Legal
Privacy, terms, cookies, and regulatory information for Rolodex Technologies.
Privacy Policy
Last updated: June 1, 2026
1. Who We Are
Rolodex Technologies Ltd ("Rolodex", "we", "our", or "us") operates the Rolodex platform, providing financial services including cross-border payments, stock and ETF trading, cryptocurrency exchange, savings accounts, and AI-powered financial advisory. Our registered address is 123 Financial District, New York, NY 10004.
2. Information We Collect
We collect the following categories of personal data:
- Identity data: full name, date of birth, government-issued ID, national identification or tax number, selfie and biometric data for identity verification.
- Contact data: email address, phone number, postal address.
- Financial data: bank account details, linked card information, transaction history, portfolio holdings, and balance data.
- Usage data: IP addresses, browser type and version, pages visited, features used, session duration, and click patterns.
- Device data: device identifiers (IDFA, GAID), operating system, hardware model, and network information.
- KYC/AML data: supporting documentation required by applicable anti-money laundering regulations, including proof of address and source of funds declarations.
3. How We Use Your Information
- Providing, operating, and improving our financial services
- Verifying your identity and preventing fraud (KYC/AML compliance)
- Processing transactions and maintaining accurate financial records
- Communicating with you about your account, transactions, and service updates
- Personalizing your experience through Rolo AI recommendations
- Complying with legal and regulatory obligations
- Marketing communications (only with your explicit opt-in consent)
4. Legal Basis for Processing (GDPR)
- Contract performance: processing necessary to provide the services you have requested
- Legal obligation: compliance with financial regulations (KYC, AML, BSA, FATF)
- Legitimate interests: fraud prevention, security monitoring, product improvement
- Consent: marketing emails, optional analytics cookies, personalized advertising
5. Data Sharing
We do not sell your personal data to third parties. We share data only with:
- Regulated banking partners and payment processors (including Stripe and Plaid) under strict contractual agreements
- Identity verification providers (Onfido, Jumio) for KYC compliance
- Regulatory authorities (SEC, FCA, FinCEN, FINTRAC) when legally required
- Cloud infrastructure providers (AWS) under data processing agreements
6. Data Retention
| Data Type | Retention Period | Basis |
|---|---|---|
| Financial transaction records | 7 years post-closure | BSA / regulatory |
| KYC identity documents | 5 years post-relationship | AML regulations |
| Account and profile data | Duration of account + 2 years | Contract |
| Marketing preferences | Until consent withdrawn | Consent |
| Server and access logs | 90 days | Security / legitimate interest |
7. Your Rights
Under GDPR, CCPA, and applicable data protection laws, you have the right to: access your personal data; correct inaccuracies; request erasure (subject to regulatory retention requirements); object to direct marketing; data portability in a machine-readable format; and lodge a complaint with your national supervisory authority.
8. International Transfers
Your data may be processed in countries outside your jurisdiction, including the United States. We ensure adequate protection via Standard Contractual Clauses (SCCs) approved by the European Commission and adequacy decisions where applicable.
9. Security
We implement AES-256 encryption at rest, TLS 1.3 in transit, SOC 2 Type II certified infrastructure, multi-factor authentication, and conduct regular third-party penetration testing. Access to personal data is restricted on a strict need-to-know basis.
10. Contact
Data Protection Officer: dpo@rolodex.com
Rolodex Technologies Ltd, 123 Financial District, New York, NY 10004
Terms of Service
Last updated: June 1, 2026
1. Acceptance of Terms
By creating an account or using the Rolodex platform (the "Service"), you agree to be bound by these Terms of Service ("Terms") and our Privacy Policy. If you do not agree to these Terms, you may not access or use the Service. These Terms constitute a legally binding agreement between you and Rolodex Technologies Ltd.
2. Eligibility
You must be at least 18 years of age, legally capable of entering into binding contracts under applicable law, and a resident of a supported jurisdiction to use Rolodex. We reserve the right to refuse service to any person for any reason at our sole discretion.
3. Account Registration and Security
You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You must:
- Provide accurate, current, and complete information during registration
- Keep your account information updated
- Enable and maintain multi-factor authentication
- Notify us immediately at security@rolodex.com of any unauthorized access
4. Financial Services
Rolodex provides access to the following financial services, each subject to additional terms and regulatory requirements:
- Stock and ETF trading: Commission-free trading executed by our registered broker-dealer partners. Subject to market hours and SEC regulations.
- Cryptocurrency: Purchase, sale, and conversion of 200+ digital assets. Cryptocurrency is not legal tender and is not backed by any government.
- Cross-border payments: Transfers to 150+ countries at mid-market rates. Transfer times and availability vary by corridor.
- Savings accounts: Variable APY savings maintained at FDIC-insured partner institutions. APY is subject to change.
- Debit cards: Physical and virtual cards available to Pro and Advanced tier users.
5. Fees and Pricing
Standard plan: Free. Pro plan: $5.99/month. Advanced plan: $9.99/month. Certain transfers may incur fees disclosed prior to transaction completion. Exchange rates may include a spread. All applicable fees are disclosed clearly before any transaction is confirmed. We reserve the right to modify fees with 30 days' notice.
6. Prohibited Activities
You may not use the Rolodex platform to:
- Engage in money laundering, terrorist financing, or other financial crimes
- Violate any applicable law, regulation, or sanction (including OFAC)
- Engage in market manipulation, wash trading, or spoofing
- Create multiple accounts or provide false identity information
- Access the platform via automated means without authorization
- Circumvent our security or compliance controls
- Use the platform for any activity prohibited by our AML policy
7. Intellectual Property
All content, software, algorithms (including Rolo AI), trademarks, and technology on the Rolodex platform are owned by Rolodex Technologies Ltd and protected by applicable intellectual property laws. You receive a limited, non-exclusive, non-transferable license to use the platform solely for personal financial management.
8. Limitation of Liability
To the maximum extent permitted by applicable law, Rolodex's aggregate liability to you is limited to the greater of (a) the total fees paid by you in the 12 months preceding the claim or (b) USD $100. We are not liable for indirect, incidental, special, or consequential damages, including market losses resulting from your investment decisions.
9. Indemnification
You agree to defend, indemnify, and hold harmless Rolodex Technologies Ltd and its affiliates, officers, directors, employees, and agents from any claims, liabilities, damages, or expenses arising from your use of the Service, violation of these Terms, or infringement of any third-party rights.
10. Governing Law and Dispute Resolution
These Terms are governed by the laws of the State of New York, without regard to conflict of law principles. Disputes shall be resolved by binding individual arbitration in New York, NY under AAA Commercial Arbitration Rules. You waive your right to participate in class action lawsuits or class-wide arbitration. Either party may seek emergency injunctive relief in court.
11. Changes to Terms
We may update these Terms by providing 30 days' advance notice via email or in-app notification. Your continued use of the Service after the effective date constitutes acceptance of the revised Terms. Contact legal@rolodex.com with any questions.
Regulatory
Last updated: June 1, 2026
1. Company Registration
Rolodex Technologies Ltd is incorporated in the State of Delaware, USA (Corporation No. 7891234). Registered and principal office: 123 Financial District, New York, NY 10004, United States.
2. Licenses and Authorizations
| Jurisdiction | License Type | Regulator | Reference |
|---|---|---|---|
| United States | Money Services Business (MSB) | FinCEN | 31000123456789 |
| United States | Money Transmitter (50 states) | State regulators | Multiple licenses |
| European Union | Electronic Money Institution (EMI) | Central Bank of Ireland | IE-EMI-2024-001 |
| United Kingdom | Authorized Payment Institution | Financial Conduct Authority | FCA Ref. 987654 |
| Canada | Money Services Business | FINTRAC | M23456789 |
3. Deposit Insurance
Fiat currency balances held in US Rolodex accounts are maintained in custodial accounts at our FDIC-member banking partners. Each user's funds are eligible for FDIC insurance up to $250,000 per depositor per institution under standard deposit insurance rules, in the event of a bank failure. Cryptocurrency assets are not FDIC-insured and are not covered by SIPC.
4. Investment Services Disclaimer
Rolodex Technologies Ltd is not a registered investment advisor (RIA) with the Securities and Exchange Commission (SEC). Stock and ETF trading executed through the Rolodex platform is facilitated by our registered broker-dealer partners who are members of FINRA and SIPC. Nothing on our platform constitutes investment advice. All investment decisions are made by you at your own risk.
5. Anti-Money Laundering (AML)
We maintain a comprehensive AML compliance program consistent with the Bank Secrecy Act (BSA), FinCEN regulations, applicable state laws, and FATF recommendations. Our program includes:
- Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for higher-risk customers
- Ongoing transaction monitoring and behavioral analytics
- Suspicious Activity Report (SAR) filing with FinCEN as required
- Currency Transaction Reports (CTRs) for transactions exceeding $10,000
- OFAC screening against sanctioned persons and entities
6. Know Your Customer (KYC)
All users must complete identity verification before accessing financial services. This includes providing a valid government-issued photo ID, proof of address, and selfie verification. Enhanced verification may be required for higher transaction volumes or risk levels. We use automated and manual review processes in partnership with Onfido.
7. Consumer Protections
- US residents: rights under the Electronic Fund Transfer Act (EFTA) and Regulation E for unauthorized electronic fund transfers, including a right to dispute transactions
- EU/EEA residents: rights under PSD2 regarding payment service disputes, including chargeback rights for unauthorized transactions
- UK residents: protections under the Payment Services Regulations 2017
8. Complaints Procedure
To file a formal complaint: use in-app support, email compliance@rolodex.com, or write to our compliance team at 123 Financial District, New York, NY 10004. We will acknowledge your complaint within 5 business days and provide a substantive response within 15 business days. Unresolved complaints may be escalated to the relevant regulatory authority in your jurisdiction.
9. Contact
Compliance: compliance@rolodex.com
Legal: legal@rolodex.com
Data Protection Officer: dpo@rolodex.com