Terms and Conditions.
These Terms and Conditions govern the access and the use of the services offered via platforms such as the Mobile Application for Smartphone Devices, Webpages, Web Dashboards and other mediums titled “FALOOS” (hereinafter, the Application or Faloos) and constitute the conditions under which the payment service provider provides the available payment services. These Terms and Conditions (hereinafter, Conditions) and their amendments, together with any other legally relevant information related to the use of the services provided by the Application, shall be made available to the User at all times through the official Application website at www.faloosapp.com as well as them being accessible via the Mobile Application under the Legal Documents tab. By downloading the Application and registering for an Account on the Application, the User accepts these Conditions, the Privacy Policy, the End User License Agreement and all other legal documentation for Faloos (all available on www.faloosapp.com in the Legal Section). In the case where the user does not agree with any terms mentioned in these documents, said User is advised and able to delete their account on the Application immediately under their own volition.
Parties:
Owner of the Application
The owner of the Application is FALOOS (hereinafter, Faloos Inc), with registered Headquarters in the United States of America.
For any queries or incidents related to the Application and its use, the User may contact privacy@faloosapp.com.
User
Person who downloads the Application or Service and accepts these Conditions.
Payment Service Provider
The company and bank partner that provides the payment services governed by these Conditions is the Bank of England, a local bank or payment service (“Payment Institution”) based in the United Kingdom.
The Payment Institution is subject to its own relevant supervision by governing bodies and Faloos bears no responsibility for the payment transactions, fund management or flow of funds handled by the Payment Institution.
The Payment Institution safeguards the funds received for the execution of the payment operations and handles the entire payment process from pulling and pushing funds on the back-end service of the Application (as well as all their own security measures such as Know-Your-Customer and PCI Compliance).
Services:
FALOOS INC provides the Users with a platform or virtual space that enables said Users, via the Application installed on their mobile device or on their Web dashboards, in a manner and the terms established in these Conditions, to:
a) Send payments to their contacts on their Friend’s list within the Application on their mobile device or Web dashboard.
b) Request money from their Friend’s list within the Application on their mobile device or Web dashboard.
c) Receive payments made by other Users that have said User added as a Friend on the Friend’s list within the Application or Web dashboard.
d) Utilise their payment sources (cards, bank account IBAN or other means) for current simple Peer-to-Peer payment flows as well as other future potential payment flows.
To provide the highest quality services indicated above, the Application may request the User’s permission to access the Friend’s list on the User’s Personal Facebook Account or their Contacts on their mobile devices. Should such access be denied, the services may not be provided as intended, but the service may still operate.
In registering with the Application, the User shall automatically become the owner of a payment account (hereinafter, Account) opened by the Payment Institution (via assigned independent Virtual IBAN or other means) into which the payments received from other Users will be deposited, and with which the details for one or several physical debit or credit cards or bank account IBAN’s (or other payment sources) may be linked, as well as accounts issued or opened in their name by a credit institution within the territories available for the usage of the Application to provide it with a funding source to initiate and receive payments.
Initiated payments, payment requests and payments received shall be noted in User Feeds on the Application and Web dashboard as an additional accounting record to enable the User to view the details of any executed payment operations and/or the ability to keep a record of their total personal payment history at any given moment.
Terms to Use the Services, Registration and Service Activation:
In order to utilise the full service, the User must (after downloading the Application from the relevant Application store to their Smartphone or after logging in to their personal Web dashboard): register with the Application by: (I) completing the fields requested (KYC, standard user registration, and Faloos profile set up, amongst others), (II) accepting these Conditions and other legal documents, (III) logging in via their Facebook or Apple ID, or other Accounts or by registering with their email and (IV) entering the information for the debit or credit cards, bank account IBAN’s or other payment sources that they wish to link to their Account as payment sources (Note: cards may be required for initiating payments and IBAN’s may be required for receiving payments. If one is provided but not the other, said User may have limited functionality of the Faloos service and may not be able to enjoy the full capabilities of Faloos).
Having registered with the Application, the data provided (Local ID Number, Phone Number, Date of Birth and Name, amongst other requirements) is then authenticated and verified (by an Identity Service Provider). The User cannot use the full services unless they pass said “checks” and unless they have provided all of the required information during registration, and any information that may be required in compliance with the terms of applicable laws and/or by policy (Know-Your-Customer or other) by the Payment Institution.
The additional verification of the User’s identity via authoritative documents may be conducted for anyone exceeding an amount decided by FALOOS INC (or the relevant regulator) at their own discretion per year, per month or daily for payments sent or received.
FALOOS INC will provide the User with notice of service confirmation immediately following the successful completion of the data registration and verification process, by sending an email or verifying on the Mobile Application, Web dashboard or other durable medium, in the case where verification is required.
The User is required to maintain the confidentiality of the account and its credentials. In case of any loss of the data because of theft or other means, FALOOS INC will not be held responsible. Being the owner of the account, the User is responsible for the activities that occur from the account. If the User finds any unauthorised usage of their account, they should reach out to FALOOS INC immediately at privacy@faloosapp.com.
FALOOS INC may utilise the User(s) email address to notify said User about changes and updates. If the User does not want to get notified through the email, they may opt-out by emailing privacy@faloosapp.com.
Identity Authentication and Data:
The telephone number linked to the Smartphone where the Application has been downloaded will constitute the identification credential for the Application User and the Virtual IBAN or relevant Account number or name attached to the User’s Faloos Account shall serve as an identifier for the transactions that are conducted by the User via the Application or Web dashboard. For this reason, the User should refrain from changing the telephone number connected to their Account. Should the User wish to use a different number, they must open a new account or contact us directly via email at privacy@faloosapp.com and Faloos will endeavour to do its best to resolve the matter.
Data relating to the User’s name and profile photo associated with their Account form their “Public Profile” and may be seen by other Users that have their telephone number saved to their Contacts list or have added them to their Friend’s list, which the User expressly authorises to by registering on Faloos.
The Application has search engines that enable you to search and be found, as long as the person initiating the search has the username of the other person or mobile phone number of the other person saved in their Contacts list.
FALOOS INC may ask the User to provide further information or documents to verify and confirm their ownership of the phone number, email address, and other financial instruments. All the information that FALOOS INC will ask the User to provide will be used for internal processes and may be passed along to the Payment Institution and/or other Third-Party Service Providers for the purpose of verifying the User’s identity. The User hereby grants Faloos their consent for Faloos to utilise the User’s personal data internally as well as externally with potential Third-Party Service providers that are vital to operating the Faloos service (such as Identity Service Providers for Identity Verification).
Payments and Transactions:
Using the Application or Web Dashboard, the User may make payments to the accounts of other Users listed in the Friend’s list or Contacts list on their mobile phone for the number linked to their Faloos Account (or in potential other ways available in future releases).
To make a Peer-to-Peer payment, the User must first click the “Pay” button on the home screen and then select the Payee from their Friend’s Contacts list (after adding each other) and enter the exact sum to be transferred into the Application. The User must then confirm the payment amount on the Confirmation Pop-Up Screen (with any associated charges), thereby authorising the payment transaction. The payment amount will be credited to the receiving User’s Local Payment Services Provider or IBAN Account, and any charges will be charged to the Account of the User initiating the payment as a Payer (with relevant fees clearly explained to the Payer before initiating said payment).
The User may request money from any contact in the Friend’s Contacts list on their mobile phone whose mobile phone number is linked to their Account and/or via their Faloos Username. To this end, the User must first click the “Request” button on the home screen and then select the Payer from their Friend’s Contacts list and enter the exact sum to be requested from said User into the Application or Dashboard (including relevant fees), thereby authorising the Application to send a communication (push notification and/or in-app notifications) to that User asking them to proceed to initiate the payment under the terms requested or reject it.
If the Payee or Payer contact is not a User of the Application, they may be sent an invitation in the name of the User to download and register with the Application in order to begin initiating or receiving payments on Faloos.
The processing of payments and transfers is handled by the Payment Institution that FALOOS INC has partnered with for the Application (and any future) Mobile Application(s) or services. The Payment Institution is capable of handling payments processed for payment sent or managed by the Payee’s Local Payment Service Provider and the partnered payment Gateway (if any) of the Payment Institution (such as Mastercard Payment Gateway Services, MPGS) which is able to handle debit and credit payment processing for the funds to be sent from the Payer or as an Open-Banking certified Payment Initiation Service Provider. FALOOS INC, the Application and Web dashboard are not in any way responsible in the scenario where funds are lost, stolen, or were incorrectly transferred to the wrong User/party as no payments are initiated without the Payer/Payee first both signing up fully on Faloos, adding their personal payment source information and adding friends (accept/reject) on the service. The User must check all activity carefully and immediately notify either the Payment Institution via its website and relevant support line or FALOOS INC by emailing privacy@faloosapp.com without delay if the said activity includes anything that seems incorrect or has not been conducted according to their instructions.
Price and Commission:
The Application is currently free to download for the User. However, the Payment Institution may charge a fee per transaction on top of the fee that FALOOS INC may charge per transaction (Users will be able to see relevant charges/fees when initiating payments or requests on Faloos via the Confirmation Pop-Up before confirming a payment initiation or request). Any modification thereto will be governed by these Terms of these Conditions. Without prejudice to the foregoing, the access to and use of the Application or Web dashboard may involve the use of mobile telephone services, such as web browsing, that may incur a cost from the mobile telephone operator, to be met by the User. Likewise, the Payment Institution and FALOOS INC reserve the right to receive from the User any updated rates established for the Services it provides as mentioned earlier.
Other:
The User is responsible for checking that the Application is compatible with their Smartphone, Computer, or any other relevant device used to access the service and is therefore liable for any damage that may arise from the use of the Application, including its installation on the said device.
Telematic Signature:
The User gives their express consent to the use of telematics for acceptance media such as, for example, the act of checking a checkbox or pressing an icon with the terms that may include (but are not limited to): “accept”, “finish”, “OK”, “confirm”, “login”, or entering a username and password or logging in via their previous Online Accounts (like Facebook or Apple ID) (hereinafter, telematic signature), as a means of providing their consent, including, but not limited to, entering into contracts with FALOOS INC and the Payment Institution, the acceptance of specific disclaimers and communications from said institutions, and the sending of orders and instructions via the Application or Web dashboard. A telematic signature is deemed to be the equivalent of a manual User signature. Consequently, the sending of orders and instructions via the Application or Web dashboard constitutes the User’s authorisation and acceptance of the operation performed, and the impossibility of it being repudiated (either directly or via a third-party with access to their Smartphone/Web dashboard and their data due to User negligence, or when the User has acted fraudulently and in bad faith). The User expressly accepts that both FALOOS INC and the Payment Institution may save the contracts and orders signed on its secure servers, potentially by way of telematic delivery, and use them as proof of execution (among other reasons). In the event of a discrepancy between their copy and the filed contract or order, the latter shall prevail.
Intellectual Property:
FALOOS INC grants, and the User accepts, a free licence to use the Application owned by FALOOS INC which is personal and non-transferable, limited, non-exclusive, and available, following acceptance of these Conditions, through a telematic download process, to directly access the home screen enabling access and use of the functionality provided via the Application. Said use includes the total or partial reproduction of the Application exclusively in the form of its use, downloading, execution, and display on a Smartphone or other device. The use of the Application is restricted to the aforementioned use and its use for any other purpose is expressly prohibited and is considered to be an act of software piracy that infringes intellectual and industrial property law, such that FALOOS INC may seek liability for non-compliance with this condition, under applicable laws. Likewise, the User or third-parties are expressly prohibited from manipulating, either in full or in part, the Application. Likewise, the Application as a whole, that is, its constituent elements (texts, images, brands, logos, audio files, software files, colour combinations, etc.), as well as the structure, selection, and order in which its content is presented, are protected by Intellectual and Industrial property law, and cannot be subject to exploitation, reproduction, distribution, modification, public communication, cessation or transformation or any other form of dissemination unless expressly authorized by FALOOS INC.
Access to the Application does not grant the User any form of right to, or ownership of, the Intellectual or Industrial property rights for the content within the Application. FALOOS INC reserves the right to take the relevant legal action against any User(s) or third party that violates or infringes its Intellectual and/or Industrial property rights.
Changes:
FALOOS INC reserves the right to change these Conditions any time without providing any prior notice to the Users of the Application. The current version of the Conditions will govern the Users’ usage of the Application and access to the Website and/or dashboard. It is the responsibility of the User to keep themselves updated about the changes and modifications. The modifications will be effective as soon as this section is updated. As a User of the Application, Website, Web dashboard and its Services, the User understands that continuous usage of the Services will be considered as the User’s consent to the latest version of all legal documents and Conditions (including, but not limited to: Terms and Conditions, Privacy Policy and End User License Agreement). It will also be considered as the User's acceptance of the modifications. Furthermore, FALOOS INC reserves the right to modify and/or improve the Application, at any time and without prior notice, which will then continue to be the exclusive property of FALOOS INC. In particular, FALOOS INC reserves the right to delete, limit or prevent access to the Application in the event of technical difficulties arising due to events or circumstances beyond the control of FALOOS INC which, in its opinion, may reduce or cancel the standard security levels adopted for the correct operation of said Application. The User has the right to terminate this Contract at any time, unless there is a prior notice period agreement for termination (such notice period must not exceed 30 calendar days). Faloos will endeavour, to the best of its abilities, to provide at least a 30 days' notice to all Users regarding changes to this Contract, and in the event the User does not agree with them, the User reserves the right to terminate this agreement at no charge.
Table of Contents
Document Control ........................................................…..………………………… 2
Document Revision History ................................................…………………………………….. 2
General Conditions ........................................................…………………………….. 5
Information On Transactions, Fees And Charges ........................................................…..………………………… 5
General Principles for Financial Consumer Protection ........................................................…..………………………… 5
PRINCIPLE 1 Equitable and fair Treatment ........................................................…..………………………… 5
PRINCIPLE 2 Disclosure and transparency ........................................................…..………………………… 6
PRINCIPLE 3 Financial education and awareness ........................................................…..………………………… 6
PRINCIPLE 4 Behavior and work ethic ........................................................…..………………………… 6
PRINCIPLE 5 Protection against fraud ........................................................…..………………………… 6
PRINCIPLE 6 Protection of Consumer Privacy ........................................................…..………………………… 6
PRINCIPLE 7 Complaints handling ........................................................…..………………………… 6
PRINCIPLE 8 Competition ........................................................…..………………………… 6
PRINCIPLE 9 Third parties ........................................................…..………………………… 6
Rights of Payee ........................................................…..………………………… 7
Variation and Termination of Framework Contract ........................................................…..………………………… 7
Advertising and Marketing ........................................................…..………………………… 7
Data Protection and Confidentiality ........................................................…..………………………… 8
Training ........................................................…..………………………… 8
Policy Update ........................................................…..………………………… 8
Policy Exemptions & Approvals ........................................................…..………………………… 9
Privacy Policy ........................................................…..………………………… 9
Policy Statement ........................................................…..………………………… 9
Nonpublic Personal Information (NPPI) ........................................................…..………………………… 9
Information Sharing ........................................................…..………………………… 9
Limiting Information Sharing ........................................................…..………………………… 10
Information Sharing Agreements ........................................................…..………………………… 10
Former Customers ........................................................…..………………………… 10
Physical and Virtual Protections ........................................................…..………………………… 10
Limiting Access ........................................................…..………………………… 10
Technological Safeguards ........................................................…..………………………… 10
Physical Safeguards ........................................................…..………………………… 11
Reporting Requirements ..........................................................…..………………………. 11
Monitoring & Testing ........................................................…..………………………… 11
Training ........................................................…..………………………… 12
Policy Update ........................................................…..………………………… 12
General Conditions
Provide a copy of terms and conditions to new customers before the commencement of the services to enable the customer to make an informed decision as to whether or not to proceed.
A copy of terms and conditions to existing customers at their request.
All changes in terms and conditions must be communicated to the customers at least 2 months in advance of any such changes being implemented. (ref section 50 of the Payment Services Regulations 2017)
In the event that a customer does not wish to agree to the revised terms and conditions, the customer must have the right to end the contractual relationship at no charge.
Information on the terms and conditions may be provided by mail or electronically (including by means of a website, mobile application, or email).
All terms and conditions should be written in easily understandable language and in a clear and comprehensible form. Any information provided must be provided or made available in English or in the language agreed by the parties (ref section 55 of the Payment Services Regulations 2017).
Information On Transactions, Fees And Charges
Faloos Inc will provide its customers the following information before the customer consents to a Payment Transaction or make available such information at the request by the customer within 3 business days (or as required by the Payment or Identity Service Provider):
The schedule of fees, charges, and commissions, including currency and conversion rates and withdrawal charges, where applicable, that apply to that Payment Transaction.
The legal name, registered address, and relevant contact details for Faloos Inc
The form and procedure for giving consent to the initiation of a Payment Order or execution of a Payment Transaction and for the withdrawal of consent.
The agreed methods of communication between Faloos Inc and the customer.
The agreed safeguarding methods to separate customer funds and Faloos Inc funds.
How and within what period of time the customer is required to notify Faloos Inc of any unauthorised or incorrectly initiated or executed Payment Transaction and the liability of Faloos Inc for unauthorised Payment Transactions.
Information relating to terms under which a customer may be deemed to have accepted changes to the terms and conditions, the duration of the contract, and the rights.
The maximum time in which the Payment Service request will be executed.
General Principles for Financial Consumer Protection
PRINCIPLE 1 Equitable and Fair Treatment
Faloos Inc will deal fairly and honestly with consumers at all stages of their relationship, as the consumers are an integral part of the company's culture. Care should also be taken and special attention given to the needs of vulnerable people and groups.
PRINCIPLE 2 Disclosure and Transparency
Faloos Inc will provide up to date information about products and services to consumers. This information will be easily accessible, clear, simple to understand, accurate, not misleading, and include any potential risks for the consumer. It will include the rights and responsibilities of Faloos Inc and customers including the mechanism for ending the business relation with or by the customer as well as details of fees, pricing and any potential penalties that the consumer may incur.
PRINCIPLE 3 Financial Education and Awareness
Faloos Inc may develop programmes and appropriate mechanisms to help its existing and future consumers develop the knowledge, skills, and confidence to appropriately understand risks (including financial risks and opportunities) and make informed choices and for them to know where to go for assistance when they need it.
PRINCIPLE 4 Behaviour and Work Ethic
Faloos Inc will work in a professional manner for the benefit of its customers during the relationship, in terms of products and services offered by Faloos Inc to its customers.
PRINCIPLE 5 Protection Against Fraud
Faloos Inc will protect (to the best of its ability) and monitor all financial assets of its customers through the development of control systems (internally or through partners such as the Identity or Payment Service Providers) with a high level of efficiency and effectiveness to reduce fraud, embezzlement, or misuse.
PRINCIPLE 6 Protection of Consumer Privacy
Financial and personal information collected by Faloos Inc during the course of business will be protected through appropriate control and protection mechanisms. These mechanisms will define the purposes for which the data may be collected, processed, held, used, and disclosed (especially to third parties).
PRINCIPLE 7 Complaints Handling
Faloos Inc will allow its consumers access to adequate complaints handling mechanisms that are accessible, affordable, independent, fair, accountable, timely and efficient.
PRINCIPLE 8 Competition
Faloos Inc will ensure that its customers are able to search, compare and where appropriate, switch between products, services, and providers easily.
PRINCIPLE 9 Third Parties
Faloos Inc have, as an objective, to work in the best interest of their customers and be responsible for upholding financial consumer protection.
Rights of Payee
Faloos Inc must, immediately after the execution of the Payment Transaction, provide to the Payee the following information:
A reference number enabling the Payee to identify the Payment Transaction and the Payer and any information transferred with the Payment Transaction. The reference number will be available in the User’s dashboard available on the Web/Dashboard.
The amount of the Payment Transaction in the currency in which the funds are at the Payee’s disposal or were sent to the Payee’s account.
The amount of any fees or charges for the Payment Transaction payable by the Payee (if any).
The exchange rate used in the Payment Transaction by Faloos Inc (if any).
The date on which the amount of a Payment Transaction is credited to a Payee’s Payment Account.
Faloos Inc will provide each of its customers with a history of their Payment Transactions, under a Framework Contract at least once per month free of charge if requested by the User (ref section 53 of the Payment Services Regulations 2017). Note: User can also access the history of their Payment Transactions directly at any time through their Web Dashboard.
Variation and Termination of Framework Contract
A customer may terminate the Framework Contract at any time, unless it was agreed between the customer and Faloos Inc to provide a prior notice period for termination. Such notice period must not exceed 30 calendar days. (ref section 51 of the Payment Services Regulations 2017)
The terms and conditions, including fees and charges, cannot be altered unless conditions for such changes are specified in the Contract with the customer.
Faloos Inc will provide each of its customers with at least 2 months’ notice for any changes to the terms of the Contract. (ref section 50 of the Payment Services Regulations 2017)
Faloos Inc will inform the affected customers of any changes in fees and charges, including any changes imposed by a third party, at least 2 months in advance of any such changes coming into effect and give customers the right to refuse and end the relationship at no cost.
Fees and charges that are linked to floating rates, such as exchange rates, may be changed in accordance with what is contracted and based on a reference rate agreed upon and available to the customer.
Faloos Inc will not charge a customer for the information required to be provided by any Regulations that Faloos Inc is governed by.
Faloos Inc will not charge any fees and charges from its customers if they were not informed to them prior to that Payment Transaction.
Advertising and Marketing
Faloos Inc will ensure that any advertising or promotional material for its product and services is not deceptive, misleading or exaggerative.
All text and numbers stated in such material should be clearly visible and understandable, with a legible font size used for all text (including footnotes).
Faloos Inc will ensure that advertising and promotional material is designed and presented so that any customer can reasonably be expected to understand that it is an advertisement, and that the availability of the product or service may require the customer to meet certain criteria.
All advertising and promotional material must be approved in writing by the Compliance function of Faloos.
A Payment Service Provider must not send promotional material to any person under the age of 18 years, where such material presents an unsuitable risk to such customers.
Data Protection and Confidentiality
Faloos Inc will protect the Customer Data and maintain the confidentiality of that data, including when it is held by a third party of the Payment Service Provider. The personal information of customers will be accessed and used by personnel authorised by Faloos Inc only for the purpose of complying with regulatory requirements applicable in the United Kingdom, including in relation to anti-money laundering reporting, fraud, and financial crime reporting. Faloos Inc will not disclose any Customer Data except where:
Required to by applicable laws and regulations, by the FCA or other competent authority in the United Kingdom.
The disclosure is made with the prior written consent of the customer. The consent from the customer will be made part of the Terms and Conditions accepted by the customer at the time of on-boarding on to the Faloos service.
Faloos Inc shall put in place and maintain adequate policies, procedures, and controls, as well as employee awareness training, to protect Customer Data and to identify, act to prevent, and resolve any information security breaches.
Training
It is the responsibility of the company to ensure that all of the relevant personnel receive appropriate training on the regulation(s) and the directives of this Policy. The training programme includes:
Regulatory requirements and Faloos Inc consumer protection policy, procedures, and processes (including any changes).
Current developments and changes to any related regulation(s);
Employee monitoring requirements
Reinforcing the importance that Senior Management places on compliance with consumer protection and ensuring that all employees understand their role in maintaining an effective compliance program.
Understanding and communicating the context and the purpose of the consumer protection Policy.
Policy Update
This policy will be reviewed on an annual basis or in case of major regulatory instructions. All minor amendments will be issued through an addendum. All addendums issued during the year will be incorporated into the policy on an annual review.
Policy Exemptions & Approvals
Approval for exemptions to any clause of this policy will be obtained from the Board of Directors on a post facto basis.
Privacy Policy
Policy Statement
Faloos Inc adopted this policy (the “Policy”) as evidence that Faloos Inc personnel are committed to the practices of ensuring that a consumer’s private information is secure and confidential. Faloos Inc will take tangible steps to ensure we safeguard consumer information from unauthorised use. As such, Faloos Inc has implemented safeguards to protect consumer information. These safeguards can be physical (restricted access to buildings), electronic (IT firewalls), or procedural (use of shredding devices).
Non-public Personal Information (NPPI)
Non-public Personal Information (“NPPI”) is any data or information considered to be personal in nature and not subject to public availability.
Personal information includes, but is not limited to:
Individual names
ID document number
Credit or debit card numbers or IBAN information
Dates of birth
IP address
Email address
Information Sharing
Faloos Inc collects information about its customers to help better serve their financial needs, to provide them with quality products and services, and to fulfil legal and regulatory requirements. We consider non-public information about our customers in our possession to be personal information, even if they cease to be a customer. The personal information we collect about our customers may include among other things:
Identifying information, such as their name, age, address, phone number, and ID document number.
Employment information (for potential future product releases).
Financial information such as their income, assets, and liabilities, as well as information about their savings, investments, and insurance (for potential future product releases).
Typically, Faloos Inc collects this information on applications and other forms completed by the customer. Faloos Inc may also collect information from a wide range of other sources in order to process the customer's request for transactions.
Limiting Information Sharing
Faloos Inc shares personal information about its consumers, only as required or permitted by law, with third parties, such as service providers who assist us in the day-to-day operations of our company.
Information Sharing Agreements
Faloos Inc may engage in joint marketing ventures with non-affiliates that require the sharing of information. Any time Faloos Inc enters into an agreement with a non-affiliate, that agreement may be reviewed by the Faloos Inc Legal/Compliance Department to confirm that there is a clause concerning NPPI and its acceptable use pursuant to that agreement. No information-sharing agreement may be executed without the approval of the Legal/Compliance Department.
Former Customers
Once a consumer is no longer an active Faloos customer, we will continue to treat information that they have provided as if they were still a customer.
Physical and Virtual Protections
Faloos Inc Information Technology Department (“IT”) provides high-level guidelines in identifying and implementing safeguarding processes to protect customer data, confidential and/or proprietary information from misuse, inappropriate transfer, and theft. The safeguarding process also identifies foreseeable internal and external risks to the security, confidentiality, or integrity of any records containing personal and/or proprietary information.
Faloos Inc has implemented physical, electronic, and procedural safeguards to maintain confidentiality and integrity of the personal information in our possession and to guard against unauthorised access. These include (among other things): procedures for controlling access to customer files, building security programs, and information technology security measures such as the use of passwords, firewalls, virus prevention, and detection software. These safeguards include:
Limiting Access
Each employee needs appropriate access to do his or her job. Therefore, when a new employee is hired, the new employee's system and physical access should meet the requirements of their job function. In the same manner, if an employee moves into a new position, that employee's system and physical access requirements could change accordingly. The person authorising such access (for example, the employee's direct leader or manager) should be mindful to limit access only to those systems and areas deemed critical for the employee to accomplish their job function.
Technological Safeguards
Faloos Inc uses a standard SSL (Secure Sockets Layer) encryption. General consumer information is encrypted when stored and encrypted when transmitted outside of the Faloos Inc environment. For Passwords, Faloos Inc utilises a bcrypt hashing and for API authentication, Faloos Inc uses JWT token security.
Physical Safeguards
In the case where Faloos Inc has its own office space, employees, consultants, and vendors must treat physical data with the same high-level care as electronically stored data.
Employees are responsible for maintaining the physical security of Faloos Inc premises. These precautions include:
Not propping or leaving doors open.
Ensuring that the door(s) are fully closed after your departure.
Directing individuals who enter secured areas without a badge to sign in with a receptionist or Administrative Services.
Immediately report lost or stolen company-issued laptops and/or cellular phones to the Information Technology Department.
Maintaining the security of paper documents. For example:
When information is no longer needed, shred proprietary, confidential and/or customer information.
Do not leave proprietary, confidential and/or customer information lying on copiers or fax machines or in unsecured areas or hallways of Company facilities.
Proprietary, confidential and/or customer information must always be within the employee’s physical possession and sight or secured out of sight in a locked area.
Reporting Requirements
The Legal/Compliance Department is responsible for ensuring that these safeguards are being followed. If any employee believes a breach of our safeguards has taken place, or they have reason to believe any non-public consumer information has been unlawfully accessed or delivered to a third party in error, they must contact the Legal/Compliance Department for investigation, notification, and resolution.
Monitoring & Testing
The policy will be re-evaluated annually to determine whether all aspects of the policy are up-to-date and applicable in the current business environment. In the event that changes to regulations are mandatory and require an immediate update, the policy will be amended to reflect such changes. The actions to take if fraudulent or illegal activity is discovered may also require revision to reduce damage to Faloos Inc and its consumers.
As part of the review, red flags may be revised, replaced, or eliminated. Defining new red flags may also be appropriate. The following factors may be considered in exercising discretion in amending the policy:
Faloos Inc experience with identity theft.
Updates in methods of identity theft.
Updates in customary methods used to detect, prevent, and mitigate identity theft.
Updates in types of accounts that Faloos Inc offers or maintains; and/or
Updates in service provider arrangement(s).
Training
It is the responsibility of Faloos Inc to ensure that all relevant employees receive the appropriate training on the regulation(s) and the directives of this policy. The training program includes:
Regulatory requirements and internal Privacy policies, procedures, and processes, including any changes.
Current developments and changes to any related regulations.
Faloos Inc employee monitoring requirements.
Reinforcing the importance that the Board of Directors and Senior Management place on compliance with the Privacy Policy and ensuring that all employees understand their role in maintaining an effective compliance program.
Understanding and communicating the context and the purpose of the Privacy Policy.
Policy Update
This policy will be reviewed on an annual basis or in case of major regulatory instructions. All minor amendments will be issued through addendum. All addendums issued during the year will be incorporated into the policy on annual review.
Back to Home
© 2025, Faloos Inc.
© 2025, Faloos Inc.
© 2025, Faloos Inc.