4th Whale Marketing Inc. Privacy Policy

Last modified: 2026-05-01

Introduction

4th Whale Marketing Inc. and our affiliates and subsidiaries (“ 4th Whale ” or “ We ”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes:

• How we collect, use, disclose, and protect the personal information of our customers and website users (“ you ”).
• Describes the types of information we may collect from you or that you may provide when you visit the website [ xxx.xxx ] (our “ Website ”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

• On this Website.
• In email, text, and other electronic messages between you and this Website.

The Website may include links to nonparty websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the nonparty to collect or share data about you. If you follow a link to a nonparty website or engage a nonparty plugin, please note that these nonparties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these nonparty websites, and we encourage you to read the privacy policy of every website you visit.

This policy does not apply to information that:

• We collect offline or through any other means, including on any other 4th Whale or nonparty website (including our affiliates and subsidiaries).
• You provide to or is collected by any nonparty (including our affiliates and subsidiaries), through any application or content (including advertising) that might link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you disagree with our policies and practices, your choice is not to use our Website. Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change on one or more occasions (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

Information We Collect About You

We collect and use several types of information from and about you, including:

• Personal information that we can reasonably use to directly or indirectly identify you, including your name, email address, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, and any other identifier we may use to contact you (“ personal information ”).

We provide an opportunity for any user to unsubscribe from our newsletter on an ongoing basis by using the unsubscribe mechanism at the bottom of our emails.

• Non-personal information , that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, including demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
• Technical information , including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
• Non-personal details about your Website interactions , including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

How We Collect Information About You

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us , for example, by filling in forms or corresponding with us by email or otherwise.
• User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or nonparties.
• Automated technologies or interactions , as you navigate through our Website. Information collected automatically might include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• Nonparties or publicly available sources , for example, our business partners.

Information You Provide to Us

The information we collect directly from you on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.

You may also provide information to be published or displayed (“ posted ”) on public areas of the Website or transmitted to other users of the Website or nonparties (collectively, “ User Contributions ”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

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

• Details of your visits to our Website, including traffic data, logs, and other communication data and the resources you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

Please note that we do not recognize or respond to any do not track signals (DNT). For more information about DNT, visit www.allaboutdnt.com .

The information we collect automatically is statistical data and does not include personal information. 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 individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection might 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 might 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 our Website and our emails might contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit 4th Whale, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Nonparty Use of Cookies and Other Tracking Technologies

Some content or applications on the Website are served by nonparties, including advertisers, ad networks and servers, content providers, and application providers. These nonparties might 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 might be associated with your personal information or they might collect information, including personal information, about your online activities over time and across different websites and other online services. They might use this information to provide you with interest-based (behavioural) advertising or other targeted content.

We do not control these nonparties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

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

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts with you, including to comply with legal requirements.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To improve our Website, products or services, marketing, or customer relationships and experiences.
• To allow you to participate in interactive features, social media, or similar features on our Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and nonparties’ goods and services that might be of interest to you, as permitted by law. If you do not want us to use your information in this way, please use the unsubscribe mechanism at the bottom of our emails. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• In accordance with law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of 4th Whale’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by 4th Whale about our customers and users is among the assets transferred.
• To contractors, service providers, and other nonparties we use to support our business (including analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. For example, we use Google Analytics to help us understand how our users use our Website (you can read more about how Google uses your personal information here: https://policies.google.com/privacy ). You can opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout .
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request, in accordance with law.
• To enforce or apply our Terms of Use and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of 4th Whale, our customers, or others. This includes exchanging information with other companies and organizations for cybersecurity, fraud protection, and credit risk reduction purposes.

Transferring Your Personal Information

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other nonparties we use to support our business (including analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that might or might not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country might be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and Canadian privacy legislation.

You are welcome to contact us to obtain further information about 4th Whale policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website might become inaccessible or not function properly. You can opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout .
• Promotional Offers from 4th Whale. If you have opted in to receive certain emails from us but no longer wish to have your email address used by 4th Whale to promote our own or nonparties’ products or services, you can opt-out by sending us an email stating your request to privacy.group@4thwhale.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.

Residents of certain jurisdictions might have additional personal information rights and choices. Please see US State Privacy Rights and EEA/UK Privacy Rights for more information.

Data Security

The security of your personal information is very important to us. We use physical, electronic, and administrative 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, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website, which any Website visitor can view.

Unfortunately, the transmission of information through 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.

Data Retention

Except as otherwise permitted or required by law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal information so it can no longer be associated with you. We may use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Individuals Under the Age of 18

Our Website is not intended for individuals under 18 years old. No one under 18 may provide any information to or on the Website. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you might use. If we learn we have collected or received personal information from an individual under 18, we will delete that information. If you believe we might have any information from or about an individual under 18, please contact us at privacy.group@4thwhale.com.

Accessing and Correcting Your Personal Information

It is important that the personal information we hold about you is accurate. Please keep us informed if your personal information changes. By law you may request access to and correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may send us an email at privacy.group@4thwhale.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal information we hold about you or make your requested changes. Law might allow or require us to refuse to provide you with access to some or all the personal information we hold about you, or we might have destroyed, erased, or made your personal information anonymous under our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact 4th Whale Marketing Inc. at privacy.group@4thwhale.com

If you delete your User Contributions from the Website, copies of your User Contributions might remain viewable in cached and archived pages or might have been copied or stored by other Website users.

Our Terms of Use govern proper access and use of information provided on the Website, including User Contributions.

Residents of certain jurisdictions might have additional personal information rights and choices. Please see US State Privacy Rights and EEA/UK Privacy Rights for more information.

Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you might have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy.group@4thwhale.com. Please note that if you withdraw your consent we might not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

US State Privacy Rights

State consumer privacy laws might provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of personal data processing for:
  • targeted advertising (excluding Iowa);
  • sales; or
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights might vary by state. To exercise any of these rights please email privacy.group@4thwhale.com. To appeal a decision regarding a consumer rights request email privacy.group@4thwhale.com. Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: privacy.group@4thwhale.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

EEA/UK Privacy Rights

If you live in the EEA or the UK, the following terms apply to you.

Legal Basis for Processing

We may process your personal data because you have given us permission to do so (for example, by sending data through our Website’s contact or signup forms), because the processing is in our legitimate interests and it is not overridden by your rights, or because we need to process your personal data to perform a contract with you or comply with the law.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws concerning your personal data. Your rights may include the following:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we might not always be able to comply with your erasure request for specific legal reasons that will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
• Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) if you want us to establish the data’s accuracy; (2) where our use of the data is unlawful, but you do not want us to erase it; (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (4) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we might not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy.group@4thwhale.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to honor your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information regarding your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will let you know and keep you updated.

Changes to Our Privacy Policy

Our policy is 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 by email to the email address specified in your account or through a notice on the Website home page. We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: privacy.group@4thwhale.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with privacy laws. To discuss our compliance with this policy please contact 4th Whale Marketing Inc. using the contact information listed above.

EU and UK Representative

Under article 27 of the EU and UK GDPR, our representatives in the EU and UK are:

EU Representative

Osano International Compliance Services Limited

ATTN: O7QQ

25 North Wall Quay

Dublin 1

D01 H104

UK Representative

Osano UK Compliance LTD

ATTN: O7QQ

42-46 Fountain Street

Belfast

Antrim

BT1 – 5EF

© xxx.xxx