Privacy Policy

Last updated: February 22nd, 2022

1. Who We Are is a social platform for the digital asset industry launched in 2021 (“WhaleRoom”) by 12948231 Canada Inc., a federal corporation based in Quebec, Canada (“We” or “Us”). 

2. Our Approach To Privacy

What We Do For You

We go above and beyond Canadian privacy law to deliver an experience to you that minimizes the amount of personal information that we collect, which ultimately helps you to stay in better control of your digital footprint. We have designed WhaleRoom to be a balance of user convenience, user privacy, and technical features. This Privacy Policy explains the balance we have struck so that you can decide whether WhaleRoom is right for you, and so you know what we do with your personal information. Our general approach is: “if we don’t need it, we don’t want it”.

Privacy Policy

This Privacy Policy sets out our approach to user privacy. When you use WhaleRoom, our handling of your personal information will be governed by this policy.

User Participation

We think chat, and chat privacy, can be done better, and that users can play an integral role. Where possible, we make privacy controls available to you. Where possible, we avoid collecting your personal information. WhaleRoom was founded on the idea that blockchain-based methods can build a community of authentic users who participate directly in its functioning, all in compliance with Canadian privacy and data protection law.

Your participation is vital, but your participation also entails a degree of risk to your privacy that is your responsibility. What you choose to disclose on WhaleRoom is within your control, and how you choose to participate may have implications for your privacy. For example, we cannot stop you from disclosing your real name when chatting. 

The Laws of Canada

Our policy and practices are based on the requirements of the laws of Quebec, Canada, the federal laws of Canada, and our own principles based on the ethos of the cryptocurrency community. You should read this Privacy Policy in conjunction with the WhaleRoom End User License Agreement that governs the use of WhaleRoom to have a full understanding of how the WhaleRoom system operates on a legal, technical, and social level. 

3. Why We Collect Personal Information

We collect personal information to the extent that it is necessary to do so in order to provide WhaleRoom to you.

Whenever possible, we avoid collecting personal information or information that could be connected to you. That said, some features of WhaleRoom, such as sending you email notifications or logging in using an email address, or connecting to an exchange API using OAuth, may result in disclosure of information to us that is necessary in order to provide the service that you are using.

We collect personal information in order to provide the WhaleRoom service(s), to improve the service(s), and to comply with Canadian tax laws (in the case of payments that you make to Us). We may also collect your personal information as part of providing customer support services if you contact Us. You may also voluntarily provide us with additional information if you contact WhaleRoom.  

4. What We Collect

What we collect depends on what you want to use.

We collect information, including personal information, according to the way you are using WhaleRoom and the particular features that you are making use of. In some cases, you can reduce or avoid disclosure of information to us by not using a feature. 

We may, as part of providing WhaleRoom to you, collect contact information (e.g. email address), cryptocurrency wallet information, IP information, browser information, and payment information if you make a payment (using third party services that are compliant with PCI and other applicable standards). We may also collect other information on an opt-in basis, as part of providing certain functionality to you.  

We collect  information that is not personally identifiable, but that could potentially become personal information when used in connection with other information (e.g. IP addresses or cryptocurrency wallet information that aren’t necessarily connected to an identifiable person). The WhaleRoom platform does not store your IP address, nor does it store any user email or phone number, but the cloud hosting platform(s) and potentially other intermediaries between You and WhaleRoom (e.g. an Internet Service Provider) do store at least IP address(es), and potentially other information that is beyond the control of WhaleRoom.

5. Rooms And Privacy

User-Generated Content (UGC) And Technical Security

The messages and other content that you post to WhaleRoom (user-generated content, “UGC”) will often be accessible to other users because it is a service designed to enable group conversations. Please be mindful of your own privacy footprint when posting UGC to WhaleRoom.

The privacy of your UGC is important to Us. Although We have developed a number of technical measures in order to ensure that only members of a particular room/community can access the messages intended for them, we cannot guarantee that in all cases these measures will be effective.

Privacy Settings And Features

We encourage you to make use of the privacy settings and features built into WhaleRoom in order to ensure that only your intended audience receives your messages. But, please keep in mind that no service can ensure that messages remain with their intended audience because users can always use a camera to take a photo of a computer screen, or use other means to circumvent technological controls. Our commitment to privacy includes continually improving the settings and security of WhaleRoom. . 

6. WhaleRoom Practices and Security

Third-Party Analytics And Other Services

We minimize collection and disclosure of personal information but there are third-party services that are integrated into the WhaleRoom offering that may result in some of your information being disclosed to third parties. For example, we make use of analytics services to better understand user behaviour, and these services are governed by their own privacy policy and applicable legal rules. 

Our Personnel

Our employees and contractors are bound by confidentiality and are not permitted to make use of information found within the WhaleRoom technical infrastructure for any purpose other than to ensure the functioning and improvement of WhaleRoom. 

Storage Of Information

We take commercially reasonable steps to ensure that your personal information and the WhaleRoom data is secure. We store information for the time periods required by Canadian law, and We may retain it for a longer period of time as part of WhaleRoom’s legal compliance or for any of the purposes set out in this agreement. 

Marketing And Use Of Information

If you provide Us with contact information then We may use it to send you notices about new features, products, or other noteworthy details about WhaleRoom and other services made by Us. We do not sell contact information but we may transfer it to third party platforms that provide, for example, email marketing services that are necessary for us to contact you, but only where these services are bound by contractual terms that prohibit them from making their own first-party use of your contact information. We may also contact you directly through WhaleRoom.  

7. WhaleRoom’s Operating Team

We do not sell personal information that belongs to our users. We expect to be running WhaleRoom for the foreseeable future but We reserve the right to transfer it to another operating team. Accordingly, as part of the sale of all or substantially all of WhaleRoom, We may in the future transfer your personal information (and other information). 

8. Lawfully-Ordered Disclosure

As a Canadian company We are subject to a number of laws that could result in the mandatory disclosure of your personal information (and other information) due to a court order or other lawful process. If We become the subject of such an order then We shall attempt to notify you, to the extent that this is permitted by law. We reserve the right to disclose additional information that may not be strictly required by law, where We are of the opinion that doing so is in the best interests of WhaleRoom or Us, or other users of WhaleRoom. 

9. Global Conversations

WhaleRoom is designed to be accessed globally, just like cryptocurrency. Due to our global technical infrastructure, WhaleRoom information may be stored in countries outside of Canada (e.g. the United States of America) and become subject to the laws of other jurisdictions. 

10. Access And Corrections

You may have the right to access personal information (and other information) that you have provided to Us. Similarly, You may have the right to request a correction of the information. In most cases, this can best be accomplished through the WhaleRoom interface, but you may write to us at the contact information provided below.  

11. Questions, Compliments, and Complaints

You may reach us by email at: [email protected].