Privacy Policy for USA and all other
non-UK and EU countries
Effective date: October 2025
Type of user and type of Data
Purposes for which we may collect, use or disclose this Personal Data
Merchants onboarding. If you register as a Merchant to our Services, we will collect, use and disclose your information during the registration process. Such information includes, but is not limited to, your name, position, region, company, email address, contact details of your contact person, financial information, etc. This information is collected from you directly when you engage with us (for instance when executing an agreement with us or signing a purchase order). We collect this information directly from you when you ask for a demo or when you engage with Fraud Deflect in a merchant agreement.
● To onboard you to our Services and/or implement the Fraud Deflect Solution within your platform;
● To provide you with the Services;
● To identify authorized Users to access the Services;
● To resolve any disputes, communicate with you regarding customer service and support issues, and to respond to questions or comments and help resolve any problems.
● To identify authorized users of the Services;
● To access and use the Services.
● To resolve any disputes, communicate with you regarding customer service and support issues, and to respond to questions or comments and help resolve any problems.
Consumers Using the Fraud Deflect Solution. When Merchants use the Services, namely the Fraud Deflect Solution to detect and prevent fraud, we collect use and disclose certain information about you. Such information includes your full name, user ID, email, phone number, billing address supplied by you. We will collect use and disclose additional information about Merchant’s consumers, including device and network data (e.g., IP addresses, user agent strings, device identifiers, cookies, session IDs, referrers), transaction and account data (e.g., order IDs, payment instrument tokens, billing and shipping addresses, account metadata, charge outcomes), Behavioral and risk signals (e.g., timestamps, event type, geolocation approximations, velocity, link analysis, model features and scores) and support artifacts (e.g., logs, screenshots, tickets, and similar records).
● To provide you with the Services, and enable you to detect and prevent fraud, therefore we will share with our Merchants information we collected from you.
● To resolve any disputes, communicate with you regarding customer service and support issues and to respond to questions or comments and help resolve any problems.
Contact Us Information. If you contact us via the “Contact Us” or “Book a Demo” feature available through the Website our otherwise, we may collect certain information regarding you, such as your full name, your email address, your phone number, your company, and how many chargebacks you receive a month on average. We collect this information directly from you when you contact us.
● To answer your queries and provide you with the services you requested from us.
Category
Examples
Collected
A. Identifiers.
A real name, billing address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, telephone number, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.
Yes
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
No
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
No
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
No
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Yes
G. Geolocation data.
Physical location or movements.
Yes
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
No
I. Professional or employment-related information.
Current or past job history or performance evaluations.
No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
No
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
No
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows: (i) directly from you, for example, when you integrate into Fraud Deflect’s platform; (ii) automatically when you visit our Website; (iii) from third-party business partners such as card networks, processors, gateways or ISOs with whom our Merchants process payment transactions.
USE OF PERSONAL INFORMATION
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
● To fulfill or meet the reason you provided the information. For example, if you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry.
● To provide, support, personalize, and develop our Website and Services, as well as improve our Website and Services.
● To provide, maintain and improve fraud detection and prevention, account security, abuse and incident response, and service integrity.
● For testing, research, analysis, and product development, including to develop and improve our Website and Services.
● To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
● As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING AND SELLING DATA
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to
both keep that Personal Information confidential and not use it for any purpose except performing the contract. We share your Personal Information with the following categories of third parties:
We share your Personal Information with our service providers (such as AWS our cloud storage services and our customer support call center service provider)
We share your Personal Information data aggregators (such as Google Analytics)
We share your Personal Information to our business partners (such as processors, gateways or ISOs with whom our Merchants process payment transactions).
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE OR FOR SELLING PURPOSES
In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose: Category A: Identifiers. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Category D: Commercial information: Commercial Information Category F: Internet or other similar network activity. Category G: Geolocation data.
SALES OF PERSONAL INFORMATION
In the preceding twelve (12) months, Company has not sold Personal Information.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
The CCPA provides consumers with specific rights regarding their Personal Information.
You may exercise any or all of your above rights in relation to your Personal Information by filling out the DSR Form and send it to our privacy team at: privacy@frauddeflect.com.
DATA SUBJECT REQUEST FORM (“DSR”)
Last Updated: October 2025
Fraud Deflect, Inc., and its relevant affiliated companies involved in the processing of personal data (and personal information as defined under CCPA) (“Company”) values the privacy rights of its users, customers, consumers, users, and others. As required by the EU General Data Protection Regulation (“GDPR”) and by the California Consumer Privacy Act of 2018 ("CCPA") (collectively “Data Protection Law”). European Union residents and California residents, respectively, are permitted to make certain requests regarding our processing of personal data. In order to submit a data subject request pursuant to the Data Protection Law, please complete this form. Upon receipt of your completed request, we will process it and respond within the timelines required under applicable Data Protection Law. If additional information is necessary, we will contact you using the contact information you provided in this form. Information provided in connection with this request will be processed only for the purpose of processing and responding to your request and will be deleted immediately thereafter. For more information please review our Privacy Policy and User Rights Policy.
For the purpose of this form Personal Data shall include Personal Information.
Any DSRs submitted to us shall be processed by us in our capacity as a “Data Controller”. Please note that if you are an individual user of the Fraud Deflect solution (i.e. a Consumer as defined in the Privacy Policy) the “Data Controller” is the Merchant you purchased the product from. If we receive a DSR by a Consumer, we will notify the Merchant and will refer the Consumer to the relevant Merchant. We will act in accordance with the Merchant’s instructions in relation to Consumer requests.
Full Name:___________________________________________________________________________________________________________________________
Address (including ZIP): _____________________________________________________________________________________________________________
Email Address: ______________________________________________________________________________________________________________________
Phone _______________________________________________________________________________________________________________________________
Number:_____________________________________________________________________________________________________________________________
Please check the applicable box:
▢ I would like to receive information of why and how you are processing my information.
▢ I would like to receive a copy of the personal data you process on me.*
▢ I would like you to delete the personal data you hold on me.
▢ I would like you to stop processing my personal data.
▢ I would like to receive a copy of my data and transfer it to a third party.*
▢ I would like you to stop sending me direct marketing.
▢ I want to withdraw my consent for processing my personal data (applicable under the
GDPR).
▢ I would like to object to the processing of my personal data (applicable under the GDPR).
▢ I believe the data you hold on me is incorrect and I would like to correct it (applicable
under the GDPR).
▢ Other.
Substantiate the request- please provide additional information about your request:
____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
______________________________________________________________________________________________________________________________________
______________________________________________________________________________________________________________________________________
What is your relationship with us (e.g. Consumer (user of the Fraud Deflect solution), Fraud Deflect website visitor, business contact, etc.):
______________________________________________________________________________________________________________________________________
______________________________________________________________________________________________________________________________________
______________________________________________________________________________________________________________________________________
______________________________________________________________________________________________________________________________________
Verification of Identity
In order to keep the privacy of individuals safe we need to make sure you are indeed who you say you are, for this reason we need to verify your identity.
Please provide us with a photo ID document (e.g., driver license, passport).
For users exercising their rights under the CCPA
Please provide proof of address so we can confirm you are a California resident (upload one of the following: utility bill, bank statement, driving license, or tax document)
Thank you for filling in the form, we will process the request by the time specified in the Data Protection Law, we reserve the right to extend the aforementioned period by the time specified in the Data Protection Law if the request is complex or numerous or we require additional information.
The processing of the request is free of charge; however, we may want to reserve the right to charge a reasonable fee to cover certain administrative costs (such as providing additional copies of the data) or for handling manifestly unfounded or excessive requests
*Under the CCPA your rights only apply to the Personal Information (as defined therein) collected 12 months prior to the request and you are not entitled to submit more than 2 requests in a 12 months period.
By submitting this question or request, I am confirming that: (i) the information I have provided is true and accurate; (2) I understand the information will be handled by the Company in accordance with its privacy policy; and (3) the Company may contact me to verify my identity and to process this request.
***Note: To submit please print and email this form and supporting documentation to: privacy@frauddeflect.com.***
CONTACT US
If you have any questions about this Privacy Policy, you may contact us as follows: By sending us an email at: privacy@frauddeflect.com.