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FALKIN LTD

PRIVACY POLICY

December 1, 2025


1. Important information and who we are

This privacy policy describes how Falkin Limited and Falkin Inc. (together, "Falkin", "we", "us" or "our") collects, uses, discloses, and otherwise processes personal data in connection with any specific product, service, or application that references or links to this privacy policy.

If you access and use our services in the UK, Falkin Ltd is the data controller and responsible for the processing of personal data described in this privacy policy. This privacy policy does not cover or address how our partners may process personal data when they use our services, or how we may process personal data on their behalf in accordance with their instructions where we are acting as their processor.

This privacy policy does not address our privacy practices relating to Falkin job applicants, employees and other employment-related individuals, nor data that is not subject to applicable data protection laws.


2. The types of personal data we collect

Depending on the way you access and interact with our services, we may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

We may also collect, use and share aggregated data, such as statistical or demographic data, which does not qualify as personal data under applicable law. For example, we may aggregate individuals' Usage Data for insights into how users are interacting with our services to help improve our services.


3. How is your personal data collected?

We use different methods to collect data from and about you including through:


4. How we use your personal data

The table below contains a description of the purposes for which we process personal data, and the legal basis we rely on to do so.

Purpose/UseType of dataLegal basis (applicable to UK data subjects only)
To register new customers, respond to user requests, manage accounts and support customer service.(a) Identity (b) Contact (c) Customer ContentIf you are our customer, performance of a contract with you. If you are not our customer but an administrative contact at our customer or business partner, necessary for our legitimate interests (to keep our records updated and manage our relationship with you).
To provide services to you, such as scam detection and analysis and troubleshooting / customer support.(a) Identity (b) Contact (c) Customer Content (d) Technical (e) UsagePerformance of a contract with you.
To protect the security and integrity of our business and this website.(a) Identity (b) Contact (c) Customer Content (d) Technical (e) UsageNecessary for our legitimate interests (for network security, to prevent fraud).
To monitor the performance of, identify and resolve bugs and issues with our services.(a) Technical (b) UsageNecessary for our legitimate interests (to prevent or detect technical faults in connection with the provision of the service requested).
To improve user safety through behavioural risk signals collected via our services. To calculate and update Falkin Score, a user-facing digital safety metric.(a) Technical (b) Usage (c) Customer ContentPerformance of a contract with you.
To generate aggregated scam intelligence and threat trends.(a) Technical (b) Usage (c) Customer ContentNecessary for our legitimate interests (to collect information for statistical purposes about how the service is used with a view to making improvements to the service; namely generating and analysing threat statistics to improve our business).
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you.(a) Identity (b) Contact (c) Customer Content (d) Technical (e) Usage (f) Marketing and CommunicationsNecessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business). We will only send direct marketing communications to you with your consent.
To defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties.(a) Identity (b) Contact (c) Customer Content (d) Technical (e) Usage (f) Marketing and CommunicationsNecessary for our legitimate interests (to protect our rights, and to pursue and defend legal claims).
To facilitate business transactions and reorganizations impacting the structure of our business.(a) Identity (b) Contact (c) Customer Content (d) Technical (e) Usage (f) Marketing and CommunicationsNecessary for our legitimate interests (to facilitate corporate transactions and reorganizations).
To comply with legal obligations. To comply with requirements to hold or disclose information to law enforcement or in response to a court order or other legal process.(a) Identity (b) Contact (c) Customer Content (d) Technical (e) Usage (f) Marketing and CommunicationsNecessary to comply with a legal obligation to which we are subject. Where the legal obligation arises under the law of a country outside the UK or EEA, necessary for our legitimate interests (to comply with legal obligations).

5. Direct marketing

When your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email. You can opt-out at any time using the link in our messages.

We may also analyse your Identity, Contact, Customer Content, Technical and Usage Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.


6. Disclosures of your personal data

We do not sell or license personal data to third parties. We may disclose your personal data to external third parties, such as sub-contractors, marketing providers, business partners and service providers, when needed for the purposes shown in the table above. We may also disclose your personal data to third parties or publicly with your consent or direction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where required under applicable law or to the extent required to protect our rights or the rights and safety of others, we may disclose your personal data to law enforcement, as well as to other third parties to the extent required to comply with a court order.


7. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to the US and other countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that either:


8. Data security

We have put in place reasonable physical, technical, and organizational safeguards designed to prevent your personal data from being accidentally lost, altered, used, accessed or disclosed in an unauthorised way. However, despite these controls, we cannot completely ensure or warrant the security of your personal data.


9. Data retention

How long will you use my personal data for?

We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


If you access our services from the UK, you have the following rights in relation to your personal data:

  1. the right to access your personal data;
  2. the right to obtain rectification of any inaccurate or incomplete personal data that we hold about you;
  3. the right, in certain circumstances, to require us to erase your personal data where the continued processing of that personal data is not justified;
  4. the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person;
  5. the right to withdraw any consent to the processing of personal data you have given to us.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data. We will assess and inform you if that is the case. You can object to processing for marketing purposes for any reason.

To exercise any of these rights, contact us at support@falkin.com.


11. Complaints (UK only)

If you are interacting with our services in the UK, you have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so, please first raise your complaint to us or ask us for clarification if there is something you do not understand. You can contact us at support@falkin.com.


12. Changes to the privacy policy and your duty to inform us of changes

We may update this privacy policy from time to time. When we make changes to this privacy policy, we will change the date at the beginning of this privacy policy. If we make material changes to this privacy policy, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address. You can contact us at support@falkin.com.


This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.


14. Children's personal data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 18. If an individual is under the age of 18, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 18 has provided personal data to us, we encourage the child's parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 18, we will promptly delete that personal data.


15. Contact us

If you have any questions or requests in relation to this privacy policy or other privacy-related matters, you can contact us at support@falkin.com.


Version 2025-4. Updated December 1, 2025