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Privacy Notice

Effective date: [launch date] · Last updated: [launch date]

1. Introduction

Cloud Excel LLC ("Cloud Excel", "we", "our") respects your privacy and is committed to protecting the personal information collected in the course of your interaction with our website, client portal and international payment services.

This Privacy Notice is issued pursuant to the Gramm-Leach-Bliley Act (15 U.S.C. §§ 6801–6809) and Regulation P (12 CFR Part 1016), in addition to other applicable federal and state laws, including the Florida Information Protection Act of 2014 (Fla. Stat. § 501.171) and the Florida Digital Bill of Rights (Fla. Stat. §§ 501.701–501.722).

2. Scope and application

This Privacy Notice applies to:

  • Visitors to the cloud-excel.com website
  • Representatives of companies submitting contact forms, quote requests or onboarding documents
  • Cloud Excel corporate clients and their authorized users
  • Beneficial owners, directors, partners and legal representatives
  • Counterparties to transactions (end payers and beneficiaries) whose information is collected in connection with our compliance requirements

3. Information we collect

3.1 Information you provide directly

  • Identification: full name, date of birth, nationality, document number (passport, national ID, SSN, ITIN, foreign tax ID)
  • Contact: residential and business address, email, telephone
  • Corporate data: legal name, EIN, jurisdiction of incorporation, company registration number, industry, beneficial owners (≥25%), ownership structure
  • Financial data: bank information, wallet data, transaction volume, source of funds and source of wealth, invoices, commercial contracts
  • Documents: Articles of Organization, Operating Agreement, passport, proof of residence, corporate licenses, bank statements, financial statements
  • Credentials: username, password, multi-factor authentication methods
  • Communications: emails, portal messages, call logs, interactions with support

3.2 Information collected automatically

  • IP address, approximate geographic location, time zone
  • Browser type and version, operating system, device
  • Pages accessed, session duration, traffic source
  • Cookies, web beacons and similar technologies (see our Cookie Policy)
  • Authentication logs, access attempts and portal activity

3.3 Information collected from third parties

  • Identity verification and KYB/KYC services
  • Sanctions screening providers (OFAC, UN, EU, UK, PEP, adverse media)
  • Blockchain analytics providers
  • Corporate information bureaus and public official sources
  • Banking partners and institutional liquidity providers
  • Regulators and competent authorities, when required by law

4. How we use your information

  • Regulatory compliance: CIP, CDD, EDD, OFAC screening, Travel Rule, SAR, CTR, Bank Secrecy Act, mandatory record retention (minimum of 5 years after termination of the relationship, per 31 CFR § 1010.430)
  • Assessment of eligibility as a client
  • Execution of international payment transactions
  • Portal account management and support
  • Fraud, money laundering and terrorism financing prevention
  • Information security and detection of unauthorized access
  • Operational communications (confirmations, alerts, regulatory notices)
  • Marketing communications, only with your prior express consent (TCPA 47 U.S.C. § 227, CAN-SPAM)
  • Compliance with legal obligations, including response to subpoenas and regulatory requests

5. Legal basis for processing

  • Compliance with a legal obligation (BSA, AML, OFAC, regulatory)
  • Performance of a contract
  • Cloud Excel's legitimate interest in operating securely
  • Data subject's consent, where applicable

6. Sharing of information

Cloud Excel does not sell, rent or trade your personal information.

6.1 With service providers

  • Identity verification providers (KYC/KYB)
  • Sanctions screening and adverse media providers
  • Blockchain analytics providers
  • Correspondent banks and liquidity partners
  • Infrastructure providers (hosting, security, email, backup)
  • Legal, accounting and audit advisors

6.2 With competent authorities

  • FinCEN (including via SAR and CTR)
  • OFAC
  • Florida Office of Financial Regulation
  • Internal Revenue Service and other tax authorities
  • Judicial and law enforcement authorities upon legal order
  • Foreign regulators, through official channels

6.3 In corporate transactions

In a merger, acquisition, restructuring or asset sale, your information may be transferred to the successor entity, subject to the protections described in this Notice.

7. International data transfers

Cloud Excel operates primarily from the United States. Your information may be transferred to, stored in and processed in the U.S. and in other jurisdictions where our providers operate. For clients in Brazil, protections analogous to the LGPD (Law 13,709/2018) apply. For the EU/UK, Standard Contractual Clauses are applied when required by the GDPR/UK GDPR.

8. Information security

  • Encryption in transit (TLS 1.2+) and at rest (AES-256)
  • Role-based access control (RBAC)
  • Multi-factor authentication for administrative users
  • Immutable audit logs
  • Periodic vulnerability and penetration testing
  • Formal incident response program
  • Ongoing team training

No system is 100% secure. In the event of an incident affecting your information, we will notify you and the authorities as required by Fla. Stat. § 501.171.

9. Retention of information

We retain your information for as long as necessary to comply with regulatory obligations (minimum of 5 years after the end of the relationship, 31 CFR § 1010.430), meet tax and accounting obligations, defend rights in proceedings, and respond to requests from authorities. After the applicable periods, information is anonymized or securely destroyed.

10. Your privacy rights

10.1 Florida residents (Florida Digital Bill of Rights)

  • Confirm processing and access information
  • Correct inaccurate information
  • Request deletion (subject to regulatory exceptions)
  • Data portability
  • Opt-out of targeted advertising, sale of data, or profiling with significant effects

10.2 California residents (CCPA/CPRA)

  • Know, delete, correct, opt-out of sale/sharing
  • Non-discrimination for exercising these rights

10.3 Brazil residents (LGPD)

  • Confirmation, access, correction, anonymization, blocking, deletion
  • Portability, sharing, revocation of consent

10.4 EU and UK residents (GDPR / UK GDPR)

  • Access, rectification, erasure, restriction, portability, objection, and automated decisions

10.5 Regulatory limitations

Certain information cannot be deleted for as long as a legal retention obligation for U.S. MSBs applies. In such cases, we will inform you of the reason for the refusal and the applicable retention period.

11. How to exercise your rights

Send your request to privacy@cloud-excel.com or by mail:

Cloud Excel LLC — Privacy Officer
2801 NW 74th Avenue, Suite 208
Miami, FL 33122 — United States

We may request additional information to verify your identity. We will respond within the applicable legal timeframe (30–45 days depending on jurisdiction).

12. Cookies and tracking technologies

See our Cookie Policy.

13. Children

Cloud Excel's services are not directed to individuals under 18. We do not knowingly collect information from children.

14. Changes to this Privacy Notice

We may update this Privacy Notice periodically. The "Last updated" date indicates the current version. Material changes will be communicated in advance by email or through the portal. We maintain a versioned history in compliance with Fla. Stat. § 560.1105 and Rule 69V-560.1012, F.A.C.

15. Contact

Cloud Excel LLC
2801 NW 74th Avenue, Suite 208
Miami, FL 33122 — United States
Phone: +1 (305) 333-0780
Email: privacy@cloud-excel.com

16. Language prevalence

The English version of this Privacy Notice prevails in case of any inconsistency with translations into Portuguese, Spanish, Mandarin or any other language.