Narwhal Privacy Policy
Last Updated: March 22, 2023
Introduction
This Privacy Policy describes how we, the Emerson Collective LLC d/b/a The Narwhal Project (“Narwhal,” “we,” “our”), collect, use, and share Narwhal platform users’ personal information. By using our website or mobile application (the “Platform” or “Services”), you consent to the practices described in this policy.
Except where otherwise noted, this policy applies to all users regardless of location. Users located in the European Economic Area, Switzerland, the United Kingdom, California, or Virginia can follow the links below to learn more about certain practices that apply only to them.
We may update this policy from time to time. Any changes to this policy will become effective as of the “last updated” date set forth above. Please check back regularly for any changes.
Information Collected
When you use our Services you provide us with information about yourself. We obtain this information either directly from you yourself, automatically when you visit our website, or from third parties. Below is a list of the kinds of information we may collect and from where.
Information You Provide
- Account Information- Everyone needs an account to use Narwhal. When you set up your account you provide us with personal information such as your name, email address, interests, and profile image.
- Communication with Us- You may provide personal information when you correspond with us directly, such as by communicating with user support, or when you respond to our surveys.
- Content of Your Posts- What you write on Narwhal may be considered personal information. While posting on Narwhal, you might include personal information beyond what is listed in this section. Please note that Narwhal does not use personal information solely provided in your posts for any other purpose.
Information Collected Automatically
Device Information- When you use our Services you provide us with some information automatically, including your IP address, location, operating system, and browser type.
Usage Information- We automatically collect information about how you use our Services when you visit our Platform, including the pages you visit and how long you spend on them.
Information Collected from Third Parties
Referrals- You may have been invited to join us on Narwhal by a friend or family member. They provide us with your name and email address so we can send you your invitation.
How We Use Your Information
We use your personal information in a variety of ways that enable us to operate and improve our business. The following describes how we use it in further detail.
Providing the Services- We use your information to maintain and allow you access to your account; enable you to post on the Platform; provide you with user support; and to communicate with you.
Analytics and Research & Development- We are constantly striving to improve our Platform. We use your information to evaluate how we are doing and to help us figure out how to change current features and develop new ones.
Safety & Security- We aim to make Narwhal a space where all feel welcome and safe. To do so, we may use your personal information for safety and security purposes including enforcing our Community Guidelines, fraud prevention, and to prevent cyberattacks.
Legal Compliance- We may use your personal information when we deem it necessary to comply with the law and law enforcement.
When We Share Your Information
We may share some of your personal information with service providers in order to operate the Services. A list of vendors and the purposes for which we share your information is below.
| Service Provider | Purpose | Account information, content of posts |
|---|---|---|
| Amazon Web Services | Storing and accessing information | Device Identifiers; Behavioral Information; account information |
| Mixpanel | Analytics | 1972 |
| SupaBase | Database hosting | Account information and user generated content |
Data Retention
We hold on to your information for as long as it is needed. Typically, this means for as long as you have an account with us, but we may have reason to keep it for longer. For example, we may need to hold onto information in order to maintain a list of banned accounts. Additionally, the content of your posts will remain visible on the Platform indefinitely, however your username will not appear next to your posts if you no longer have an account with us.
Opt out of Communication
You have the right to opt out of communication with us at any time. To do so, please follow the “unsubscribe” link at the bottom of any email we send. There, you can opt to unsubscribe from all or only some types of
Contact Information
You can contact us by email at privacy@thenarwhalproject.com. Alternatively, you can write to us at the following address: The Narwhal Project ATTN: General Counsel 130 Prince Street New York, NY 10012
Additional Information for Users in the European Economic Area, Switzerland, and the United Kingdom
Below you will find additional information on how we use your personal information (referred to as “personal data” in the General Data Protection Regulation and other laws) and the rights you have over it. This section only applies to users based in the European Economic Area, Switzerland, and the United Kingdom and is subject to the European Union’s General Data Protection Regulation (“GDPR”), the Swiss Federal Data Protection Act (“FADP”), and the United Kingdom’s General Data Protection Regulation (“UK GDPR”) (collectively, “European Data Privacy Laws”)
Lawful Basis for Processing
Earlier in this policy we let we know what kind of personal information we collect from you and how we use it and share it (in other words, how we process your information). We will only process your data if we have a lawful basis for doing so. While different data points may be processed for different reasons, our primary bases are (1) to fulfill our agreement to provide you with our Services, and (2) our legitimate interests, such as to ensure the safety and security of the Platform or to conduct research & development. We may also process your information in order to fulfill legal obligations should they arise.
International Data Transfers
Narwhal is headquartered in the United States and stores data on U.S.-based servers. If you are accessing Narwhal outside of the U.S., including in the EEA, UK, and Switzerland, your personal information may be subject to an “international data transfer,” as defined in European Data Privacy Laws. By using Narwhal, you consent to this kind of transfer. In order to protect the security of your information, we rely on the European Commission’s Standard Contractual Clauses and/or the United Kingdom’s International Data Transfer Agreement or Addendum depending on the source of the data and the specific circumstance, when making such transfers.
Your Rights Concerning Your Personal Information
Access- You have the right to access the personal information we hold about you. You may request that we provide you with the categories of information we have about you and/or the specific data points that we have. To make this request, please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Correction- You have the right to request that we correct incorrect personal information we hold about you or to supplement incomplete information. To make this request, please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Deletion- You have the right to instruct us to delete the personal information we hold about you. While submitting a deletion request will cause us to delete your account and all associated personal information, the posts you made on Narwhal will remain on the Platform. However, your username will no longer appear connected to them. We may also still retain limited personal information for legal compliance and to ensure site safety and security. To make this request, please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Objection and Withdrawal of Consent- You can change your mind about how we process your personal information at any time, including objecting to us processing it based on our legitimate interest. To withdraw or change your consent preferences please email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
How to Appeal- In the event that any of the requests listed above are denied, you have the right to appeal our decision. To do so, please email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of the request that was denied as possible.
Right to Lodge a Complaint
If you believe that we have processed your personal information in violation of a European Data Privacy Law, you have the right to lodge a complaint with the Supervisory Authority of the country in which you reside.
Additional Information for California Residents
Below you will find additional information on how we use your personal information and the rights you have over it. This section only applies to California Residents, subject to the California Privacy Rights Act (“CPRA”).
Information We Disclose To Third Parties
As described earlier in this policy, we may share your personal information with service providers in order to operate our business. For example, we may share your name and contact information with a service provider that helps us manage our communications with you. Information we may share includes identifiers (such as your name, contact information, IP address, and device identifiers); internet activity information (such as your browsing history on our Services and interactions with our Services); and geolocation data.
Your California Privacy Rights
Under the CPRA, you have certain rights related to how we use and store your personal information. Information on what these rights are and how to exercise them is below. We will not discriminate or retaliate against you for exercising any of these rights.
Access- You have the right to know the categories of personal information we hold about you, where we got it from, why we collected it, and to whom we disclose it. You additionally have the right to request an account of the specific pieces of personal information we hold about you. To request any or all of this information, please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Correction- If you believe that any personal information we hold about you is incorrect or incomplete, you can ask that we correct it. For any other corrections please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Deletion- You have the right to instruct us to delete the personal information we hold about you. While submitting a deletion request will cause us to delete your account and all associated personal information, the posts you made on Narwhal will remain on the Platform. However, your username will no longer appear connected to them. We may also still retain limited personal information for legal compliance and to ensure site safety and security. To make this request, please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Selling and Sharing of Data
We do not “sell” or “share” your personal information. Under the CPRA, a business “sells” your personal information when it discloses it to a third-party for something of monetary or any other value. A business “shares” your personal information when it discloses it to a third-party to facilitate targeted advertising. We do neither.
Additional Information for Virginia Residents
Below you will find additional information on how we use your personal information and the rights you have over it. This section only applies to Virginia residents, subject to the Virginia Consumer Data Protection Act (the “VCDPA”).
Access- You have the right to know the categories of personal information we hold about you, where we got it from, why we collected it, and to whom we disclose it. You additionally have the right to request an account of the specific pieces of personal information we hold about you. To request any or all of this information, please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Correction - If you believe that any personal information we hold about you is incorrect or incomplete, you can ask that we correct it. You can correct some information yourself by visiting your account settings page. For any other corrections please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Delete- You have the right to instruct us to delete the personal information we hold about you. While submitting a deletion request will cause us to delete your account and all associated personal information,, the posts you made on Narwhal will remain on the Platform. However, your username will no longer appear connected to them. We may also still retain limited personal information for legal compliance and to ensure site safety and security. To make this request, please fill out this form or email us at privacy@thenarwhalproject.com. In your email, please provide as complete a description of your request as possible.
Selling and Sharing of Data
We do not “sell” or “share” your personal information. Under the CPRA, a business “sells” your personal information when it discloses it to a third-party for something of monetary or any other value. A business “shares” your personal information when it discloses it to a third-party to facilitate targeted advertising. We do neither.
Information We Disclose To Third Parties
As described earlier in this policy, we may share your personal information with service providers in order to operate our business. For example, we may share your name and contact information with a service provider that helps us manage our communications with you. Information we may share includes identifiers (such as your name, contact information, IP address, and device identifiers); internet activity information (such as your browsing history on our Services and interactions with our Services); and geolocation data.