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Privacy Policy

We respect the importance of your personal data. This privacy policy (Privacy Policy) applies to your personal data that we collect through or in connection with the operation of our Website at blackswan.com and the Services. We want you to understand our Privacy Policy and, specifically, what information we gather in connection with the website and services, how that information is used, with whom we share that information and what we do to protect it. We’re accountable for the protection of your Personal Data under our control and are committed to following this Privacy Policy and complying with the law. This Privacy Policy is not a contract between us and you.

In this Privacy Policy, we, us or our means Black Swan Data Ltd, an English company based in London, England and our affiliates, and you or your means a person who accesses or uses www.blackswan.com and any affiliated websites (the Website).

What Categories Of Information Do We Collect?

We collect information in order to operate the Website. Examples of the types of information we collect include:

  • Personal Data. Personal Data is any information that is related to an identified or identifiable natural person, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, telephone number, driver's license number, passport number, or other similar identifiers. We use the broadest definition under applicable law.
  • Sensitive Personal Data. Sensitive Personal Data is Personal Data that reveals genetic, biometric, and health data, as well as revealing racial and ethnic origin, political opinions, religious or ideological convictions, or trade union membership.
  • Contact Information. Contact Information is your name, email address, telephone number, and other contact information that you provide us with.
  • Payment Information. Payment Information is any credit card, debit card, or related banking information you provide us with to pay for the Services. Most people will not be providing us with payment information.
  • Network and Device Information. We collect information about your device and information that is necessary to provide you with the Website and the Services, such as a session ID token, source and destination addressing information, IP address, MAC address, the software you are using, and related device and network information.
  • Feedback Information. You may volunteer, or we may ask for, information on your experience using the Website or the Services. At no time are you obliged to provide such information. Feedback Information includes comments, complaints, requests, suggestions, or feedback sent by you to us regarding the Website or the Services.
  • User Data. User Data is all information and data that is not Personal Data that you access, send, receive, or generate when using the Services.
  • Location Data. We may collect data regarding your location while you are using the Website and/or the Services (more specifically, the location of the device that is accessing the Website and/or Service).

Persons under 18 Years of Age.

The Website is not directed towards persons under 18 years of age and we do not intentionally or knowingly collect Personal Data from persons under 18 years of age.

How Do We Collect Information?

We may collect information about you in a number of different ways, including:

  • when you visit the Website
  • what you provide to us when signing up to obtain information, or to participate in seminars, promotional events, or similar events
  • from communications between you and us
  • from public sources
  • automatically in connection with your use of your device and the Website
  • from our service providers

Collection of certain information is essential to the operation of the Website, to respond to you, or troubleshoot issues. Except where we are not required to do so under applicable law, we will obtain your consent before we collect other Personal Data.

How Do We Use This Information?

We may use the following information as described below:

  • Your Personal Data. We do not sell your Personal Data to third parties. Your Personal Data is only used and disclosed in connection with the operation of the Website, including, as applicable, to send you information that you request, register you for events you sign up for, process payments, verify your identity, answer questions about our business, the Website, our services, troubleshoot problems, customize, measure, and improve the Website, inform you about updates, seek feedback, compare information for accuracy, and enforce the terms of use.

    When you provide us with your Personal Data, you give us your informed consent to collect, use, and disclose your Personal Data in accordance with this Privacy Policy. Except where we are not required to do so under applicable law, we will notify you and obtain your consent before we disclose or use your Personal Data in any other way.

  • User Data. User Data that is associated with your Personal Data is only used and disclosed in connection with the operation of the Website, including to troubleshoot problems, customize, seek feedback, data analysis, and research to measure and improve the Website, user communications, and enforce the terms of use. User Data associated with your Personal Data will not otherwise be shared with third parties. User Data that is not associated with your Personal Data is treated as De-Personalized Information, see below.
  • Contact Information. Contact Information is used to verify, process, and charge for things, to contact you regarding events you have signed up for, to send you information that you request, to register you for events you sign up for, and to communicate with you regarding these.. Contact Information will shared with our service providers only to the extent they need this information to perform their services for us.
  • Payment Information. Payment Information is used to verify, process and charge for things you purchase from us. Payment Information will be shared with our service providers only to the extent they need this information to perform their services for us.
  • Network and Device Information. Network and Device Information is used and disclosed in connection with the operation of the Website, including to troubleshoot problems, customize, and data analysis, and research to measure and improve the Website and the Services, and enforce the terms of us.
  • Feedback Information. We can use Feedback Information in any manner and for any purpose without any obligation to account for such use or to compensate you for it. We reserve the right to utilize Feedback Information, on an anonymous basis, for marketing purposes, for instance by displaying selected comments on the Website, in marketing materials, or in other communications. We will not disclose any Personal Data in Feedback Information to third parties (other than to third parties who are involved in providing services where such feedback relates to those providers) without your consent.
  • Passive Information. Passive Information is information that is automatically generated in connection with your use of the Website. We only use Passive Information, on an aggregated basis, to provide you with better service or for statistical information.
  • Location Data. We use location data to troubleshoot problems, customize, seek feedback, data analysis, and research to measure and improve the Services, for communications, and to enforce the terms of use.
  • De-Personalized Information. We collect information of any type, anonymize that information, and use it alone or with similar anonymized information obtained from other users (“De-Personalized Information”). No Personal Data will be included in any De-Personalized Information. We can disclose De-Personalized Information to any third party and use it for any purpose we deem appropriate in our sole discretion.
  • Other Parties’ Ability to Collect Personal Data. We do not authorize any third parties to collect Personal Data about a user’s activities over time and across different sites when a user visits the Website.

You agree that we can, subject to applicable law, use your Personal Data to operate the Website (including sharing your Personal Data with our service providers and/or agents; conduct analysis and research; prevent fraud or misuse; protect our rights or property or the safety of you or others; and send you communications regarding events you have signed up for, information you have requested, or other requests you have made, or for reasonably relevant things we beleive you might find to be of interest (see Marketing below). We may also disclose Personal Data if we believe in good faith that we are required to do so by law, or that doing so is necessary to comply with legal process, respond to requests from law enforcement or governmental agencies, to respond to claims, or to protect our rights.

Your Personal Data is stored and processed in the countries in which we or our affiliates or service providers maintain facilities. We reserve the right to transfer and store your Personal Data outside the country in which you reside.

As we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions, as well as in the event we or substantially all of our assets are acquired by a third party, your Personal Data and other information will generally be one of the transferred business assets. We reserve the right to include your Personal Data and other information, collected as assets, in any such transfer to a third party. Additionally, your Personal Data and other information could be disclosed as part of a bankruptcy involving us.

Marketing

If you opted-in to receive marketing communications from us, from time to time we may send you information about Black Swan news, events, reports and services of ours that we think you might find to be of interest. You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click the unsubscribe link in the marketing email we sent you or send a request to DPO@blackswan.com asking to be unsubscribed.

What are Your Data Protection Rights?

We want to make sure you are fully aware of your data protection rights. Every person visiting our Website is entitled to the following:

  • The right to access - You have the right to request copies of your Personal Data that we have. We may charge you a small fee for this service.
  • The right to rectification - You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
  • The right to erasure - You have the right to request that we erase your Personal Data under certain conditions.
  • The right to restrict processing - You have the right to request that we restrict the processing of your Personal Data under certain conditions.
  • The right to object to processing - You have the right to object to our processing of your Personal Data under certain conditions. However, if you are a User, the Services cannot operate without processing certain Personal Data and objecting to this may result in the termination of your Account or inability to access and use the Services.
  • The right to data portability - You have the right to request that we transfer the Personal Data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at DPO@blackswan.com or by mail at Black Swan Data Ltd, Attn: Data Protection Officer, 15th Floor, WeWork Building, 10 York Rd, London, SE1 7ND England.

What Categories of Third Parties Do We Share Your Personal Data?

The categories of third parties with whom we may share your Personal Data, depending on the situation, are our service providers to the extent such disclosure is necessary to operate the Website or to communicate with you regarding events you have signed up for, information you have requested, or other requests you have made.

Consent for Electronic Communications.

We use Contact Information to communicate with you regarding events you have signed up for or information you have requested. By providing Contact Information, you consent to receive such communications at such e-mail address and/or telephone number.

What Are Cookies and How Do We Use Them?

Cookies are pieces of information that are transferred to your computer or mobile device through a browser. For further information, visit www.allaboutcookies.org. We use Cookies to collect and store certain information. We may use both session cookies (which expire when you close your web browser) and persistent cookies (which stay on your device until you delete them).

We use cookies so that we can identify the device being used and to reestablish service (auto-log-in). Cookies also enable us to gain information about your use of the Services and to enhance it to meet your preferences. These cookies persist until you delete them. We do not use web beacons. The Help option on the toolbar of most browsers will tell you how to prevent or limit the browser from accepting cookies, how to have the browser notify you when you receive a cookie, or how to disable cookies altogether.

It is possible that you may be able to access third party websites, online services, or applications using the Website. The use of cookies, web beacons, or similar technologies on such other websites, online services, or applications is subject to any applicable privacy policies that they may have, not this Privacy Policy.

How We Treat “Do Not Track” Or Similar Signals.

Some browsers provide you with “do not track” options. Because there is not yet a common understanding of how to interpret the “do not track” signal, we do not currently respond to the browser “do not track” signals when you use the Services or interact with the Website.

How Your Personal Data Is Protected.

We take physical, organizational, and technical measures to protect the Personal Data you provide to us. We cannot guarantee the absolute security of our database, nor can we guarantee that any information supplied will not be intercepted while being transmitted over wireless networks or the Internet.

How Long Is Personal Data Kept?

We will retain your Personal Data only for as long as is necessary to operate the Website; maintain records until they cannot be lawfully challenged and legal proceedings may no longer be pursued; carry out marketing activities; comply with applicable law, regulatory requests, and relevant orders from government authorities; and enforce or fulfill any of the other purposes detailed in, the terms of use.

For California Residents: Your California Privacy Rights.

California Civil Code Section 1798 entitles California customers to request information concerning whether a business has disclosed Personal Data to any third parties for the third parties’ direct marketing purposes. As stated in this Privacy Policy, we will not sell or share your Personal Data with non-affiliated companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How Can We Be Contacted” section below.

Can This Privacy Policy Be Modified?

We reserve the right to modify this Privacy Policy at any time. Use of the Website after we have published a modified Privacy Policy constitutes acceptance of such modified Privacy Policy.

How We Notify You of Modifications.

We will publish the modified Privacy Policy on the Website. The modified Privacy Policy becomes effective upon publishing. If the modifications are material, we will provide more prominent notice as appropriate under the circumstances (for example, for a period of time following publication the icon or link to the Privacy Policy may be highlighted or include the word such as “modified,” “revised,” “updated” or similar).

How Can We Be Contacted?

You can contact us by email at DPO@blackswan.com or by snail mail at: Black Swan Data Ltd, Attn: Data Protection Officer, 15th Floor, WeWork Building, 10 York Rd, London, SE1 7ND England.

How To Contact The Appropriate Authority?

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner's Office at https://ico.org.uk/global/contact-us/

Last revised: April 16, 2020 © 2020 Black Swan Data Ltd. All rights reserved.

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