Your information and choices
Privacy Policy
Bokolo Cash is the Digital Solomon Islands Dollar (e-SBD) wallet published by the Central Bank of Solomon Islands (CBSI) through Bokolo Hub. This notice covers the Android and iPhone wallets, their account services and associated support during the Bokolo Cash pilot in Solomon Islands.
You choose a participating financial institution (FI): POB, BRED, ANZ, BSP, M-Selen or EziPei. CBSI is responsible for the app and payment-system services. Your FI is responsible for its customer relationship, identity checks and financial-compliance obligations.
You can request account deletion from the Android app or without installing it. See the request options and what happens to your data.
Information we use
- Account and contact details: your name, email address and/or phone number, address, country/residency details, wallet alias, account identifiers, selected FI, public signing keys and verification status.
- Identity verification: when required, your date of birth, source of funds, identity and supporting-document images, selfie, and KYC, screening and account-limit decisions. These records are handled through the selected FI’s KYC vault.
- Payments: amounts, balances, wallet or linked-account references, counterparties, transaction identifiers, times, status and optional memos. A person receiving your payment or scanning your QR request can receive the details included in it.
- Device and security records: device/installation identifiers, app version, push token, authentication events, network IP address and user-agent where available, hardware-attestation and app-integrity evidence, and cryptographic records needed to authorize and recover payments.
- Recovery and support: encrypted wallet backups and lookup metadata when you use recovery features, plus the information you submit in a support or privacy request. Optional Google Drive backup uses the app’s private data area in the Google account you authorize. You can instead keep the encrypted backup with your selected FI’s Bokolo Cash service, linked to Sign in with Apple.
Why we use it
We use this information to create and secure accounts, verify contact details and identity, process payments, provide history and notifications, support account recovery, prevent fraud, respond to requests and meet record-keeping obligations. Bokolo does not sell personal data or use it for advertising. The apps do not include Google Analytics or Crashlytics.
Who receives information
Your selected FI handles onboarding, account services and its own legal/compliance responsibilities. CBSI handles payment-system and supervisory responsibilities. SORAMITSU and approved hosting providers support the technology under the operating instructions and access controls of CBSI/FIs; Bokolo does not authorize them to sell data, advertise to you or reuse it for unrelated profiling.
Twilio supports verification-message delivery when that service is used. Its terms also cover its own communications-usage, security, abuse-prevention and legal purposes. On Android, Google Firebase Cloud Messaging and Firebase Installations support notifications and installation identifiers; on iPhone, Apple Push Notification service delivers notifications. Google/Apple sign-in, Google Play Integrity, Apple App Attest, Google Nearby Connections on Android and optional Google Drive backup involve the provider you use and its applicable terms. These services can process information internationally.
Payment counterparties receive the information needed for your payment or request. Required information may also be disclosed to authorized regulators, law enforcement or courts. We limit each disclosure to its purpose and do not describe every recipient as acting solely on our instructions.
Provider information: Twilio data terms and Firebase privacy and retention.
Device permissions and security
- Camera and photos: the camera scans QR codes and captures identity documents. On iPhone, photo access lets you attach identity documents and save a QR code when you choose.
- Offline payments: offline payments pass between two phones by QR code, tap or Nearby, whichever you choose. QR code uses the camera to scan the other phone’s code. Tap uses NFC while the two phones are held together. Nearby finds and connects to the other phone over Bluetooth and Wi-Fi.
- On iPhone: tap uses NFC, and Nearby asks for Bluetooth and local network access.
- On Android: tap uses NFC, which Android grants when the app is installed. Nearby uses Google’s Nearby Connections and needs the Nearby devices permission on Android 12 and later, and local network access on Android 17 and later. On Android 12 and earlier, Android requires location permission for Nearby’s device scanning, so Nearby also asks for location there. The wallet does not use this permission to read or record your location. Nearby needs Google Play services; QR code and tap do not.
- Biometrics: unlocking uses the phone’s own security: Face ID, Touch ID or the passcode on iPhone, and fingerprint, face or screen lock on Android. The device supplies an authentication result; Bokolo does not obtain your biometric template.
- Notifications: notification permission controls whether notifications appear. On Android, Firebase installation identifiers and messaging tokens are created when the app starts, even if you decline that permission. Verified account closure triggers deletion of both identifiers and disables their automatic re-creation for the closed account.
- Your choices: the apps do not request access to your contacts, microphone, SMS inbox or call history. You can revoke app permissions in the phone’s settings; some features may stop working when you do.
Service connections use HTTPS. Local secure preferences and uploaded recovery backups are encrypted. KYC documents and submission metadata are encrypted before vault storage, with controlled decryption access. Hardware-backed app keys and ledger-account keys serve separate purposes. A valid enrollment does not by itself establish protection against competing offline payments; KAGEMUSHA payment features require the applicable qualified-device and protocol checks.
How long information remains
Deleting the app account removes access and data that no longer need to be retained. Some financial records must remain available for compliance, security, disputes or a specific legal hold. Retained records are restricted to those purposes.
| Information | Retention rule |
|---|---|
| Payment records | The later of ten years after the record was first received/created or six years after the transaction completed. |
| KYC and relationship records | The later of ten years after first receipt/creation or seven years after the FI relationship closes. The seven-year closure period is Bokolo’s operating policy. |
| Regulatory/audit records | Ten years after creation, with any longer applicable report/enquiry requirement or legal hold. Necessary account-to-ledger identity links remain while their related records are retained. |
| Live access and optional data | Access credentials, device/push bindings, optional recovery material and non-retained profile/preferences are removed through the verified closure process. Pending financial obligations must first be resolved. |
| Backups and providers | CBSI/FI-managed copies of non-retained data expire within 90 days after verified closure. Firebase documents up to 180 days after an installation-ID deletion request. User-controlled backups and independent provider records have separate controls, explained in the completion response. |
Specific lawful holds can extend a record’s deadline. We review holds regularly and remove eligible records after their retention period and holds end. A minimal request/deletion receipt is kept for ten years; it excludes private keys, tokens and identity-document images. Historical ledger/payment records and a counterparty’s copy are not erased by uninstalling the wallet.
Your requests and contact
In the Android app, open More → Privacy & account data → Request account deletion. On any phone, you can follow the public deletion instructions. You may also request access to or correction of your information through your selected FI or CBSI at info@cbsi.com.sb.
We aim to acknowledge requests within two business days and resolve verified deletion requests within 30 calendar days. If financial obligations, a lawful hold or provider work delays completion, we explain the next step and what remains. We verify ownership before changing an account or disclosing its records.
We update the version date when this notice changes. Material changes to the data practices will be reflected here and in the app’s disclosures.
Bokolo Cash