Privacy Policy

Last updated: October 17, 2026

DRAFT — not published. Operational and legal review is still in progress.

This Privacy Policy explains how CodeblueS handles personal information when you browse codetheblues.com, create an account, buy our products, or contact us about an order or technical support (together, the “Store”). It covers our retail activities involving home miners, Bitcoin hardware and accessories.

1. Who is responsible for your information?

The Store is operated by CODEBLUES LIMITED, a company registered in Hong Kong and trading as CodeblueS (“we”, “us”, “our”). We are the controller of personal information used for the purposes described in this policy.

• Place of registration: Hong Kong
• Administrative address: Unit 1021, Beverley Commercial Centre, 87–105 Chatham Road South, Tsim Sha Tsui, Hong Kong
• Privacy contact: ctpresource@codetheblues.com

Returns and after-sales shipping: The address above is our administrative address only. It is not a returns, repairs or after-sales shipping address. Please refer to our Return & Refund Policy for the applicable return or after-sales shipping address and instructions.

Our Store runs on SHOPLINE. Providing the Store through SHOPLINE does not transfer our responsibility for explaining our own use of your information.

2. Information we collect and where it comes from

The information involved depends on how you interact with the Store:

• Contact and account information: your name, email address, telephone number, billing and delivery addresses, account identifier and account preferences, when you provide them.
• Purchase and transaction information: products ordered, order history, amounts, currency, payment status and transaction references, delivery updates, refunds, returns and related communications. We receive these details from you and from the service providers involved in your transaction.
• Website and device information: IP address, browser and device type, operating system, referring pages, pages viewed, timestamps, cookie identifiers and interactions with the Store. These may be recorded by our storefront and security services. Approximate location may be inferred from an IP address; optional measurement and advertising depend on the tools and choices described below.
• Support information: messages, order numbers, product serial numbers, photographs, videos, firmware versions and diagnostic files that you choose to send us. Logs or screenshots may contain device identifiers, network details, mining-pool settings or public wallet addresses.
• Preferences and privacy requests: marketing subscriptions, consent and opt-out records, and information needed to handle and document a privacy request.

You can browse without placing an order. Information required for payment, delivery or an account is identified when requested. Without information needed to fulfil a transaction, we may be unable to complete it.

3. Why we use information

Where the EU or UK GDPR applies, we use the following purposes and legal bases:

• Contract: take steps you request before a purchase; process an order or refund; arrange delivery; administer an account you request; and provide support connected with your purchase.
• Legal obligation: maintain required tax and accounting records, comply with applicable consumer and customs requirements, and respond to binding legal demands.
• Legitimate interests: protect the Store, investigate fraud, manage business records and claims, and resolve general enquiries. These interests are subject to an assessment of their necessity and their effect on your rights.
• Consent: optional tracking and promotional communications where consent is required. You may withdraw consent without affecting processing that was lawful before withdrawal.

We do not treat simply visiting the Store or accepting this policy as consent to optional tracking or advertising.

4. Who receives information

We disclose relevant information to the organisations needed for the purposes above:

• SHOPLINE and storefront infrastructure providers for hosting, checkout, order administration, security and related store functionality.
• Payment providers, banks and fraud-prevention services for payment authorisation, transaction checks, refunds and disputes.
• Carriers, fulfilment providers and customs intermediaries for packing, shipping, tracking and import or export formalities.
• Customer-service, communications and technical-support providers when they help us answer enquiries or resolve product issues.
• Professional advisers, authorities or a business successor where necessary for legal obligations, protecting rights or a business transaction, subject to applicable safeguards.
• Consentik GDPR Cookie Banner (Omega) to present cookie choices and manage consent preferences for the Store.
• Analytics and advertising providers when the planned services described in Section 6 are activated, subject to applicable privacy choices.

Providers acting on our instructions process information for the services they provide. Some recipients, including certain payment providers, process information for their own legal or operational purposes. Their privacy notices explain those activities. See SHOPLINE’s privacy information.

5. Payments and transaction screening

PayPal is currently available. When you select PayPal at checkout, PayPal processes the payment and relevant payment credentials. We and PayPal exchange information needed to complete your purchase, confirm payment, fulfil the order, and handle refunds or disputes. This can include your name, email address, delivery details, order information, transaction reference, amount, currency and payment status.

PayPal also processes personal information for its own payment-service, security and legal-compliance purposes as a separate controller. Its processing and the rights available to you are described in the PayPal Privacy Statement.

SHOPLINE Payments is planned for future activation. Once activated and offered at checkout, it and the relevant financial partners will process information needed for the payment method you select, including payment credentials, billing information, transaction details and verification results. We will update this policy as necessary when that integration becomes available. See SHOPLINE’s privacy information.

The payment options displayed at checkout determine which services are available for your purchase.

We do not use an automatic order-rejection function in our Store. Payment providers and banks may carry out their own payment-authorisation and security checks, which can result in a payment being declined or additional verification being requested. These are separate from our order-handling process. Contact us if you need help with an order or believe a transaction has been incorrectly flagged.

6. Cookies, analytics and marketing

The Store uses cookies or similar technologies to support functions such as the shopping basket, sign-in, checkout, security and remembering privacy choices.

Consentik GDPR Cookie Banner is currently used on our Store. We use this consent-management tool, provided by Omega, to present cookie choices and manage visitors’ consent preferences. Consent choices and information needed to remember those choices are used to administer your preferences.

Your cookie choices: Use the Store’s cookie banner and preference controls to review the available categories and accept or reject optional cookies. Where consent is required, optional analytics and advertising technologies require your consent before use. To change or withdraw your choices, reopen the cookie preference controls. If you cannot find or access them, contact ctpresource@codetheblues.com for assistance.

Essential cookies support the services you request and are handled separately from optional analytics and advertising choices. Your browser can also block or remove cookies, although this may affect checkout or account features. Simply browsing the Store does not constitute consent to optional tracking.

Planned services: Google Analytics, Google Ads and Meta Pixel are planned for activation in the near future and are not currently enabled by us. The following descriptions explain their intended uses:

• Google Analytics: to understand how visitors find and use the Store, such as pages viewed and shopping activity, and to improve the shopping experience.
• Google Ads: to measure advertising performance and purchase conversions and, where remarketing or personalisation features are enabled and permitted, to present relevant advertising.
• Meta Pixel: to measure interactions with our Store and the effectiveness of advertising on Meta services and, where enabled and permitted, to support advertising audiences and personalisation.

When an integration is activated, the relevant provider may receive information such as page URLs, browser or device details, IP addresses, cookie or advertising identifiers, and shopping events such as product views, basket activity or purchases. The actual information and uses will depend on the features enabled and your privacy choices. Providers may associate events with other information they hold, as explained in their privacy notices.

Before activating these integrations, we will update the relevant privacy and cookie information to reflect the actual services and features used and provide the notices and choices required by applicable law. Future activation is not authorised merely by your reading this policy.

Read how Google uses information from partner sites and Meta’s Privacy Policy for further information. Google also offers advertising settings and a Google Analytics browser opt-out add-on. Provider settings are additional choices and do not replace the Store’s own consent or statutory opt-out controls.

You can stop promotional emails using their unsubscribe link or by contacting us. Order confirmations, delivery updates and other messages necessary to service your purchase are separate from promotional emails.

7. Mining hardware, USMO OS and support files

USMO OS and our mining hardware do not automatically send device logs, hashrate, IP addresses, mining-pool settings or wallet addresses to CODEBLUES LIMITED. Information displayed in the device’s local interface is not automatically uploaded to us.

For after-sales or technical support, we receive only the device information you choose to provide, such as diagnostic logs, screenshots, photographs, serial numbers or firmware details. We use that material to investigate the reported problem, provide support and keep relevant case records as described in this policy.

This statement concerns information sent by the hardware or USMO OS to us. It does not mean that browsing our Store is anonymous, or that a mining pool or other third-party service you configure receives no data.

Please remove unrelated personal information from support files. Do not send wallet seed phrases, private keys, Wi-Fi passwords or account passwords. A public wallet address may identify a person when linked with other records.

Mining pools and other third-party services you choose have their own privacy practices. If we introduce device telemetry or separate CodeblueS cloud, node or pool services, we will provide the relevant privacy information and any choices required before that processing begins.

8. How long we keep information and how we protect it

Retention is based on the purpose of each record, applicable legal requirements and whether an unresolved dispute or security incident requires preservation:

• Account records: while needed to provide the account, with limited information retained after closure where required for legal, security or transaction purposes.
• Orders, payments and delivery records: through fulfilment and any relevant return, dispute, accounting, tax or statutory recordkeeping period.
• Support files: for resolving the case and any related product or legal claim; unnecessary diagnostic material should be removed sooner.
• Technical and cookie data: for the duration needed for the relevant security or operational purpose or to administer the applicable consent preference.
• Consent and suppression records: as needed to document and respect your choices, including keeping limited details to avoid sending unwanted marketing.

When a retention purpose ends, information is deleted or anonymised, subject to necessary backup retention. We use safeguards appropriate to the information and risks involved; no transmission or storage system can be guaranteed completely secure.

9. International processing

Our employees process orders and provide after-sales support from mainland China and Hong Kong. In carrying out those activities, they access and use relevant customer contact details, order and delivery information, and support materials that you provide.

If you are located outside those regions, this processing involves access to your personal information from outside the country where you live. SHOPLINE, payment providers and other service providers may also process relevant information in the jurisdictions in which they and their service providers operate. The location of our employees does not mean that all Store data is stored exclusively in mainland China or Hong Kong.

Where applicable law restricts an international transfer, the transfer must meet the relevant legal requirements. You may contact us at ctpresource@codetheblues.com to ask about the processing locations and safeguards relevant to your information and to request available information about those safeguards. Using the Store does not, on its own, provide consent to an international transfer.

10. Rights in the EEA and United Kingdom

Where the applicable data-protection law gives you these rights, you may request access, correction, erasure, restriction or a portable copy of your personal information. You may object to processing based on legitimate interests and object at any time to direct marketing. You may withdraw consent where processing relies on it.

You may also have rights concerning solely automated decisions with legal or similarly significant effects, including requesting human involvement and contesting a decision.

These rights are subject to applicable conditions and exceptions. For example, deleting an account does not necessarily require deletion of tax records that must be retained.

You can complain to your local data-protection authority without first contacting us. EEA residents can find their authority through the European Data Protection Board; UK residents can contact the Information Commissioner’s Office.

11. Additional information for United States residents

State privacy laws apply according to their own scope and exemptions. Where a law applies to our processing and grants you the right, you may request access, correction, deletion or a portable copy, and opt out of sale, targeted advertising or specified profiling. California residents may also have a right to limit certain uses or disclosures of sensitive personal information. We will not unlawfully discriminate against you for exercising a protected right.

Sections 2–4 describe the types of information involved in our Store, their sources, the purposes for which they are used and the types of recipients. You can contact us using Section 12 to request information about the processing relevant to you or to exercise an applicable privacy right.

The Google Analytics, Google Ads and Meta Pixel integrations described in Section 6 are planned for future activation. When advertising integrations are enabled, disclosures of identifiers, browsing activity or purchase events to advertising partners can qualify as a “sale”, “sharing” or processing for targeted advertising under applicable US state law, even where no money is exchanged. Before activation, we will review the actual configuration and update the disclosures and privacy choices required for those activities.

Where state law provides an appeal, you may appeal a refusal using our privacy contact and the subject “Privacy Appeal”. We will explain the outcome and any further complaint route required by that law.

12. How to make a privacy request

Contact ctpresource@codetheblues.com or send privacy-related correspondence to the administrative address in Section 1. Describe the request and provide enough information for us to locate the relevant records.

For access, correction or deletion, we may request proportionate information to verify identity or an agent’s authority. Sale or sharing opt-outs must not be subject to unnecessary identity verification or an account-creation requirement. An authorised agent may submit a request where the law permits.

We respond within the time required by the applicable law—generally one month for GDPR requests and 45 days for many US state requests, with permitted extensions explained when applicable. Shorter deadlines can apply to opt-outs. If we cannot fulfil a request, we will explain the reason and available next steps.

13. Minors and external websites

The Store is intended for adult purchasers and is not directed to minors. If you believe a minor has provided us with personal information, contact ctpresource@codetheblues.com so that we can investigate and take action required by applicable law.

Links to external websites do not mean that this policy covers those websites. Review the notices of the services you choose to use.

14. Changes to this policy

We update this policy when our practices or relevant requirements change and revise the date above. Where required, we provide an additional notice or obtain new consent before a change takes effect. Contact our privacy contact with questions about this policy.