RayLay Technologies GmbH is in the process of securing [or "has secured"] an Electronic Money Institution (EMI) license in Germany (via BaFin), which will be passportable across the European Economic Area (EEA). We are also registering as a Virtual Asset Service Provider (VASP) to comply with crypto-asset regulations like MiCAR. For fiat on-ramping, we partner with licensed and regulated on-ramp aggregator services that handle direct customer fiat interactions. Our primary role is orchestrating these services and managing crypto-asset ledgering and transfers within our ecosystem and to merchant-designated exchange accounts.

RayLay operates as a technical service provider and orchestrator. The actual collection of fiat funds from end-users and their conversion to crypto is handled by our licensed on-ramp partners. RayLay then manages the crypto assets (primarily USDC on Solana) within its system, providing ledgering services for merchants. The final fiat off-ramp is facilitated by transferring crypto assets to the merchant's own corporate account at a regulated exchange (e.g., Coinbase), from which the merchant controls the fiat withdrawal. Our activities involving crypto-asset management and transfer will be covered by our VASP registration and adherence to relevant EMI licensing requirements concerning safeguarding and operational integrity.

When an end-user pays with fiat, the Know Your Customer (KYC) and Anti-Money Laundering (AML) checks for that initial transaction are primarily performed by our integrated on-ramp aggregator partners (e.g., services like Onramper). These partners are regulated entities responsible for verifying the identity of the fiat remitter. RayLay ensures its partners meet stringent compliance standards. We conduct our own KYC/AML on merchants onboarding to the RayLay platform.

Fraud prevention is multi-layered. Our on-ramp partners employ their own robust fraud detection for fiat transactions (e.g., card payments). RayLay adds an additional layer by monitoring crypto transaction patterns within our ecosystem for suspicious activity. We also provide merchants with tools and best practices. For direct crypto payments (SOL/USDC from user wallets), the inherent nature of blockchain reduces certain types of fraud, though chargeback mechanisms differ.

When fiat is on-ramped, it's converted to crypto (typically USDC on Solana) and held in RayLay's secure, institutional-grade custodial wallets, segregated operationally per merchant. These wallets utilize multi-signature security and industry best practices. Merchants have a clear view of their crypto balance within their RayLay dashboard. RayLay itself does not typically hold large fiat balances for merchants; the model is designed for crypto settlement and subsequent transfer to the merchant's exchange account for fiat off-ramping.

Our primary and most cost-effective payout method involves RayLay transferring the merchant's accumulated crypto (e.g., USDC) balance to their pre-verified corporate account at a major cryptocurrency exchange like Coinbase. The merchant then initiates a fiat withdrawal (e.g., SEPA for EUR, ACH for USD) from their Coinbase account to their bank. Coinbase offers free or very low-cost withdrawals for these methods. RayLay's role is the secure transfer of crypto to the merchant's exchange account. We may offer direct crypto-to-fiat payouts as a secondary, potentially higher-cost option via licensed partners in the future.

RayLay primarily settles transactions in stablecoins like USDC on Solana to minimize volatility during the transaction and holding period within our system. When fiat is on-ramped, it's converted to USDC almost immediately. Merchants hold USDC in their RayLay balance. They can configure preferences within their RayLay dashboard regarding their risk appetite, for instance, choosing to hold primary balances in USDC or, for advanced users, potentially opting into automated strategies to convert portions to other assets like SOL or even yield-bearing instruments (subject to feature availability and regulatory considerations). The merchant assumes volatility risk for any non-stablecoin assets they choose to hold or convert to.

RayLay is committed to GDPR and other applicable data privacy laws. For merchant onboarding, we collect necessary business information. For end-user fiat transactions, our on-ramp partners are responsible for initial PII collection and GDPR compliance. RayLay receives anonymized or pseudonymized transaction data required for processing and ledgering. We implement robust technical and organizational measures to protect any data we process, including encryption and access controls. Our Privacy Policy and DPA (for merchants) detail our data handling practices.

No. Personally Identifiable Information (PII) such as names, addresses, or full card details of end-users are not stored on the public Solana blockchain by RayLay. Blockchain transactions managed by RayLay involve transfers of crypto-assets (like USDC) between RayLay's operational addresses and addresses linked to merchant balances. These on-chain transactions typically show wallet addresses, amounts, and transaction IDs, but not direct PII of the original fiat payer.

Chargeback handling depends on the initial payment method used by the customer via the on-ramp aggregator:

• Card Payments: Standard card network chargeback rules apply. The on-ramp provider that processed the card payment will manage the dispute. RayLay will facilitate providing any relevant transaction data we hold to assist merchants in the dispute process.
• Bank Transfers (ACH/SEPA): Reversal capabilities vary by region and bank. Disputes are handled through the banking system via the on-ramp partner.
• Direct Crypto Payments (SOL/USDC from user wallet): Transactions on Solana are irreversible. Merchants are responsible for their own refund policies for direct crypto payments. RayLay provides tools to facilitate refunds from the merchant's balance if they choose to issue one.

Merchants using RayLay will be advised on best practices for managing dispute risks associated with different payment methods.

RayLay's primary settlement asset within our system is USDC on Solana due to its stability and wide acceptance. Merchants hold USDC balances. Future enhancements may allow merchants to configure preferences for automatic conversion of a portion of their incoming USDC balances into other assets like SOL or BTC, or to allocate funds to select, vetted yield-bearing DeFi protocols directly from their RayLay dashboard. Such features will be subject to clear risk disclosures, user consent, and regulatory compliance. Initially, the focus is on USDC settlement and efficient fiat off-ramping.