# Privacy Policy

Effective Date: July 29, 2026

This Privacy Policy is provided by Rory Financial Group, Inc. and its UK/EU affiliates (collectively, "Rory Financial", "we", "us", or "our") to developers, business customers, and representatives residing in the United Kingdom (UK) and the European Economic Area (EEA). We process personal data in compliance with the UK GDPR, EU GDPR, and local data protection regulations.

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## 1. Data Controller & Representatives

The data controller is Rory Financial Group, Inc. For our operations in Europe, we designate our UK office as our main representative:
- **Representative:** Rory Financial UK Ltd., 128 City Road, London, EC1V 2NX, United Kingdom
- **Email:** dpo@roryfinancial.com

## 2. Legal Bases for Processing

Under GDPR regulations, we process personal data under the following lawful bases:
- **Contract Performance:** Setting up and managing your developer accounts and routing agreements.
- **Legal Compliance:** Screening transactions against financial sanctions lists, AML compliance, and maintaining audit trails.
- **Legitimate Interests:** Securing our network infrastructure, preventing platform fraud, and optimizing API performance.

## 3. Data Protection Rights

You possess the following rights in relation to your personal data:
- **Access and Portability:** Requesting copies of personal data and transferring it in structured format.
- **Rectification and Erasure:** Requesting corrections to inaccurate data or deleting personal data.
- **Object and Restrict:** Objecting to legítimate interest processing or requesting suspension of processing.

To exercise these rights, please email dpo@roryfinancial.com.

## 4. International Transfers

Data is stored and processed on servers outside the UK/EEA (principally in the US). We secure international transfers using standard contractual clauses (SCCs) approved by the UK Government and the European Commission to ensure equivalent safety standards.

## 5. Complaints

You have the right to lodge a complaint with your local data protection authority, such as the Information Commissioner's Office (ICO) in the UK (www.ico.org.uk).