ROOTPAY TECHNOLOGY, INC. ("Rootpay", "Company", "We", "Us", or "Our") is committed to safeguarding your privacy. This Privacy Policy ("Policy") describes how we collect, use, maintain, protect, and disclose information obtained from users of our mobile and web-based application ("App" or "Platform"), as well as our practices regarding the handling of such information.

Rootpay Technology, Inc. is incorporated under Delaware law with its registered office at 8 The Green #14621, Dover, Delaware, 19901.

1. SCOPE AND APPLICATION

This Policy applies exclusively to personal information collected or received through our App and Services. It does not govern information collected through websites or services not under our control, including external websites you may access through links on our App, or information you provide directly to third parties. Such third parties maintain their own privacy policies, which we encourage you to review before providing any information to them.

For questions, inquiries, requests, or concerns regarding this Privacy Policy, please contact us at: admin@rootpay.finance or legal@rootpay.finance. You may also reach us by phone at +91 9953260592.

2. ROOTPAY’S ROLE AND THIRD-PARTY SERVICE PARTNERS

Rootpay partners with the following licensed third-party service providers who deliver actual financial services and process your information:

• "Cybrid" – Licensed provider for digital asset onboarding, custody, and related services;
• "Plaid" – Licensed provider for secure bank account connections and verification services;
• "Mudrex" – Licensed provider for digital asset offboarding, exchange, and related services.

Your personal information will be collected, processed, and retained by these service providers in accordance with their respective privacy policies. By using our Services, you consent to the collection, use, and sharing of your personal information by these service providers. Their privacy policies are available at:

• linkCybrid Privacy Policy
• linkPlaid Privacy Policy
• linkMudrex Privacy Policy

3. INFORMATION WE COLLECT

4. HOW WE USE YOUR INFORMATION

Rootpay uses information to operate the platform and facilitate connections with service providers. Our service providers use your information to:

1. Deliver financial services, including transaction processing, account administration, and customer support;
2. Verify your identity and perform KYC/AML compliance checks as mandated by applicable laws and regulations;
3. Detect, prevent, and respond to fraud, security threats, and other prohibited or illegal activities;
4. Fulfill legal obligations, including responding to lawful requests from government authorities;
5. Send service-related communications, including account notifications, transaction confirmations, and security alerts;
6. Enforce their respective terms of service and protect rights, property, and safety.

Rootpay uses platform usage data to enhance the App, analyze usage patterns, and provide technical support.

5. DISCLOSURE AND SHARING OF INFORMATION

Rootpay shares limited information necessary to facilitate Services. Personal information is primarily disclosed:

1. With our service providers (Cybrid, Plaid, Mudrex) to enable them to deliver their licensed financial services;
2. By our service providers with their respective partner financial institutions as necessary for transaction processing;
3. To comply with court orders, laws, or legal processes, including responses to government or regulatory requests;
4. To enforce or apply our Terms of Service and other contractual agreements;
5. When we believe disclosure is necessary to protect rights, property, or safety, including exchanging information for fraud prevention purposes.

6. DATA RETENTION PRACTICES

Rootpay retains minimal platform usage information for as long as necessary to operate the platform and comply with legal obligations. Our service providers retain your personal information according to the following principles:

1. Throughout the duration of your active use of their respective services;
2. For periods mandated by applicable laws and regulations, including anti-money laundering laws (typically 5-7 years), tax laws, and financial regulations;
3. For purposes including dispute resolution, agreement enforcement, and protection of legal rights;
4. Even following account closure, certain information may be retained as required or permitted by applicable law.

7. INFORMATION SECURITY MEASURES

Rootpay and our service providers have implemented security measures designed to protect your personal information from accidental loss and unauthorized access, use, alteration, and disclosure:

1. All data transmitted through Rootpay’s platform is encrypted using secure socket layer (SSL) technology;
2. Our service providers maintain sensitive information on secure servers protected by firewalls;
3. Access to personal information is limited to authorized personnel only;
4. Our service providers employ industry-standard security practices and comply with applicable data security regulations.

However, internet data transmission is not completely secure, and we cannot guarantee absolute security of personal information transmitted through our App. Any transmission of personal information occurs at your own risk.

8. YOUR PRIVACY RIGHTS AND CHOICES

Depending on your jurisdiction, you may have certain rights regarding personal information held by our service providers, including:

• The right to access and obtain a copy of your personal information;
• The right to rectify inaccurate or incomplete personal information;
• The right to request deletion of your personal information, subject to legal retention obligations;
• The right to object to or restrict certain processing activities involving your personal information;
• The right to data portability for your personal information.

To exercise these rights, contact us at legal@rootpay.finance. We will coordinate with our service providers to fulfill your request. Please note that identity verification may be required, and certain rights may be limited when necessary to comply with legal obligations or protect legitimate interests.

9. CROSS-BORDER DATA TRANSFERS

Your information, including personal data, may be transferred to and stored on computers located outside your jurisdiction, where data protection laws may differ from those in your region. Our service providers may operate across multiple jurisdictions. By using our Services, you consent to the transfer of your information to the United States and other locations where we or our service providers conduct operations. We and our service providers will take all reasonably necessary steps to ensure your data is treated securely and in accordance with this Privacy Policy and applicable data protection laws.

10. CHILDREN’S PRIVACY PROTECTION

Our Services are not designed for or directed to individuals under 18 years of age. We do not knowingly collect personal information from minors under 18. If we discover that we have inadvertently collected or received personal information from a minor without parental consent verification, we will promptly delete such information. If you believe we possess information from or about a minor under 18, please contact us immediately at legal@rootpay.finance.

11. POLICY UPDATES AND MODIFICATIONS

We may update this Privacy Policy periodically. Material changes to our treatment of user personal information will be communicated via email to the address associated with your account or through a prominent notice in the App. The date of the most recent revision is displayed at the top of this document. You are responsible for maintaining an up-to-date, active, and deliverable email address, and for periodically visiting https://www.rootpay.finance/legal/privacy to review any modifications.

12. EXPRESS CONSENT TO DATA PRACTICES

By using our Services, you expressly consent to:

• The collection, processing, and storage of your personal information by our service providers as described in this Policy;
• The sharing of your personal information with our service providers (Cybrid, Plaid, Mudrex) and their respective partner institutions for the purpose of delivering financial services;
• The retention of your personal information by service providers for periods mandated by law and as specified in this Policy;
• The transfer of your personal information to jurisdictions outside your country of residence, which may have different data protection laws;
• The use of your personal information by service providers for KYC/AML compliance, fraud prevention, transaction processing, and other purposes described in this Policy.

13. THIRD-PARTY SERVICES AND EXTERNAL LINKS

Our App may contain links to third-party websites, applications, or services not owned or controlled by Rootpay. We exercise no control over, and assume no responsibility for, the content, privacy policies, or practices of third-party websites or services. We encourage you to review the privacy policies of third-party services before providing them with personal information. This includes the privacy policies of our service providers (Cybrid, Plaid, Mudrex), which govern their collection, use, and protection of your information.

14. LEGAL AND REGULATORY COMPLIANCE

Rootpay and our service providers are committed to complying with all applicable data protection and privacy laws, including but not limited to:

• Anti-Money Laundering (AML) regulations;
• Know Your Customer (KYC) requirements;
• Counter-Terrorist Financing (CTF) laws;
• Bank Secrecy Act (BSA) and USA PATRIOT Act requirements;
• Data protection and privacy laws applicable in your jurisdiction;
• Financial services and payment processing regulations.

We and our service providers may be required to disclose your personal information to government authorities, regulatory agencies, law enforcement, or other third parties without your consent when required by law or when we believe such disclosure is necessary to comply with legal obligations, protect our rights, or ensure user safety.

15. GRIEVANCE RESOLUTION PROCEDURE

For grievances or complaints regarding the processing of your personal information, contact our Compliance Officer, Saras Agrawal, at saras@rootpay.finance or +91 9953260592. We will acknowledge receipt of your complaint within two (2) business days and work to resolve it within thirty (30) days from receipt. For complaints concerning information held by our service providers, we will coordinate with them to address your concerns.