Falcon App Inc., doing business as Sanoki

Privacy Policy

Effective Date: September 12, 2026

This Privacy Policy complies with Colombian Law 1581 of 2012 and Decree 1377 of 2013 (Habeas Data). See Section 10 for your rights.

1. Introduction

Falcon App Inc., doing business as Sanoki ("Falcon," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at sanoki.ai or use our cloud-based services (collectively, the "Services").

This Privacy Policy applies to all users of our Services, including visitors to our website, registered users, and customers. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

For Users in Colombia: This Privacy Policy complies with Colombian Law 1581 of 2012 and Decree 1377 of 2013, which regulate the protection of personal data and establish your rights as a data subject (Habeas Data). Section 10 of this Policy specifically addresses your rights under Colombian law.

2. Data Controller

The data controller responsible for your personal information is:

Falcon App Inc., 2483 Coney Island Ave, Brooklyn, NY 11223, United States

Email: [email protected]

For inquiries related to personal data protection, you may contact us at the address above or via email.

3. Information We Collect

3.1 Information You Provide to Us

We collect information that you voluntarily provide when you:

Create an Account: Name, email address, company name, job title, phone number, and billing information.
Subscribe to Our Services: Payment information (processed by our payment providers), subscription preferences, and service configuration.
Contact Us: Any information you include in correspondence with us, including support requests, feedback, and inquiries.
Participate in Surveys or Promotions: Responses, preferences, and contact information.

3.2 Information Collected Automatically

When you access our Services, we automatically collect certain information, including:

Device Information: Device type, operating system, browser type, and unique device identifiers.
Log Data: IP address, access times, pages viewed, referring URL, and actions taken within the Services.
Usage Data: Features used, interactions with the Services, and performance data.
Location Data: General geographic location based on IP address.

3.3 Information from Third Parties

We may receive information about you from third parties, including:

Authentication Providers: When you use single sign-on (SSO) services.
Business Partners: When you are referred to us or participate in joint offerings.
Public Sources: Publicly available information relevant to our business relationship.

3.4 Customer Content

When you use our Services, you may submit data for processing ("Customer Content"). We process Customer Content only as necessary to provide the Services. Please see Section 8 (Data Retention and Processing) for details on how we handle Customer Content.

4. How We Use Your Information

4.1 To Provide and Maintain the Services

Creating and managing your account
Processing transactions and sending related information
Providing customer support and responding to inquiries
Delivering the features and functionality of the Services

4.2 To Improve and Develop Our Services

Analyzing usage patterns and trends
Conducting research and development
Testing new features and functionality
Fixing bugs and improving performance
Training and improving our artificial intelligence and machine learning models (using anonymized data only, with opt-out available)

4.3 To Communicate with You

Sending service-related notices and updates
Responding to your comments and questions
Providing information you request
Sending marketing communications (with your consent where required)

4.4 To Ensure Security and Prevent Fraud

Detecting, preventing, and addressing technical issues
Protecting against unauthorized access and malicious activity
Enforcing our Terms of Service
Verifying identity and preventing fraud

4.5 To Comply with Legal Obligations

Responding to legal process and government requests
Complying with applicable laws and regulations
Protecting our legal rights and interests

5. Legal Basis for Processing

We process your personal information based on the following legal grounds:

Contract Performance: Processing necessary to provide you with the Services you have requested.
Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our Services, marketing, and security, provided these interests do not override your rights.
Legal Compliance: Processing necessary to comply with applicable laws and regulations.
Consent: Processing based on your explicit consent, which you may withdraw at any time.

For users in Colombia, we process your personal data in accordance with the purposes described in this Privacy Policy and with your prior, express, and informed authorization as required by Law 1581 of 2012.

6. How We Share Your Information

6.1 Service Providers

We share information with third-party service providers who perform services on our behalf. These providers are contractually obligated to protect your information and may only use it to provide services to us.

6.2 Business Transfers

If Falcon is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information.

6.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including:

Court orders or legal process
Government or regulatory requests
Law enforcement investigations
Protection of our rights, privacy, safety, or property

6.4 With Your Consent

We may share your information with third parties when you have given us your consent to do so.

7. Data Hosting and International Transfers

7.1 Default Hosting Location

By default, your data is processed in Falcon's infrastructure located in the United States (AWS Ohio region).

7.2 Regional Hosting Options

Upon written request, Falcon may arrange for your data to be processed in an alternative geographic location, such as Colombia via Oracle Cloud Infrastructure. Regional hosting options are subject to availability and may incur additional fees. To inquire about regional hosting, please contact us at [email protected].

7.3 International Transfers

By using our Services, you consent to the transfer of your information to the United States and acknowledge that data protection laws in the United States may differ from those in your country of residence.

For users in Colombia, we ensure that international transfers of personal data comply with the requirements of Law 1581 of 2012 and Decree 1377 of 2013, including ensuring adequate levels of data protection in recipient countries or obtaining your express authorization for such transfers.

8. Data Retention and Processing

8.1 Primary Processing Mode

The primary mode of processing Customer Content is transient, meaning data is processed in real-time to provide the requested Services and is not permanently stored beyond the immediate processing session.

8.2 Quality Assurance Retention

Falcon may retain Customer Content for up to thirty (30) days for quality assurance purposes, including:

Troubleshooting and debugging
Performance monitoring and optimization
Service reliability improvements

Data retained for quality assurance is stored securely with access restricted to authorized personnel and is automatically deleted after the thirty (30) day retention period.

8.3 Model Training and Improvement

Falcon may use Customer Content to develop, train, and improve its artificial intelligence and machine learning models, subject to the following safeguards:

Anonymization: All personally identifiable information is removed before any data is used for training purposes.
Aggregation: Data is aggregated with data from other sources to prevent identification of any individual or customer.
Non-Reversibility: The anonymized and aggregated data cannot be traced back to any specific customer or individual.

8.4 Opt-Out of Model Training

You have the right to opt out of having your data used for model training at any time. To exercise this right:

Submit a written request to [email protected] with the subject line "Opt-Out: Model Training"
Upon receiving your request, we will cease using your data for training purposes within fifteen (15) business days
Opting out does not affect the quality, availability, or functionality of the Services provided to you
Your opt-out preference will remain in effect unless you notify us otherwise

8.5 Account and Transaction Data

We retain account information and transaction records as follows:

Account Information: Retained for the duration of your account and for a reasonable period thereafter (typically two years) to comply with legal obligations and resolve disputes.
Transaction Records: Retained for the period required by applicable tax and accounting laws (typically five to seven years).
Usage Data: Retained in anonymized, aggregated form for analytical purposes indefinitely.

8.6 Data Deletion

When we no longer need your personal information, we will securely delete or anonymize it in accordance with our data retention policies and applicable law.

9. Data Security

We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, alteration, and disclosure. These measures include:

Encryption of data in transit and at rest
Access controls and authentication mechanisms
Regular security assessments and monitoring
Employee training on data protection
Incident response procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security.

10. Your Privacy Rights

10.1 General Rights

Depending on your location, you may have the following rights regarding your personal information:

Access: The right to request a copy of the personal information we hold about you.
Correction: The right to request correction of inaccurate or incomplete information.
Deletion: The right to request deletion of your personal information, subject to legal exceptions.
Portability: The right to receive your personal information in a structured, commonly used format.
Objection: The right to object to certain processing activities, including model training.
Restriction: The right to request restriction of processing in certain circumstances.
Withdrawal of Consent: The right to withdraw consent at any time, where processing is based on consent.
Opt-Out of Model Training: The right to opt out of having your data used for AI/ML model training, as described in Section 8.4.

10.2 Rights Under Colombian Law (Habeas Data)

If you are located in Colombia, you have the following rights under Law 1581 of 2012 and Decree 1377 of 2013:

Right of Access: You have the right to know, update, and rectify the personal data collected about you. You may request free access to your personal data that has been processed.

Right to Update: You have the right to request the update of your personal data to ensure it is accurate and current.

Right to Rectification: You have the right to request the correction of personal data that is inaccurate, incomplete, or misleading.

Right to Deletion: You have the right to request the deletion of your personal data when: (a) you consider it is not being treated in accordance with the principles, duties, and obligations set forth in Law 1581 of 2012; (b) the data is no longer necessary for the purpose for which it was collected; or (c) you have revoked your authorization for processing.

Right to Revoke Authorization: You have the right to revoke your authorization for the processing of your personal data at any time, unless there is a legal or contractual obligation to continue processing.

Right to File Complaints: You have the right to file complaints with the Superintendencia de Industria y Comercio (SIC) if you believe your rights have been violated.

Right to Be Informed: You have the right to be informed about the use that will be given to your personal data.

10.3 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: [email protected] (Include "Privacy Rights Request" in the subject line)

Mail: Falcon App Inc., 2483 Coney Island Ave, Brooklyn, NY 11223, United States

We will respond to your request within the timeframes required by applicable law:

For users in Colombia: Within fifteen (15) business days from the date of receipt of the request, extendable for an additional eight (8) business days when necessary.
For all other users: Within thirty (30) days of receipt of the request.

We may request additional information to verify your identity before processing your request.

10.4 Filing Complaints

If you are located in Colombia and believe that your data protection rights have been violated, you may file a complaint with the Superintendencia de Industria y Comercio (SIC) at:

Superintendencia de Industria y Comercio, Carrera 13 No. 27 - 00, Pisos 1 al 10, Bogota D.C., Colombia. Website: www.sic.gov.co. Phone: (57) 601 587 0000

11. Cookies and Tracking Technologies

11.1 Types of Cookies We Use

We use cookies and similar tracking technologies to collect information about your browsing activities and to distinguish you from other users of our Services.

Essential Cookies: Necessary for the operation of our Services and cannot be disabled.
Analytics Cookies: Help us understand how visitors interact with our Services.
Functionality Cookies: Remember your preferences and settings.
Marketing Cookies: Used to deliver relevant advertisements (if applicable).

11.2 Your Cookie Choices

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. However, disabling cookies may affect the functionality of our Services.

12. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

If you believe we have collected information from a child under 18, please contact us at [email protected].

13. Third-Party Links

Our Services may contain links to third-party websites, products, or services that are not owned or controlled by Falcon. This Privacy Policy does not apply to such third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access.

14. Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature that signals to websites that you do not want your online activity tracked. Currently, there is no uniform standard for interpreting DNT signals, and we do not currently respond to DNT signals. However, you may use the privacy controls described in this Policy to manage your preferences.

15. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

Update the "Effective Date" at the top of this Policy
Notify you via email or through the Services for material changes
Post the updated Policy on our website

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: