANADA INC — BC
Support contact: support@broco.app
Depending on where you live and the service you use, a Broco affiliate or a regulated financial partner may be the controller for certain processing (e.g., regulated wallet issuance). The “Controller for your account” will be disclosed in-app in your account settings.
SCOPE AND DEFINITIONS
2.1 Scope. This Policy applies to:
Users, prospective users, recipients (to the extent relevant), Agents, couriers/carriers/forwarders, and business partners.
2.2 Definitions.
“Personal data” means information relating to an identified or identifiable person.
“Processing” means any operation performed on personal data (collection, storage, use, disclosure).
“Controller” means the entity that determines purposes and means of processing.
“Processor” means an entity that processes personal data on behalf of a controller.
PERSONAL DATA WE COLLECT
3.1 Data you provide directly
Identity & contact: name, date of birth, address, email, phone, nationality (where required).
Account credentials: hashed passwords, MFA settings, security questions (if used).
Customer support: messages, call recordings (if legally permitted and disclosed), screenshots, complaint data.
Marketing preferences: opt-ins/opt-outs.
Logistics/shipping: sender/recipient name and address, phone, pickup/drop details, parcel description, declared value, customs-related information and documentation (where required).
3.2 Data we collect automatically
Device and usage: IP address, device identifiers, browser type, app version, language, time zone, crash logs.
Cookies/trackers: identifiers and browsing events (subject to consent where required). See Cookie Policy:
3.3 Data from third parties
Payment processors (e.g., Stripe): payment status, tokenized payment references, dispute/chargeback signals. We do not typically receive full card numbers when you use hosted checkout.
Identity/KYC providers: document authenticity results, liveness checks, risk signals.
Fraud and sanctions screening providers: watchlist/sanctions match indicators, device risk signals, fraud scores.
Payout/wallet/banking partners: account validation, payout confirmation, wallet settlement events (where applicable).
Billers/aggregators: posting confirmations and exceptions.
Logistics carriers/customs brokers: tracking events, delivery confirmation, customs clearance status.
WHY WE PROCESS PERSONAL DATA (PURPOSES)
We process personal data to:
A. Provide the Services (account creation, wallet, send money, bill pay, delivery/forwarding).
B. Meet legal and regulatory obligations (KYC/AML/CFT, sanctions screening, fraud prevention, recordkeeping).
C. Secure the Platform and prevent abuse (security monitoring, access control, incident response).
D. Communicate with you (service notifications, receipts, support).
E. Improve our Services (analytics, debugging, product improvements).
F. Market our Services (where permitted, with opt-out/consent controls).
G. Protect legal rights (claims, disputes, audits, enforcement).LAWFUL BASES (GDPR BASELINE)
Depending on the activity, our lawful bases include:
Contract necessity (to provide the Services you request).
Legal obligation (e.g., KYC/AML recordkeeping, fraud reporting, tax/accounting obligations).
Legitimate interests (security, fraud prevention, improving Services, certain B2B communications), balanced against your rights.
Consent (marketing in certain cases; non-essential cookies; certain biometric processing where required).
Vital interests (rare; e.g., emergencies) where applicable.
If we process biometric data (e.g., facial templates) for uniquely identifying you, we will do so only where permitted by law and with an appropriate Article 9 condition (typically explicit consent or another permitted condition where available), and only to the extent necessary for identity verification and fraud prevention.
KYC/AML AND COMPLIANCE PROCESSING (IMPORTANT)
6.1 Why this is necessary. Financial services often require identity verification, sanctions screening, transaction monitoring, and enhanced due diligence.
6.2 What we process. ID documents, selfies/liveness, proof of address, source-of-funds information (where required), transaction patterns, beneficiary/recipient details.
6.3 Consequences. If you do not provide required information, we may be unable to open your account, provide certain services, or complete transactions. We may also apply compliance holds or restrictions.
In UEMOA jurisdictions (e.g., Senegal, Côte d’Ivoire), we and/or our partners may be subject to BCEAO rules on customer identification and e-money operations that require KYC and secure processing of customer data, and may require disclosures or reporting to competent authorities.
AUTOMATED DECISION-MAKING AND PROFILING
We may use automated systems to detect fraud, assess risk, and enforce compliance (e.g., unusual payment patterns, device anomalies, sanctions screening).
If an automated decision produces legal effects or similarly significantly affects you (e.g., account closure or refusal of service), we will provide appropriate safeguards where required, such as the ability to request human review, to contest the decision, and to provide additional information.WHO WE SHARE PERSONAL DATA WITH
We may share personal data with:
Affiliates (for operations, security, and customer support).
Processors and sub-processors (hosting, analytics, customer support tooling, communications/SMS/email providers).
Payment processors (e.g., Stripe) and financial partners (banks, wallet issuers, payout partners).
Identity verification and screening providers (KYC, sanctions, fraud).
Agents (for cash-in/out) and their compliance/settlement tooling, limited to what is necessary.
Billers and bill payment aggregators (to execute and confirm posting).
Logistics providers (carriers, forwarders, customs brokers) for delivery and customs clearance.
Authorities (regulators, law enforcement), where legally required or permitted.
Professional advisors (auditors, legal counsel) under confidentiality obligations.
We do not sell personal data in the sense of “selling” under typical privacy frameworks; however, we may use cookies and advertising technologies where you consent.
INTERNATIONAL DATA TRANSFERS (OUTSIDE THE EEA)
We may transfer personal data outside the EEA/UK (e.g., to service providers or partners). Where GDPR applies, we rely on:
Adequacy decisions (where available), or
Standard Contractual Clauses (SCCs) and, where needed, supplementary measures (e.g., encryption, access controls), and transfer risk assessments.
DATA RETENTION
We keep personal data only for as long as necessary for the purposes described, including legal and regulatory obligations. Retention depends on the service and your relationship with Broco.
Retention schedule placeholders (to be validated with counsel and regulators):
Account/profile data: life of account +1 years after closure.
KYC/identity records: 2 years after relationship ends or last transaction (AML/legal obligation).
Transaction records (wallet/send money/bills): 3 years (legal/accounting).
Fraud/security logs: 12 months rolling for technical logs; longer where needed for investigations.
Marketing data: until you opt out or 1 years after last interaction.
Logistics/shipping data: 12 months after delivery/claim closure, plus legal retention.
Cookie identifiers: per Cookie Policy / CMP settings.
SECURITY MEASURES
We implement appropriate technical and organizational measures based on risk, such as:
encryption in transit and at rest (where appropriate),
access controls and least-privilege,
logging/monitoring,
vulnerability management and incident response,
vendor due diligence and contractual security requirements.
YOUR RIGHTS (GDPR BASELINE)
Subject to conditions and exceptions, you may have the right to:
Access your personal data
Rectify inaccurate data
Erase data (“right to be forgotten”)
Restrict processing
Data portability
Object to processing (including direct marketing)
Withdraw consent at any time (where processing is based on consent)
Not be subject to certain solely automated decisions, and to request human review
Lodge a complaint with a supervisory authority
To exercise rights: contact support@broco.app and include your account email/phone and request type. We may verify your identity before responding.
If GDPR applies and your main establishment is in France, you may lodge a complaint with the CNIL (Commission Nationale de l’Informatique et des Libertés).
In Canada, you may request access and correction of your personal information and challenge our compliance by contacting our privacy contact. You may also contact the Office of the Privacy Commissioner of Canada.
If Algerian data protection law applies, additional registration/authorization and cross-border transfer constraints may apply. We will comply with applicable Algerian legal requirements and authority instructions.
If Moroccan data protection law applies, certain processing and international transfers may require CNDP formalities/notification/authorization depending on the circumstances.
If Tunisian data protection law applies, certain processing and international transfers may require formalities with the competent authority and compliance with Organic Law 2004-63.
If Senegalese or Ivorian law applies, you may have additional rights and formalities; we will comply with instructions of the competent authorities.
CHILDREN
Our Services are not directed to children under 18. We do not knowingly collect personal data from minors. If you believe a minor provided data, contact us to request deletion.DATA BREACHES
If a personal data breach occurs, we will assess risk and comply with applicable notification obligations (including notification to supervisory authorities and, where required, affected individuals) and maintain breach records.THIRD-PARTY LINKS
Our Platform may contain links to third-party websites. We are not responsible for their privacy practices.CHANGES TO THIS POLICY
We may update this Policy. We will post changes and update the “Last updated” date. Material changes may be notified in-app or by email where required.CONTACT
Support: support@broco.app
Cookie Policy
Last updated on April 1, 2026
WHAT ARE COOKIES AND SIMILAR TECHNOLOGIES?
Cookies are small text files stored on your device by your browser. We may also use similar technologies (SDKs, pixels, local storage, and tags). In this Policy, “cookies” includes these similar technologies.WHY WE USE COOKIES
We use cookies to:
operate and secure the Platform (strictly necessary cookies);
remember preferences (language, region, settings);
measure performance and improve services (analytics, diagnostics);
deliver and measure advertising/marketing (only where you consent).
CONSENT AND COOKIE BANNER (FRANCE/GDPR-FOCUSED)
3.1 Non-essential cookies. Where required, we will not place non-essential cookies until you have provided consent via our CMP.
3.2 Equal choice. Where required (e.g., in France), refusing cookies will be as easy as accepting them (e.g., “Reject all” available on the first layer with similar prominence).
3.3 Withdrawal. You can withdraw or change your consent at any time via [COOKIE SETTINGS LINK — UNSPECIFIED] or “Cookie preferences” in the footer.
Certain analytics cookies MAY be exempt from consent only if configured to meet strict conditions (e.g., limited purpose, limited data, short retention, no cross-site tracking). If we rely on an exemption, we will document configuration and provide the opt-out where required.COOKIE CATEGORIES WE USE
A. Strictly necessary cookies
Required for security, fraud prevention, load balancing, authentication, checkout, and core features.B. Preferences (functional) cookies
Remember choices (language, region, saved settings).C. Statistics (analytics) cookies
Help us understand site usage and improve services.D. Marketing cookies
Used to measure campaigns and deliver personalized advertising (only with consent where required).SAMPLE COOKIES (ILLUSTRATIVE — ACTUAL LIST IN CMP)
The cookies used can change depending on configuration and vendors. The most up-to-date list, purposes, and retention periods will be shown in our CMP.
Examples:
Payment/checkout (Stripe): cookies may be set to support payment security and fraud prevention (e.g., __stripe_mid, __stripe_sid).
Analytics (Google Analytics): _ga (typical duration up to 2 years, configurable).
Experience analytics (Hotjar): hjSessionUser{site_id} (typical 365 days), plus session storage/local storage items depending on configuration.
Marketing (Meta/Facebook): _fbp (often used for campaign measurement; duration depends on configuration).
HOW TO MANAGE COOKIES
6.2 Browser controls. You can manage cookies in your browser settings:
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Note: Disabling cookies may break core functionality.
6.3 Vendor opt-outs (examples)
DO NOT TRACK (DNT)
Some browsers offer a “Do Not Track” setting. Our Services may not respond to DNT signals consistently. Please use the CMP controls to manage tracking preferences.UPDATES
We may update this Cookie Policy. We will post the updated version and revise the “Last updated” date.