Children's Privacy Notice

1. Who this notice is for

This notice is for parents and legal guardians of children under 13 who are using Falken or who are registered for a Falken-hosted camp or event. The federal Children's Online Privacy Protection Act ("COPPA") applies in this case.

Falken also requires guardian permission for users 13–17, but those obligations are described in the master Privacy Policy and our Terms of Service. This notice is specifically the COPPA direct notice for under-13.

2. The operator

• Name: Falken Ltd.
• Address: 402 Foxcroft Drive, Winston-Salem, NC 27102, United States
• Email: privacy@falken.ltd
• Phone: (980) 643-8814

3. What we collect from children

What we do not collect from children: precise geolocation, behavioral advertising profiles, persistent identifiers used for cross-site tracking.

4. How we use it

We use children's information only to deliver the platform features the child or guardian has asked for, run the organization's program, and comply with law. We do not send marketing email to children. We do not use children's data for AI training, and we will not begin to do so without your separate consent.

5. Who we share it with

• The organization the child belongs to (their club, camp, school) and that organization's coaches and admins.
• Our sub-processors — Auth0, Microsoft Azure, Stripe (for camp payments), Firebase Cloud Messaging and Apple Push Notification service. The complete list is at Sub-processors.

Never with third parties for advertising or marketing.

6. How we get your consent

Before we collect personal information from a child under 13, we obtain your verifiable consent using one of the following FTC-approved methods:

• Credit/debit card transaction. When you register a child for a paid camp, the transaction through Stripe satisfies the FTC's "verifiable transaction" method.
• Signed consent form. A digital signature on a parental-consent form delivered through the guardian portal; we keep the signed PDF.
• Email plus follow-up. The FTC's "email plus" method — we email you, you confirm, and we follow up by email or phone after a reasonable delay.
• Government-ID matched check. For high-value or sensitive features, we may ask for a government-ID verification (via Stripe Identity or similar). Optional, used only when needed.

We document the method used and the date of consent for each child account.

7. Your rights as a parent or guardian

• Review. See all data we have collected from your child. We provide a downloadable export within 30 days of your request.
• Delete. Ask us to delete some or all of your child's data. We delete within 30 days unless retention is required by law (such as financial records).
• Refuse further collection. Tell us to stop collecting any more data. We will continue to provide the service to the extent possible without further collection.
• Withdraw consent. Withdraw at any time. We then close the child's account and delete data per the retention schedule.

8. No condition of participation

We will not require a child to disclose more personal information than is reasonably necessary to participate in a feature. For example, a child can use the training and competition features without optional features that are not required for participation.

9. How to contact us

For children's-privacy questions:

• Email privacy@falken.ltd with subject line "Children's Privacy" — routes to a dedicated queue.
• Address: Falken Ltd., 402 Foxcroft Drive, Winston-Salem, NC 27102, United States.
• Phone: (980) 643-8814.

We respond to verifiable parental requests within 30 days.

10. FTC resources

You can learn more about COPPA and parental rights at the FTC's website: ftc.gov/coppa. Falken does not currently participate in any FTC-approved Safe Harbor program; if we ever join one, we will name it here.