Privacy Policy

Last updated: October 22, 2025

1. Introduction

The Whales Club ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, and safeguard your information when you visit our website, use our gift card trading services, or interact with our platform. We are committed to transparency in our data practices.

2. Information We Collect

2.1 Personal Information

We may collect the following personal information:

• Name and contact information (email, address)
• Business or organization name (for bulk traders)
• Gift card trading history and transaction details
• Payment and banking information
• Identity verification documents
• Communication preferences

2.2 Automatically Collected Information

When you visit our website, we automatically collect:

• IP address and device information
• Browser type and version
• Pages visited and time spent
• Referring website information
• Cookies and similar technologies

3. How We Use Your Information

We use your information for the following purposes:

• Providing and managing our gift card trading services
• Processing gift card transactions and payments
• Verifying identity and preventing fraud
• Communicating with you about trading opportunities and updates
• Improving our platform and services
• Complying with legal and regulatory obligations
• Providing customer support and assistance

4. Legal Basis for Processing

We process your personal information based on:

• Consent: When you explicitly agree to our data processing
• Contract: To fulfill our obligations to you
• Legitimate Interest: To provide and improve our services
• Legal Obligation: To comply with applicable laws

5. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

• Service Providers: With trusted third parties who assist in our operations
• Payment Processors: With financial institutions for transaction processing
• Legal Requirements: When required by law or legal process
• Protection of Rights: To protect our rights, property, or safety
• Fraud Prevention: With security services to prevent fraudulent activities
• With Your Consent: When you explicitly authorize sharing

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. We regularly review and delete unnecessary data.

8. Your Rights and Choices

8.1 General Rights

You have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of your information
• Object to our processing of your information
• Request data portability
• Withdraw consent where applicable

8.2 California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected and how it's used
• Right to delete personal information
• Right to opt-out of the sale of personal information
• Right to non-discrimination for exercising privacy rights

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze website traffic and usage
• Provide personalized content
• Improve website functionality

You can control cookie settings through your browser preferences. However, disabling cookies may affect website functionality.

10. Third-Party Services

Our website may contain links to third-party websites and services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

11. Children's Privacy

We do not knowingly collect personal information from children under 13 without parental consent. If we become aware that we have collected such information, we will take steps to delete it promptly. Parents or guardians who believe we have collected their child's information should contact us.

12. International Data Transfers

Your personal information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place to protect your information in accordance with this policy.

13. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of any material changes by posting the new policy on our website and updating the "Last updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

14. Contact Us

If you have any questions about this privacy policy or our data practices, please contact us: