Privacy Policy

Last Updated: February 14, 2026

1. INTRODUCTION

1.1 About This Policy

This Privacy Policy explains how Gray Whale Inc (“Gray Whale,” “we,” “us,” or “our”), a Delaware C corporation, collects, uses, discloses, and safeguards your information when you visit our website https://graywhale.ai (the “Website”) or use our services.

We respect your privacy and are committed to protecting your personal information. We encourage you to read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.

1.2 Changes to This Privacy Policy

We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will notify you about material changes in the way we treat personal information by adequately informing you via your account, by placing a prominent notice on our Website, or through other appropriate communication channels. It is your responsibility to review this Privacy Policy periodically. All changes shall be effective from the date of publication unless otherwise provided.

We encourage you to review this Privacy Policy periodically to stay informed about our data practices and your choices.

1.3 Children’s Privacy

We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at privacy@graywhale.ai, and we will delete such information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

1.4 Key Terms

For clarity in this Privacy Policy, we use the following terms:

Personal Information: Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Processing: Any operation or set of operations performed on personal information, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Services: All services provided by Gray Whale Inc, including those available through our Website.
User, You, and Your: All individuals who use our Website or Services.

2. GRAY WHALE AS A DATA CONTROLLER AND PROCESSOR

2.1 Gray Whale as a Data Controller

For purposes of data protection laws, Gray Whale is the “data controller” (or similar term under applicable laws) and is generally responsible for and controls the processing of your personal information collected through your use of our Service. This Privacy Policy applies to instances where Gray Whale acts as a data controller.

2.2 Gray Whale as a Data Processor

In providing our Service, our customers may collect data in our products and services, or we may collect data on their behalf, which may include personal information or data about our customers’ end users (“Customer Data”). In such instances, Gray Whale acts as a “data processor” (or similar term under applicable laws), and we have contractually committed ourselves to process Customer Data on behalf and under the instruction of the respective customer, who is the data controller. This Privacy Policy does not apply to the processing of Customer Data and we recommend you read the Privacy Policy of the respective customer if their processing concerns your personal information.

3. YOUR CONSENT TO THIS PRIVACY POLICY

Our Privacy Policy applies to any visitor to the Website or user of our Services (collectively, “you”). We ask you to show your consent to this Privacy Policy in different ways.

Consent by Site User. We have structured the Website and Services so that you may be able to review selected information about the Services and even use the Services without providing us with any Personally Identifiable Information. By accessing our servers and using the Services as a visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it.

Consent by User Acting in a Representative Capacity. If you are agreeing to our Privacy Policy on behalf of a company or other legal entity (“Your Organization”), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization, and (ii) for all purposes in this Privacy Policy, the term “you” means Your Organization on whose behalf you are acting.

Right to Withdraw Consent. You have the right to withdraw your consent at any time, in accordance with Section 6 (Your Privacy Rights).

4. INFORMATION WE COLLECT

We collect several types of information from and about users of our Website and Services, including:

4.1 Information You Provide to Us

We may collect personal information that you voluntarily provide to us when you:

Register on our Website
Subscribe to our newsletter or communications
Request information or assistance
Participate in surveys or contests
Contact our customer service
Provide feedback or testimonials
Apply for employment opportunities

The types of information we may collect include:

Identifiers: Such as your name, email address, postal address, phone number, and other similar identifiers.
Account Information: Such as your username, password, and account preferences.
Commercial Information: Such as records of products or services purchased, obtained, or considered.
Professional Information: Such as your occupation, employer, professional qualifications, and work history if you apply for employment.
Communications: Records of your communications with us, including customer service inquiries and feedback.

4.2 Information We Collect Automatically

When you visit our Website or use our Services, we may automatically collect certain information about your equipment, browsing actions, and patterns, including:

Technical Information: Such as your Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
Usage Information: Such as information about how you use our Website and Services, including the full Uniform Resource Locators (URLs), clickstream to, through, and from our Website (including date and time), products or services 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), methods used to browse away from the page, and any phone number used to call our customer service.
Location Information: Such as general geographic location based on the IP address we collect.

4.3 Information Collected Through Cookies and Similar Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activities on our Website. Cookies are small data files stored on your device that help us improve your experience on our Website, see which areas and features of our Website are popular, and count visits.

For more information about these practices and your choices regarding cookies, please see our “Cookies and Tracking Technologies” section below.

4.4 Information from Third Parties

We may receive information about you from third parties, including:

Business Partners: We may receive information about you from our business partners, such as when they co-sponsor an event or promotion with us.
Service Providers: We may receive information about you from our service providers who help us with various aspects of our business operations.
Publicly Available Sources: We may collect information about you from publicly available sources, such as public social media profiles.

4.5 Information We Do Not Collect

We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information. If you choose to provide such information to us, we will treat it in accordance with this Privacy Policy and applicable laws.

We do not collect biometric information or precise geolocation data unless you specifically opt-in to such collection.

5. HOW WE USE YOUR INFORMATION

Gray Whale Inc uses the information we collect for various business and commercial purposes. We have outlined these purposes below:

5.1 Business Purposes

We may use your personal information for the following business purposes:

To provide and maintain our Services: Including to operate our Website, provide you with updates and other information relating to the Website, and to maintain and improve the performance of our Services.
To manage your account: Including to manage your registration as a user of our Services, manage your account settings, and handle your requests.
To fulfill and manage your orders: Including to process and deliver your orders, manage payments, fees, and charges, and collect and recover money owed to us.
To communicate with you: Including to respond to your inquiries, comments, feedback, or questions, provide customer support, send you technical notices, updates, security alerts, and administrative messages, and communicate with you about products, services, offers, promotions, and events offered by Gray Whale Inc and others.
To personalize your experience: Including to personalize your experience on our Website and present products and offers tailored to you.
To improve our Website and Services: Including to administer our Website, diagnose any problems with our servers, analyze trends, track visitor movements, gather demographic information, and improve the overall quality and user experience of our Website and Services.
To protect our Services: Including to detect, investigate, and prevent fraudulent transactions and other illegal activities, verify identity, and protect against unauthorized access to personal information.
To comply with legal obligations: Including to comply with legal requirements, industry standards, and our policies.

5.2 Commercial Purposes

We may use your personal information for the following commercial purposes:

Marketing and advertising: Including to send you promotional communications, offer you products and services, and present advertisements that may be of interest to you.
Market research and analysis: Including to conduct research and analyze data to improve our products and services and develop new products and services.

We will not use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.

6. HOW WE SHARE YOUR INFORMATION

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as described below.

6.1 Service Providers

We share personal information with third party contractors and service providers, that are subject to reasonable confidentiality terms, and which may include processing payments, providing web hosting and maintenance services, technology support providers, email and messaging communications providers, analytics providers, data storage providers, and web and video hosting providers and developers. Any such service providers will be subject to confidentiality provisions, and be bound to only process the data on our behalf and under our instructions, unless such service providers act as their own controllers (e.g., in the case we seek advice from lawyers and tax consultants).

6.2 Business and Marketing Partners

We may also disclose personal information with other business and marketing partners with whom we jointly offer products or services, co-market or host events, or who are part of our partner ecosystem. We may obtain your consent where required by applicable law. Our business and marketing partners will use your information in accordance with their own Privacy Policies.

6.3 Advertising Partners

We may share certain personal information (including information collected through cookies) with our advertising service providers and vendors in order to advertise our Services to you. For more information on how we collect and share this information, please see the Online Advertising section of this Privacy Policy.

6.4 Corporate Transactions

We may transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, change of control or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Policy.

6.5 Legal Obligations and Rights

We may disclose personal information to third parties, such as legal advisors and law enforcement agencies, regulators, other authorities and other third parties for legal reasons if we reasonably believe that such action is necessary:

in connection with the establishment, exercise, or defense of legal claims;
to comply with laws or to respond to lawful requests and legal process;
to protect our rights and property and the rights, personal safety and property of others, including to enforce our agreements and policies;
to detect, suppress, or prevent fraud; or
as otherwise required by applicable law.

6.6 With Your Consent

We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our website or service-related publications.

7. ONLINE ADVERTISING

We may share (or we may permit these parties to collect) personal information with online advertising networks, social media companies, and other third-party services, including information about your use of our Service over time, so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, clickstream information, browser type, time and date you visited the website and other information.

This information is used to display targeted ads on other websites, apps, or services. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. We may also display targeted advertising to you through social media platforms, such as LinkedIn, Facebook, Twitter, Google, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics.

For more information on our online practices specifically in relation to cookies, please see our Cookie Notice.

8. CONTROL OVER YOUR INFORMATION

8.1 Email Communications

From time to time, we may send you emails regarding updates to our Services, products or services, notices about our organization, or information about products/services we offer that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related communications (e.g., account verification, confirmations of transactions, technical or legal notices).

8.2 Messaging Platforms

We may use personal information we collect to communicate with individuals via messaging platforms, including to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from these messages at any time by replying STOP in one of our messages.

8.3 SMS Text Messaging

We may use personal information we collect to communicate with individuals via text message, including (with your consent) to market to you or offer you information and updates on products or services we think you may be interested in. You can unsubscribe from marketing text messages at any time by replying STOP or clicking the unsubscribe link (where available) in one of our messages. For more information, please see our Terms of Service.

8.4 Modifying Account Information

If you have a Gray Whale service account with us, you have the ability to modify certain information in your account (e.g., your contact information and profile picture) through the “Account” or “Profile” section in your account. Not all personal information is maintained in a format that you can access or change. If you would like to request access to, or correction or deletion of personal information, you may send your request to us by messaging support through your Gray Whale account. We will review your request and may require you to provide additional information to identify yourself, but we do not promise that we will be able to satisfy your request.

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 Cookies and Similar Technologies

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. For more information about these practices and your choices regarding cookies, please see our Cookie Notice.

9.2 Cookie Management

You can manage your cookie preferences through our cookie management tool:

Cookies Settings

To opt-out of targeted advertising (cookies opt-out), please use our cookie management tool above.

10. THIRD PARTY WEBSITES AND SERVICES

The Services may contain integrations or links to third party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party and not Gray Whale. Please note that Gray Whale is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the Privacy Policies and online terms of those third parties to learn more about how they handle your personal information.

11. PRIVACY RIGHTS

In accordance with applicable privacy law and the jurisdiction in which you reside (including, without limitation, Colorado, Connecticut, Utah, and Virginia), you may be able to exercise some or all of the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

11.1 Right of access and portability

You may have the right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information.

11.2 Right to correction

You may have the right to require us to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

11.3 Right to deletion

You may have the right to request the deletion of your personal information, subject to certain exceptions.

11.4 Right to opt-out

You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or the “sale” of your personal information to third parties in certain contexts. You may also have the right to direct us not to use automated decision-making or profiling for certain purposes.

11.5 Right to exercise control over sensitive personal information

You may have the right to exercise control over our collection and processing of certain sensitive personal information.

11.6 Right to non-retaliation

You may have the right to be free from retaliatory or discriminatory treatment for exercising any of the rights described above.

To exercise your rights: please submit a request by filling out our Privacy Rights Request form or by emailing privacy@graywhale.ai.

Before processing your request, we will need to verify your identity and confirm you are a resident of a jurisdiction that offers such right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional personal information so that we can properly identify you to track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. We may not process your request if we, in good faith, believe that the request is fraudulent. In such instances, we will send a notice to the requestor explaining our decision.

12. DATA STORAGE AND SECURITY

We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting credit or debit card information.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

13. INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to and stored in locations outside your jurisdiction of residence where we and our third-party service providers have operations, including in the United States, where Gray Whale Inc. is located.

In the event of a transfer by Gray Whale to a location outside your jurisdiction, we ensure that: (i) personal information is transferred to countries recognized as having an equivalent level of privacy protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as contractual obligations.

14. CHILDREN

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.

15. CHANGES TO PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will notify you about material changes in the way we treat personal information by adequately informing you via your account, by placing a prominent notice on our website, or through other appropriate communication channels. It is your responsibility to review this Privacy Policy periodically. All changes shall be effective from the date of publication unless otherwise provided.

16. CONTACT US

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@graywhale.ai.

17. REGION-SPECIFIC DISCLOSURES

This Privacy Policy is designed to apply to our website visitors, users of our Service, and other companies and users on a global basis. Please refer below for additional disclosures that may be applicable to you:

17.1 ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS (UNITED STATES)

These additional disclosures for California residents (“CA Disclosures”) supplement the information contained in our Privacy Policy and apply solely to individual residents of the State of California (“consumers” or “you”).

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”) Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

A. COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information from and about you for a variety of purposes, as described in the How We Collect Your Personal Information and How We Use Your Personal Information sections of the Privacy Policy.

B. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

In the last 12 months, we have collected the following categories of personal information:

Identifiers, such as name, email address, mailing address, phone number, account name, IP address, and an ID or number assigned to your account.
Customer records, such as billing and shipping address, and credit or debit card information.
Commercial information, such as products or services history and purchases.
Internet or other electronic network activity information, such as log data, referring and exit pages, date and time of your visit, browser type, and cookie data.
Geolocation data, such as general location information derived from IP address.
Professional or employment-related information, such as business contact details, job title, or business affiliations.
Inferences, including information about your interests, preferences