Introduction & Scope

Bit Labs Inc. (“Bit Labs”, “we”, “our” or “us”) is a technology company which provides access to software applications such as Nobl (the “App”).

The purpose of this Privacy Policy (“Policy”) is to provide you with information about how we collect, use, disclose and protect your personal informal information in connection with the App and any other services made available through the App (the “Services”).  In this Policy, “personal information” means information about an identifiable individual.

In adopting and adhering to this Policy, we assure you that the personal information we collect will be used in an appropriate and responsible manner.  Bit Labs is committed to protecting the privacy of all personal information which has been provided to us and we will manage personal information in accordance with applicable Canadian privacy legislation and any other applicable provincial or federal legislation.

This Policy applies to all users of the App and Services (“Users”).  This Policy applies only to information we collect in the App and in email, text, and other electronic communications sent through or in connection with the App.  This Policy DOES NOT apply to information that we collect offline or on any other Bit Labs applications or websites, including websites you may access through this App.

Please read this Policy carefully.  If you do not agree with our policies and practices, do not download, register with, or use this App.  By downloading, installing, registering with, or using the App or Services, you acknowledge the notices in this Policy and you consent to our collection, use, disclosure, and retention of your personal information in accordance with this Policy and as otherwise permitted by law.

Withdrawing Your Consent

Where you have provided your consent to the collection, use and/or disclosure of your personal information, you may have the legal right to withdraw your consent by giving Bit Labs reasonable notice.  Consent may not be withdrawn where doing so would frustrate the performance of a legal obligation.  To withdraw your consent, if applicable, contact the Bit Labs Privacy Officer (see the “Questions and Concerns” section below).  Please note that if you withdraw your consent, we may 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 make your decision.

Personal Information We Collect About You And How We Collect It

Bit Labs collects personal information from Users when they provide information directly to Bit Labs and when they use the App and/or the Services.  Bit Labs also collects some personal information from Users automatically, which is addressed in more detail below.

In some cases, Bit Labs may seek your consent for the use and disclosure of your personal information after it has been collected, but before it has been used or disclosed (e.g. where we want to use your personal information for a purpose not previously identified to you).  We will not use or disclose your personal information for any new purpose without first identifying the new purpose and providing notice to you or obtaining your consent (as applicable), unless otherwise permitted by law.

You can always choose not to provide Bit Labs with certain requested personal information, but then you may not be able to access or utilize all or part of the App and/or the Services.

  1. Personal Information You Provide to Bit Labs

We collect the following types of personal information from Users:

  • Contact information: we collect your personal information when you contact Bit Labs directly to inquire about the App and/or the Services.  This may include your name, e-mail address, phone number, and other information that you choose to provide to us.
  • Account and profile information: we collect your personal information when you register for a Nobl account (“Account”), and when you create or modify your Account or user profile.  This includes information such as your e-mail address, username, and password (this is the only personal information required to create an Account). If you include personal information in your profile bio, we collect that personal information.  If you upload a photograph of yourself to your user profile, we collect that information.  You are not required to upload a photograph of yourself, or at all, to create an Account.  If you do upload a photograph, it will be viewable to all other Users.  Users can choose to enter their full name, business name, or phone number in their user profile.  While your email address and phone number will not be displayed to other Users, that information will be searchable by them.
  • User Payment information:
  • Feedback: we collect the information you include in any feedback you provide to Bit Labs through the App.  For example, if you report a problem with the App, or if you provide feedback to Bit Labs about another User.
  • User contributions: we collect personal information when you provide information for publication or display (“posted”) within the App or through the Services (collectively, “User Contributions”).  This includes when you post or share messages, information, images, data, video, audio, or any other content in any public or private area within the App or through the Services, including via our private Messages.  You post and transmit User Contributions to others at your own risk.  Bit Labs cannot control the actions of third parties with whom you may choose to share your User Contributions.  Therefore, we do not guarantee that unauthorized persons will not view your User Contributions.  Bit Labs may collect any information that you disclose through such means, and your comments and messages may be monitored, and/or moderated for purposes such as removal of profanity, personal information, and other inappropriate conversations.
  • Other information: we collect any other personal information that Users submit directly to Bit Labs on a voluntary basis.  For example, you may provide information to Bit Labs in respect of a claim or dispute.
  1. Personal Information Automatically Collected When Using the App

  • Technical and usage information: we collect information about the sections of the App that you visit, the date and time of your use of the App and your in-media time, your actions within the App (e.g. search queries), App crashes and other system activity, and certain content that you download from the App
  1. Information We Receive from Other Sources

How We Use Your Personal Information

Bit Labs may use the personal information that it collects for the following purposes:

  • Contact information: we use your contact information to contact and correspond with you directly about our relationship, and your use of the App and/or Services.  Bit Labs may contact you to inform you about its services in different ways including by email, telephone, or other means to which you have agreed.  We may use your contact information to provide you with information or services that you have requested, to respond to customer service requests.  We may also use your contact information to notify you when App updates are available, and of changes to any products or services we offer or provide through it.  Where we have your consent to do so, we may send you information about Bit Labs services, including general updates and announcements, and for other opportunities (see below for information on how to “opt-out” of receiving certain communications from us).
  • Account and profile information: we use your Account and profile information to provide you with access to the App and/or Services, to create and set up your Account and user profile, and to administer your use of the App and/or Services.
  • User Payment information: we use User payment information to facilitate payments between Users
  • Feedback: we use feedback information to improve the App, and/or Services, including to administer and resolve technical issues on the App.  We may also use this information to investigate and address User concerns.  In addition, we may use this information to suspend or deactivate the accounts of Users.
  • Technical and usage information: we use this information to understand traffic and activity on the App, and to enable us to improve the App and/or the Services.

In general, Bit Labs may also use the personal information we collect:

  • To conduct data analysis, testing, research, and monitor and analyze usage and activity trends;
  • to promote the safety of Users;
  • to ensure compliance with and identify violations of the Terms of Use;
  • to identify and prevent fraudulent activity and to protect security of the App;
  • to meet legal and regulatory requirements; and
  • to facilitate such other services and activities, as we may identify to you at the time.

Bit Labs will only use your personal information for the purpose for which it was originally collected, or for a use consistent with that purpose, unless you expressly consent otherwise or it is permitted or required by law.

If you provide us with your e-mail address and “opt-in” to receiving messages from us via the e-mail address provided, you may receive electronic communications from us from time to time.  These electronic communications will provide you with our contact information and a method to opt-out and unsubscribe from receiving marketing information and/or any further communications from us.  You can also always opt-out by contacting the Privacy Officer at the details below.  Bit Labs may use your e-mail address to communicate with you regarding important matters, such as information about your Account.  You may not opt-out of receiving communications required by law, or necessary to provide you with requested services.

Disclosure Of Your Personal Information

Except as described in this Policy or in other situations where we have provided you with prior notice, have obtained your consent, or are obligated or permitted by law, Bit Labs will not share your personal information with third parties.  We may disclose personal information that we collect or you provide as described in this Policy.

  1. Third Party Service Providers

Bit Labs may disclose certain personal information to third party service providers with whom it has contracted to provide certain services on behalf of Bit Labs.  Currently, Bit Labs uses the third party service providers set out below:

  • Hosting and backend infrastructure services: we use a third party cloud computing platform, Amazon Web Services, to host certain information, including User’s personal information. The Amazon Web Services privacy policy is available here:
  • Electronic communications: we use a third party email service provider, Mailgun Technologies, Inc., dba “Mailjet”, to send electronic communications to Users. The Mailjet privacy policy is available here:
  • Payment processing: we use a third party payment processing platform, l, to facilitate payment transactions l.

The third party service providers will have access to personal information needed to perform their functions, but are only provided the limited amount of information required to perform their services.  When Bit Labs uses third party service providers, it requires the providers to protect your personal information in accordance with the law and with the same or more stringent security and privacy standards than Bit Labs. Any such disclosure of your personal information by Bit Labs to a third party service provider will be conditional upon the information being used solely for the purpose for which it has been disclosed.

  1. Sale or Transfer of the Business

Bit Labs may decide to sell or transfer all or part of our business to a related company or to a third party, to merge with another entity, to insure or securitize its assets, or to engage in another form of corporate or financing transaction (including transfers made as part of insolvency or bankruptcy proceedings or as part of a corporate reorganization or stock sale or other change in corporate control).  Bit Labs may share your personal information in connection with the evaluation of and/or entry into such transactions.

  1. Where Required or Authorized by Law

Bit Labs may disclose your personal information where authorized or required by law.  For example, we may disclose your personal information to comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information, pursuant to an investigation into the breach of a law, or to our legal counsel.

Transferring Your Personal Information

The third party service providers identified in this Policy are located outside of Canada. These countries have different privacy laws that may or may not be as comprehensive as Canadian law.  Your personal information may be stored, accessed or used in the United States and may be subject to the laws and access by government, courts, law enforcement, or regulatory organizations in those jurisdictions.

By submitting your personal information or engaging with the App, you consent to this transfer, storage, or processing of your personal information outside of Canada.

If you have any questions about Bit Labs’ policies and practices with respect to service providers outside of Canada, including its collection, use, disclosure, and storage of personal information, you can contact the Bit Labs Privacy Officer at the contact information listed in this Policy.

Security And Protection Of Your Personal Information

The security of your personal information is very important to us.  We use security arrangements to protect against unauthorized access, collection, use, disclosure, and disposal, in a manner appropriate to the sensitivity of the information.  As well, Bit Labs will use care when destroying or disposing of personal information to prevent unauthorized access, use or disclosure of any personal information.  Bit Labs’ employees and independent contractors with access to personal information are required to respect the confidentiality of such information.

The safety and security of your personal information also depends on you.  Where we have given you (or you have chosen) a password for access to certain parts of our App, you are responsible for keeping it confidential.  Bit Labs is not responsible for any lost, stolen, or compromised usernames, passwords or for any activity on your Account (which includes your bitcoin wallet) via unauthorized password activity.  You should take steps to protect against authorized access to your Account by, for example, choosing a robust password and keeping your username and password private.

Bit Labs does store a User’s private keys relating to a User’s bitcoin wallet used in the App.  This means that it is very important that you retain a record of your username, email address, password and the wallet recovery backup phrase.  If you lose this information, Bit Labs will not be able to recover your bitcoin wallet for you and you may lose access to your cryptocurrency.  You should store this information in a highly secure place. Any person who gets their hands on it will gain access to your funds.

We urge you to be careful about giving out personal information in public areas of the App like commenting on another User’s posts if that User has a public profile, which any User can view.  We offer all Users the ability to make their Account “private”, which means that only Users who they have accepted as followers can view and comment on their posts, and send them messages.  If your Account is not private, then any User can view and comment on your posts, and send you a message on the App’s message feature.  We also offer all Users the ability to modify message settings (for example, you may limit those who can message you from anyone, to those you follow, or to your subscribers.)

Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure.  Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the App.  Any transmission of personal information is at your own risk.  We are not responsible for circumvention of any App privacy settings or security measures.  Bit Labs is not responsible for any failure by you to secure your own device(s) and its access to the Internet or your use of public, unsecured networks.

The App may include links to external websites.  Once you leave the App this Policy does not apply.  Bit Labs is not responsible for the privacy practices, collection of personal information, or content of external websites.

Retention Of Your Personal Information

Except as otherwise permitted or required by applicable law, 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 or aggregate your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Children Under The Age Of 13

Our App is not intended for children under 13 years of age.  No one under age 13 may provide any information to or on the App.  We do not knowingly collect personal information from children under 13.  If you are under 13, do not use or provide any information on this App or on or through any of its features/register on the App, make any purchases through the App, use any of the interactive or public comment features of this App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any username you may use.  If we learn we have collected or received personal information from a child under 13 without parental consent, we will delete that information.   If you believe we might have any information from or about a child under 13, please contact the Bit Labs Privacy Officer at the contact information listed below (see Questions and Concerns).

Accessing And Correcting Your Personal Information

All personal information in your Account and user profile is accessible by you.  You can make changes to certain personal information that Bit Labs holds about you, such as your contact information, by editing the information in your Account.  You are responsible for keeping the personal information in your Account up to date and accurate.  Certain minimum personal information must be input in your Account in order to use the App’s services.  For example, you must provide us with your e-mail address.

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

You can challenge the accuracy and completeness of your personal information in the possession and control of Bit Labs.  In appropriate circumstances, Bit Labs will amend the information.  It is your responsibility to provide any updates to your personal information to Bit Labs in writing (the contact information for Bit Labs’ Privacy Officer is in the Questions and Concerns section below).

You may request access to your personal information and/or correction of that information by contacting Bit Labs in writing at the contact information noted below, with sufficient detail to enable Bit Labs to identify the personal information being sought.  When you contact Bit Labs, we may ask for further information to confirm your identity and the nature of the information being sought.

After we receive your request for access to personal information, Bit Labs will provide you with an estimate of when you can expect a response.  In some cases, Bit Labs may need additional time to respond to a request, in which case we will provide you with written notice of the extension.  Please note that in some cases, Bit Labs may not provide access to personal information that we hold about you, such as where the denial of access is authorized by law.  There are also cases where Bit Labs may be legally required to refuse access to personal information.  If Bit Labs denies your request for access to personal information, we will advise you of the reason for the refusal, and will provide the name, title, and contact information of the designated person who can address the refusal.

Bit Labs may charge a reasonable fee according to the cost required to retrieve and provide access to the requested information.  We may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee.

Changes To Our Privacy Policy

Bit Labs may update this Policy from time to time by posting a new version of the Policy on the App.  If there are significant changes made to the Policy, we may notify Users in advance through the App or by e-mail.  Bit Labs’ collection, use, disclosure, and retention of your personal information will be governed by the version of the Policy in effect at that time.  We suggest that you review this Policy periodically.

Governing Law

Those who choose to use or access the App and/or the Services from outside Canada do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable.  Notwithstanding the foregoing, and recognizing the global nature of the Internet, each User shall comply with all local rules regarding online conduct and submission of acceptable materials.  This Policy is governed and interpreted pursuant to the laws of the province of British Columbia, Canada and the federal laws of Canada applicable therein, without regard to principles of conflicts of law that would impose the law of another jurisdiction.

Questions And Concerns

Any questions, comments, concerns or requests regarding this Policy, including the collection of your personal information, can be directed to the Bit Labs Privacy Officer, who is responsible for ensuring Bit Labs’ compliance with this Policy.  You can contact the Privacy Officer using any of the following methods:

Bit Labs Inc.

Attn: Privacy Officer


Bit Labs takes any complaint about our privacy practices seriously.  Bit Labs will investigate all complaints.  If Bit Labs finds a complaint justified, we will take the necessary steps to resolve it.  If you are not satisfied with Bit Labs’ response to a complaint, you may have options to exercise various complaint procedures, including with the relevant Privacy Commissioner (if a User based in Canada) or other regulatory authority (if a User based outside of Canada).

Last modified: 05/14/2021