Soluna Labs Inc (together with its affiliates, “Soluna,” “we” or “us”) respects the privacy of the users (“User” or “you”) of its website located at www.soluna-labs.com (the “Website”) and apps (collectively, the “Services”). We are committed to protecting the information we collect and receive.
1. Collection of Information
Through your use of the Services, we collect only “General Information,” which cannot be used to identify you. We do not actively collect “Personal information” which can be used to identify you, unless such information is sent to us by you or others via email by your/their own will. In most cases we will actively delete any received personal information immediately and will not store or process it. We will maintain only general information.
Together, Personal Information and General Information are referred to as “Information.” The Information we collect may include:
a. Information You Generate. Soluna collects the content of the communications that you input using the website or send to our email (collectively, “Content”). Examples of Content include text, documents, audio, video, photos, images, software, and other media and files.
c. Web beacons. “Web beacons” (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on web pages (or in an e-mail).
2. Usage of Information
We are committed to protecting your privacy and earning your trust. Your Information is an integral part of our operations, and we used it in a variety of ways in providing and improving the Services, administering your use of the Services, operating our business, and complying with our legal obligations. For example:
a. To Operate and Provide Services. We collect and use Information to operate and provide you with our Services in accordance with our legitimate interests.
b. For Informational, Promotional and Survey Purposes. We may use your Personal Information to inform you of our product and service offerings, subject to your ability to opt-out of receiving such information as described below. We may also contact you via surveys to conduct research about your opinion of current Services features or of potential new services. These activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest.
c. For Customized and Efficient Provision of Services. Soluna keeps track of the websites and pages you visit within our website and what features and algorithms you use and how frequently. We use this information to maintain and improve the content, design, usability and quality of the Services; to improve your user experience; to generate and provide statistics regarding use of the website and the Services to deliver customized content and advertising to Users whose behavior indicated that they are interested in a particular subject area, and to develop new product and service offerings. These activities are based on our legitimate interest in improving the functionalities of the Services.
d. Maintaining the Security of the Services and Complying with Applicable Law. We may use Information to prevent potentially prohibited or illegal activities, to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity, to conduct security investigations and risk assessments, comply with our legal obligations, resolve any disputes with any of our Users and enforce our agreements with third parties, and to enforce our agreements and other policies.
We process this Information given our legitimate interest in (i) improving the Services and our Users’ experience with it, (ii) protecting the Services, (iii) measuring the adequate performance of our contracts where it is necessary to process such data for adequate performance of the contract with you, (iv) undertaking marketing activities to offer you products or services that may be of interest to you, subject to your request to opt out of such marketing activities, and (iv) complying with applicable laws. Please review “Your Rights and Choices” below.
3. Sharing Information with Third Parties
We will not share any Information that we have collected from or regarding you except as described below:
a. With Your Consent. Where you have provided consent, we share your Information, including Personal Information, as described at the time of consent, such as when you authorize a third party application or website to access your membership or when you participate in promotional activities conducted by Soluna partners or third parties.
b. Services Providers. We may engage third-party services providers to work with us to administer and provide the Services. These third-party services providers have access to and may collect Information only for the purpose of performing services on our behalf and are not permitted to share or use the Information for any other purpose. They are also required to follow the same data security practices that we ourselves adhere to, and they may be located inside or outside of the European Economic Area (“EEA”).
c. Aggregated and Anonymous Information. We may share aggregated and anonymous General Information with third parties for industry research and analysis, demographic profiling and other similar purposes. This Information does not contain any Personal Information.
d. Business Transactions. Information that we collect from our Users, including Personal Information, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third party acquirer in connection with the transaction.
e. Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any Information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
We take great care in maintaining the security of our Services and your Information and endeavor to take all commercially reasonable measures to prevent unauthorized access to your Information by using standard technology and internal procedures. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the security of any information you transmit to us or store on the Services and you do so at your own risk. We also cannot guarantee that such Information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
5. Privacy of Children
The Services are intended for a general audience and are not directed to children under the age of 16. We do not knowingly collect Information from anyone under the age of 16. If we learn that we have inadvertently collected Personal Information from a child under the age of 16, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 16, please contact us at firstname.lastname@example.org.
6. California Residents
Under California law, users who are residents of California are permitted to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year (if any) and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.
7. Data Retention
The length of time we retain Information depends on a number of factors relating to our business needs and legal requirements. In general, we will keep Information for such time as required by applicable law or to exercise our legal rights.
8. Your Rights
We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all the features of the Services. You may exercise any of the rights described in this section below by sending an email to email@example.com. Please note that we may ask you to verify your identity before taking further action on your request.
b. Accessing, Modifying and Deleting Your Information. You can access, update, modify or delete the Personal Information associated with you, by sending us an email at firstname.lastname@example.org. If you want us to delete your Personal Information, please contact us with your request. We’ll take steps to delete your Personal Information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law. You further have the right to ask us to correct inaccurate or incomplete Information concerning you (and which you cannot update yourself within your account).
c. Data Portability. In some jurisdictions, applicable law may entitle you to request copies of your Personal Information held by us. You may also be entitled to request copies of Information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
d. Withdrawing Consent and Restriction of Processing. Where you have provided your consent to the processing of your Personal Information, you may withdraw your consent at any time by changing your membership settings or by sending us a communication specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Information, in particular where (i) you contest the accuracy of your Personal Information; (ii) the processing is unlawful and you oppose the erasure of your Personal Information; (iii) we no longer need your Personal Information for the purposes of the processing, but you require the Information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to your right to object to processing (below) and pending the verification whether the legitimate grounds of Soluna override your own.
e. Objection to Processing. In some jurisdictions, applicable law may entitle you to require us not to process your Personal Information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your Personal Information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.
9. Links to Other Sites
10. International Transfer
Soluna sites and are primary located and managed on servers within the USA. In order to provide our products and services to you your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.
• Necessary Cookies – Necessary Cookies are essential to navigate the Website and use the Services. For example, these Cookies help remember your preferences as you move around the Website.
• Statistics Cookies – Statistics Cookies collect anonymous data for statistical purposes on your use of the Services. We use Information supplied by Statistics Cookies to help understand how you use the Services, to monitor aggregate usage and web traffic routing, and to improve and customize the Services. These Cookies don’t contain Personal Information and are generally set by independent analytics companies.
• Preferences Cookies – These cookies are used during your visit to the Website to remember information you have entered or choices you make, and they permit us to remember your preferences for future visits.
• Marketing Cookies – These Cookies are placed by third party advertising companies to collect information about your activities to deliver targeted and relevant ads to you and to track ad performance. These third party companies have their own privacy and cookie policies, and they may use their Cookies to target advertising to you on other websites, based on your visit to our Website.
b. How Can I Control My Cookies? You can manage and disable Statistics Cookies, Preferences Cookies or Marketing Cookies by sending an email to email@example.com You can prevent Cookies from being placed on your device through your browser settings by following the instructions set out at allaboutcookies.org. Most browsers also provide the ability to let you review and erase Cookies. You can also opt-out of third party targeting or advertising Cookies through the Digital Advertising Alliance, the Network Advertising Initiative or the European Interactive Digital Advertising Alliance.