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Privacy Notice — Draft

DRAFT ONLY — NOT LEGAL ADVICE — NOT TAX ADVICE. LEGAL REVIEW REQUIRED BEFORE PUBLIC USE.

1. Data minimization

Finscope follows data minimization: we aim to collect only what is necessary to provide and control access to EMIS.

2. Payment data

Finscope does not collect or store card or bank credentials. We do not collect IBAN, card numbers, CVC, API keys or secrets. Payment data is handled by the payment processor, not by Finscope.

3. No PII in payment metadata

No personally identifiable information is placed in payment processor metadata. Billing facts are kept separate from access decisions.

4. Access records

Access to EMIS is controlled by Finscope. Payment does not automatically activate access; access is activated through the Finscope access process.

5. Review

This privacy notice is a draft placeholder and will be finalised subject to privacy/legal review before any public use.