Privacy Policy

Latest update: March 13th, 2025

1. Overview

Falcon Finance is committed to protecting the privacy and security of your personal and institutional information. Our privacy policy (this “Privacy Policy”) explains how we collect, use, store, and disclose your information when you access or use the Platform, the Services or the Falcon Stablecoins, or any related services, tools, and features (collectively, the "Falcon Services") .

By agreeing to the USDf and sUSDf Terms and Conditions *the “Terms”), you also agree to the terms of our Privacy Policy. Unless otherwise defined herein, all capitalised terms in this Privacy Policy shall have the same meanings given to them in the Terms.

We process your data in accordance with Applicable Laws, including the General Data Protection Regulation (the “GDPR”). Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Falcon Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access, or download any of the Falcon Services.

2. Information collection

When you register for an Account, access, or use the Falcon Services, we may collect (directly or through third-party providers) various types of information about you from a variety of sources. This includes information provided during “Know Your Customer” (“KYC”) and Anti-Money Laundering (“AML”) processes, as well as data generated through your transactions on the Platform. Specifically, we may collect:

a. Basic Information: name, address, date of birth, nationality, country of residence, phone number, email address;

b. Identification Information: utility bills (or other proof of address), photographs, government-issued identification (such as identification cards, passports, driver’s licenses, etc.), tax ID number, employment information, proof of residency, visa information, organizational documents, and information regarding ultimate beneficial owners;

c. Financial Information: income/net assets/wealth verification statements, transaction history, and any other relevant financial data;

d. Blockchain Information: publicly available blockchain data, such as wallet addresses, transaction history, holdings, purchases, sales, or transfers of tokens, which may subsequently be associated with the information you provide to us; and

e. Technical Information: log files, IP addresses, browser type, operating system, and usage data collected automatically when you interact with the Platform.

3. Legal Bases for Processing Personal Data

We process your personal data under the following legal bases permitted by GDPR:

a. Contractual Necessity: To provide the Falcon Services and fulfill contractual obligations, such as verifying your identity during KYC/AML procedures (Art. 6(1)(b) GDPR);

b. Legal Obligations: To comply with legal and regulatory requirements, including financial regulations, AML laws, and tax obligations (Art. 6(1)(c) GDPR);

c. Legitimate Interests: To ensure the security and stability of the Falcon Services, prevent fraud, improve our Services, and conduct limited promotional activities (Art. 6(1)(f) GDPR); and

d. Consent: For activities that require your explicit consent, such as sending marketing communications (Art. 6(1)(a) GDPR). You can withdraw your consent at any time without affecting the lawfulness of prior processing.

4. Information use

We use your information to provide, maintain, and improve the Falcon Services, to communicate with you, to comply with legal and regulatory requirements, and for other purposes as described in our Privacy Policy. Specifically, we use your data to:

a. identify you as a User on our Platform;

b. identify your place of residence, or registered office;

c. provide access to and use of the Falcon Service;

d. improve the administration of the Falcon Service and enhance your experience;

e. provide customer support and respond to your requests and inquiries;

f. investigate and address conduct that may violate the Terms;

g. detect, prevent, and address fraud, violations of the Terms, and/or other harmful or unlawful activity;

h. send you administrative notifications, such as security, support, and maintenance advisories;

i. send you newsletters, promotional materials, and other notices related to our Services or third parties' goods and services;

j. respond to your inquiries related to employment opportunities or other requests;

k. comply with Applicable Laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and

l. act in any other way we may describe when you provide the information.

5. Information Sharing

We may share your information with third parties in certain circumstances for legitimate purposes. Such circumstances include:

a. Service Providers: engaging blockchain analysis providers, KYC/AML service providers, data analytics vendors, and cloud service providers;

b. Compliance with Laws and Regulations: complying with legal obligations, including cooperation with law enforcement, court orders, or regulatory investigations;

c. Business Transactions: facilitating business transactions such as mergers, acquisitions, financing, bankruptcy proceedings, or asset sales, during which your information may be transferred as part of the transaction. If our business or assets are acquired by another entity, they will inherit the rights and responsibilities regarding your information as outlined in this Privacy Policy;

d. Ensuring Compliance and Security: enforcing the Terms or ensuring the safety and security of the Platform and its Users;

e. Affiliated Entities: sharing information with parent companies, subsidiaries, joint ventures, or other affiliated entities under common ownership, provided they adhere to this Privacy Policy; and

f. Professional Advisors: disclosing information to professional advisors, including auditors, legal counsel, accountants, or KYC service providers.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:

a. data encryption during transmission and storage;

b. regular security audits and vulnerability assessments;

c. access controls to limit data access to authorized personnel; and

d. secure storage solutions for sensitive information.

Despite our efforts, no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." You are responsible for securing your digital wallets and keeping your account credentials confidential.

In the event of a data breach, we will notify affected individuals and relevant authorities in accordance with Applicable Laws.

7. Data Retention

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Specifically:

a. Account-Related Data: retained for as long as your account remains active;

b. Regulatory Requirements: retained for the duration specified by legal and regulatory obligations (e.g., financial and AML requirements); and

c. Dispute Resolution: retained as necessary to resolve disputes or enforce agreements.

Once your data is no longer required for these purposes, we will delete or anonymize it. Note that blockchain data (e.g., transaction history) cannot be altered or deleted due to the immutable nature of blockchain technology.

8. Your Rights as Data Subject

If you are in the European Economic Area (EEA) or other jurisdictions with similar data protection laws, you have the following rights under GDPR:

a. Access: the right to request access to the personal data we hold about you (Art. 15 GDPR);

b. Correction: the right to request correction of inaccurate or incomplete information (Art. 16 GDPR);

c. Deletion: the right to request deletion of your personal data, subject to legal and regulatory retention obligations (Art. 17 GDPR);

d. Restriction: the right to request restriction of processing in certain circumstances (Art. 18 GDPR);

e. Portability: the right to request a copy of your data in a structured, commonly used, and machine-readable format (Art. 20 GDPR);

f. Objection: the right to object to processing based on legitimate interests or for direct marketing purposes (Art. 21 GDPR);

g. Withdrawal of Consent: the right to withdraw your consent at any time for activities requiring consent (Art. 7(3) GDPR); and

h. Lodging Complaints: the right to lodge a complaint with a supervisory authority if you believe your rights have been violated.

To exercise your rights or to learn more about our Privacy Policy, please contact us at [e-mail]. We may require additional information to verify your identity.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance the functionality of our Services, analyze usage patterns, and personalize your experience. These include essential, performance, and marketing cookies.

You can manage your cookie preferences through your browser settings; however, please note that disabling cookies may limit certain features of the Falcon Services. Additionally, our Platform does not currently respond to "Do Not Track" signals from browsers.

10. Automated Decision-Making and Profiling

You have the right to object to the processing of your data for purposes of profiling or automated decision-making that may have significant effects on you, as permitted under Applicable Laws, including Article 21 of the GDPR. If you believe your data is being processed in this way, you may contact us at [e-mail] to exercise your right to object or to request additional information.

11. International Transfers

Your information may be transferred to and processed in countries outside of your jurisdiction, where data protection laws may differ. By using the Falcon Services, you consent to such transfers. We ensure that any such transfers comply with applicable data protection laws and implement appropriate safeguards.

12. Changes to Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any significant changes by posting a notice on our website or through other appropriate means. Your continued use of the Falcon Services after any such changes constitutes your acceptance of the updated Privacy Policy. If you do not agree to any changes in the Privacy Policy, you must stop using the Falcon Services.