Privacy Policy

Last modified: October 9, 2023

1. Introduction.

   Beluga, a service provided by CS Labs 21, Inc. (the "Company," "we," "our," or "us") takes protecting your privacy very seriously. This Privacy Policy explains the types of information we may collect from you or that you may provide when you visit the Beluga website located at https://heybeluga.com/ and its related subpages (collectively, the "Website") or use our software applications, and our practices for collecting, using, maintaining and disclosing that information.

   This Privacy Policy applies to information we collect:

   • On the Website.
   • In email, text and other electronic messages between you and the Company.
   • Information provided to us through software applications we host. As used herein, "our software applications" refers to all of the above.

   Please read this Privacy Policy carefully to understand how we interact with your personal information and what we do with it. By using the Website and providing us with your information, you agree to this Privacy Policy. This Privacy Policy may change from time to time, and by continuing to use the Website, you agree to those changes. We encourage you to check this Privacy Policy periodically for updates.

2. Children Under the Age of 13.

   Our Website and software applications are not intended for children under thirteen (13) years of age. No one under age thirteen (13) may provide any information to us, including on the Website and our software applications. We do not knowingly collect personal information from children under thirteen (13). If you are under thirteen (13), do not use or provide any information on this Website and our software applications or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, email address, any identity or records related to you or any screen name or user name you may use. If we learn we have collected or received personal information from a child under thirteen (13) without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under thirteen (13), please contact us at [email protected].

3. The Kinds of Personal Information We Collect.

   Information You Provide to Us: The information we collect on or through our Website or our software applications may include:

   • Your IP address;
   • Information that you provide by filling in forms on our Website or our software applications, including credit card information, web3 wallet or public address information or any other applicable payment information;
   • Information by which you may be personally identified, such as name, email address, postal address, telephone number or any other identifier through which you may be contacted online or offline, including social media handles or any other relevant identifier ("personal information");
   • Details of transactions you carry out through our Website or through our software applications, including financial or personal information associated with any such transaction;
   • Information about blockchain transactions, including but not limited to your public key address or other public identifier related to your blockchain account and information about how you are using the Company's blockchain infrastructure;
   • Records and copies of your correspondence, including email addresses, if you contact us;
   • Transcripts of your interaction with our Website's chat feature; or
   • Details regarding how you found our site and how you intend to use it, if applicable.

   You also may provide information to be published or transmitted to other users of the Website or our software applications, or third parties (collectively, "User Contributions"). Your User Contributions are provided at your own risk. Additionally, we cannot control the actions of other users of the Website or our software applications with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

   If you submit information to us that we believe places your privacy or security at risk, we may immediately delete that information.

   Information Collected Automatically: As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

   • Usage details, including the total time you spend on our Website, the time you spend on each page, the order in which those pages were visited and the internal links clicked, the general geographic location from which you access our Website, which browser and operating system you are using to visit our Website and the referring website;
   • Performance details, including monitor page load times, CPU/memory usage, browser crashes and React component rendering; or
   • Information about your computer and internet connection, including your IP address, operating system and browser type.

   We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

   • Estimate our audience size and usage patterns;
   • Store information about your preferences, allowing us to customize our Website according to your usage patterns; and
   • Recognize you when you return to our Website.

   The information we collect automatically is only statistical data and does not, itself, include personal information, though it may be correlated with other personal information to build a unique profile about you.

   The technologies we use for this automatic data collection may include:

   • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
   • Web Beacons. Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, verifying system and server integrity).

   We also collect data concerning the users of our applications. For example, any information that you may provide when creating an account (including personal identifying information) will be retained by us. We also collect IP addresses and information on the activities of the users of our applications, both on an individual and aggregate level, including, for example, how often a user uses a certain platform and what activities the user engages in on a platform.

4. How We Use Your Information & Why We Collect It.

   We use information that we collect about you or that you provide to us, including any personal information:

   • To present our Website, our software applications and their contents to you;
   • To manage our relationship with you;
   • To communicate with users on how to use our services;
   • To market our services and features;
   • To fulfill any other purpose for which you provide it (including to interact with our affiliates or subsidiaries, or third parties that are associated with a transaction that is carried out through our Website or software applications);
   • To carry out our obligations and enforce our rights under our Terms of Use, including restricting access to the Website and our software applications from specific Prohibited Jurisdictions (as defined in our Terms of Use);
   • To allow you to participate in interactive features on our Website and our software applications;
   • To help facilitate the ongoing development of our services;
   • In any other way we may describe when you provide the information; or
   • For any other purpose with your consent.

5. Third-Party Use of Cookies & Other Tracking Technologies.

   Some content or applications, including advertisements, on the Website or in our applications may be served by third-parties, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

6. Disclosure of Your Information.

   We may disclose aggregated information and information that does not directly identify any individual about our users without restriction. We may disclose personal information that you provide to us as described in this Privacy Policy:

   • To our subsidiaries and affiliates;
   • To contractors, service providers and other third parties we use to support our Website and our software applications and services;
   • To provide you with information, products or services that you request from us;
   • To fulfill any other purpose for which you provide it;
   • To provide you with notices about your account, including expiration and renewal notices;
   • To a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company's assets, whether as a going concern or as a part of bankruptcy, liquidation or similar proceeding;
   • For any other purpose disclosed by us when you provide the information; or
   • With your consent.

   We may also disclose your personal information:

   • To comply with any court order, law or legal process, including to respond to any government or regulatory request;
   • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or
   • If we believe disclosure is necessary or appropriate to protect the rights, property or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction or identifying malicious actors using our products or the Company's affiliates or subsidiaries.

   We value your privacy and want to provide you with control over your personal information. If you do not want your personal information sold or disclosed to third parties, please submit a written request to the Company. We will promptly take steps to honor your request.

7. Privacy & The Blockchain.

   A key feature of many blockchain technologies, including any blockchain on which the Company's services rely, is the transparency and public accessibility of on-chain transactions. As such, any information stored on-chain may be public, immutable and not easily removed or deleted and, in many cases, cannot be deleted. Your account with the Company may reveal information about you and this information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. If you are unfamiliar with blockchain technology and its transparent and public nature, we strongly encourage you to conduct your own research into blockchain before electing to use our services.

8. Data Security.

   We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or our software applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

   Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or our software applications.

9. Special Disclosures for European Users.

   Under the European General Data Protection Act, European Union users are entitled to the following:

   • The right to access — You have the right to request copies of your personal data from us. We may charge you a small fee for this service.
   • The right to rectification — You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
   • The right to erasure — You have the right to request that we erase your personal data, under certain conditions.
   • The right to restrict processing — You have the right to request that we restrict the processing of your personal data, under certain conditions.
   • The right to object to processing — You have the right to object to our processing of your personal data, under certain conditions.
   • The right to data portability — You have the right to request we transfer the data that we have collected to another organization or directly to you, under certain conditions.

   If you make a request, we will in most cases respond to you in one month. If you would like to exercise any of these rights, please contact us at [email protected].

10. Data Protection Rights Under the California Consumer Privacy Act (CCPA).

    If you are a California resident, you are entitled to learn what data we collect about you, ask us to delete your data and not to share it. To exercise your data protection rights, you can ask us:

    • What personal information we have about you. If you make this request, we will return to you:
      • The categories of personal information we have collected about you.
      • The categories of sources from which we collect your personal information.
      • The business or commercial purpose for collecting your personal information.
      • The categories of third parties with whom we share your personal information.
      • The specific pieces of personal information we have collected about you.
      • A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your information, we will inform you of that fact.
      • A list of categories of personal information that we have disclosed for business purposes, along with the category of any other company we shared it with.

    Please note, you are entitled to ask us to provide this information twice at any point in a rolling twelve (12) month period. When you make this request, the information we provide will be limited to the previous twelve (12) months.

    • To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
    • To stop selling your personal information. If you submit a request to stop selling your personal information, we will stop selling it. If you are a California resident, to opt-out of the sale of your personal information, please email such request to [email protected].

    Please note, if you ask us to delete or stop selling your data, it may impact your experience with us and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. In no circumstances we will discriminate against you for exercising your rights.

    To exercise your California data protection rights described above, please send your request(s) to [email protected].

11. Changes to Our Privacy Policy.

    It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes. If someone does not agree with this Privacy Policy, they should refrain from using our website and platforms. Continued use of the Website or our software applications after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy.

12. What If I Have Questions About this Privacy Policy?

    If you have any questions about this Privacy Policy, please send a detailed message to [email protected] and we will try to resolve your concerns and provide further information.