Privacy Policy

RORO Holdings Inc. ("RORO Holdings," "we," "us," or "our") operates roroholdingsinc.com (the "Website") as a general corporate information site about our non-operating holding company and group structure.

This Privacy Policy explains how we collect, use, disclose, and protect information when you visit the Website or communicate with us by email. It also describes your choices and rights. Use of the Website is subject to our Terms of Use.

Data controller: For purposes of this Website, the data controller is RORO Holdings Inc., a Delaware corporation operating as a non-operating holding company. Contact: contact@roroholdingsinc.com.

This Privacy Policy applies to:

• Visitors to roroholdingsinc.com;
• Individuals who email us through addresses published on the Website; and
• Individuals whose technical data is processed when the Website is loaded in a browser.

This Privacy Policy does not apply to:

• Third-party websites linked from the Website, including rorotechnology.io (RORO Technology LLC) or rorostrategicholdings.com (RORO Strategic Holdings Ltd);
• Offline agreements or private communications not initiated through this Website;
• The password-protected admin area at /admin, which is for authorized personnel only.

We collect limited categories of information:

A. Information you provide by email

If you contact us at contact@roroholdingsinc.com, we receive your email address, message content, subject line, and any information you choose to include (for example, your name, organization, or phone number). We do not operate a public web form on this Website.

B. Technical and usage information

When you visit the Website, our hosting and infrastructure providers may automatically process technical data such as IP address, browser type and version, device type, operating system, referring URL, pages viewed, date and time of access, and error logs. This data is used to deliver, secure, and troubleshoot the Website.

C. Cookies and similar technologies

We use only essential cookies and similar technologies required to operate and secure the Website (for example, load-balancing or session cookies from our hosting provider). We use Google Analytics to understand aggregate Website usage, such as pages viewed, approximate geography, device type, browser, and referral source. We do not use advertising cookies on the public Website. Where required by law, we will obtain consent before placing non-essential cookies.

D. What we do not collect on this Website

• We do not offer securities through this Website;
• We do not collect investor accreditation, KYC, or document-room uploads on this site;
• We do not require public visitor accounts or passwords; and
• We do not knowingly collect payment card information through this Website.

• Directly from you when you send email to addresses published on the Website;
• Automatically through server logs and essential cookies when you browse the Website; and
• From infrastructure providers that host or deliver the Website (for example, cloud hosting, content delivery, or font services).

Where applicable law requires a legal basis, we rely on:

• Legitimate interests — to operate, secure, and improve the Website, understand aggregate usage, and respond to corporate inquiries, balanced against your rights;
• Consent — where you voluntarily email us or where we are required to obtain consent (for example, non-essential cookies if introduced later);
• Legal obligation — to comply with law, regulation, court order, or lawful government request; and
• Contract — where processing is necessary to respond to a request you initiate or to take steps at your request before a potential agreement.

We use information to:

• Respond to inquiries about the holding company and group structure;
• Operate, maintain, secure, and troubleshoot the Website;
• Detect, prevent, and address fraud, abuse, or security incidents;
• Comply with legal obligations and enforce our Terms;
• Maintain internal records and corporate governance documentation; and
• Improve Website performance and content in aggregate, non-profiling ways.

We do not sell personal information. We do not use the public Website to build investor marketing profiles or to offer securities.

We may share information with:

• Service providers — hosting, infrastructure, email, and IT vendors who process data on our instructions (for example, providers that serve the Website or store logs);
• Group entities — RORO Technology LLC, RORO Strategic Holdings Ltd, or other affiliates where needed to respond to an inquiry you directed to the group or to maintain group records;
• Professional advisers — lawyers, accountants, or consultants under confidentiality obligations; and
• Authorities — when required by law or to protect rights, safety, and security.

We may also share information in connection with a corporate transaction (for example, merger, restructuring, or asset transfer) subject to appropriate confidentiality protections.

We are based in the United States. If you access the Website from outside the United States—including from Ghana, the European Economic Area, or the United Kingdom—your information may be processed in the United States and other countries where we or our service providers operate.

Where required by applicable law, we implement appropriate safeguards for cross-border transfers (such as standard contractual clauses or equivalent mechanisms). You may contact us for more information about applicable safeguards.

We retain information only as long as reasonably necessary for the purposes described in this Policy, including:

• Email correspondence — typically for the period needed to respond and maintain corporate records, unless a longer period is required by law or ongoing matter;
• Server and security logs — for a limited operational period consistent with security and troubleshooting needs; and
• Legal holds — longer where required by litigation, investigation, or regulatory obligation.

We use reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, loss, or alteration. No method of transmission over the Internet or electronic storage is completely secure. Email is not a guaranteed secure channel; please do not send sensitive information by email unless we direct you to a secure process.

Depending on your location, you may have rights to access, correct, delete, restrict, or object to certain processing of your personal information, and to data portability or withdrawal of consent where processing is consent-based.

California residents (CCPA/CPRA): We do not sell or share personal information for cross-context behavioral advertising as defined under California law. You may request access to, deletion of, or correction of personal information we maintain about you, subject to legal exceptions.

Ghana: If you are located in Ghana, you may have rights under applicable Ghana data protection law regarding access, correction, and complaint to a supervisory authority. Group entities in Ghana maintain separate policies for their own activities.

To exercise applicable rights, email contact@roroholdingsinc.com with sufficient detail for us to verify your request. We will respond within the timeframe required by applicable law.

The Website is not directed to children under 16 (or the age required by local law). We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will take appropriate steps to delete it.

The Website links to third-party sites and may load third-party resources (such as fonts). Those third parties have their own privacy policies. We encourage you to review their policies before providing information to them.

We may update this Privacy Policy from time to time. The "Last updated" date above shows when it was last revised. Material changes will be posted on this page. Continued use of the Website after changes become effective constitutes acknowledgment of the updated Policy where permitted by law.

Canonical URL: https://roroholdingsinc.com/privacy

Privacy questions or requests may be directed to:

RORO Holdings Inc.
Email: contact@roroholdingsinc.com