Personal details: given name(s); preferred name; and photograph.
Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
Correspondence: records and copies of your correspondence if you contact us.
Professional details: your CV; records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.
Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
Visitor logs: records of visits to our premises.
Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).
Purchase details: records of purchases and prices; and consignee name, address, contact telephone number and email address.
Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
Data relating to hardware, Sites, and Apps: operational and diagnostic data relating to [COMPANY] hardware; device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data; and other technical communications information (some of which may constitute Personal Information); registration details; username; password; security login details; usage data; and aggregate statistical information.
Employer details: where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.
Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
Cookie data: we collect information via cookies and similar technologies.
Security information: your password(s); login attempt details; security settings; and other security-related information.
Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
Inferences: Inferences drawn from the above, such as product interests and purchasing insights.
Provision of Sites, Apps, products, and services: providing our Sites, Apps, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, products, or services.
Operating our business: operating and managing our Sites, our Apps, our products, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our Apps, our products, or our services; and notifying you of changes to any of our Sites, our Apps, our products, or our services.
Planning: organisational planning; succession planning; making changes to the nature and scope of our operations or our business; mergers, acquisitions, dissolutions demergers, liquidations, asset sales, divestitures, reorganisations and similar corporate structuring arrangements.
Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites, products and services for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable.
Product safety communications: communications in relation to product safety, including product recalls and product safety advisory notices.
Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.
Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.
Financial management: sales; finance; corporate audit; and vendor management.
Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, our products, or our services.
Security: physical security of our premises (including records of visits to our premises) and electronic security (including login records and access details).
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
Legal compliance: compliance with our legal and regulatory obligations under applicable law.
Improving our Sites, Apps, products, and services: identifying issues with our Sites, our Apps, our products, or our services; planning improvements to our Sites, our Apps, our products, or our services; and creating new Sites, Apps, products, or services.
Fraud prevention: Detecting, preventing and investigating fraud.
Establishment, exercise and defence of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings.
Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.
You and, where appropriate, your appointed representatives.
Third party distributors through whom you acquire any of our products or services.
Accountants, auditors, consultants, lawyers and other outside professional advisors to [COMPANY], subject to binding contractual obligations of confidentiality.
Third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted in Section 6.
Any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims.
Any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties.
Any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and any relevant third party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Information may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.
Third parties with whom you consent to sharing your information, such as with social media services or academic researchers.
Government entities or other third parties for legal reasons, such as to comply with law or for other legal reasons.
Black Marlin Group and its partners use these technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.
We partner with a third party to either display advertising on our web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Like many other companies which offer online services to their clients/customers, our web site also includes Social Media Features, such as the Facebook Like button and Widgets, as along with the sharing buttons or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.
You also have other choices to adjust your preferences for interest-based advertising, and/or to opt-out of use of your Personal Information by third parties for such advertising, including:
As noted above, if you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt-out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
INFORMATION FOR CALIFORNIA RESIDENTS
Under the California Consumer Privacy Act (the “CCPA”), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents. California Residents are also afforded certain rights with regard to the Personal Information we collect about them that include the rights of access, deletion, correction, and to be free from discrimination. This section includes the disclosures required by the CCPA, and describes the rights afforded to California Residents. We also describe the methods by which a California Resident may exercise these rights and some of the statutory exceptions that may apply.
The disclosures required by the CCPA are as follows:
If you are a California Resident, the CCPA grants you the following rights regarding your Personal Information:
To exercise your rights under the CCPA, please submit your request through email at: admin@blackmarlindev.com. Generally, in order to verify your requests to exercise your rights, we will compare the Personal Information we have about you to pieces of Personal Information we will request in the course of processing your request. The Personal Information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable California Resident request.
Notice of Financial Incentives: We may offer various financial incentives. For example, we may provide incentives to customers who participate in a survey or provide testimonials. When you participate in a financial incentive, we collect Personal Information from you, such as identifiers (like your name and email address) and information about your experiences using our products or services. You can opt into a financial incentive by following the sign-up or participation instructions provided, and, for any ongoing benefits, you can opt-out at any time, such as by following the unsubscribe instructions in the applicable program’s terms or by contacting us. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your Personal Information is reasonably related to the value of the offer or discount presented to you.
California’s “Shine the Light” Law: Under California’s “Shine the Light” law, California Residents are entitled to ask us for a notice describing what categories of Personal Information Black Marlin Group shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. However, we do not “share” your Personal Information as we understand that term to be defined by “Shine the Light” law, so there is no need to exercise these rights.
Metrics On Your Rights: The CCPA requires us to track and publish the below metrics for the previous calendar year. The below metrics are our calculations from [X] to [X], and include requests from all individuals in the U.S.
Right to Know
Received: [X]
Complied with: [X]
Denied: [X]
Average response time: [X] days
Right to Delete
Received: [X]
Complied with: [X]
Denied: [X]
Average response time: [X] days
Right to Opt-out of Sale
We don’t sell or share your Personal Information as those terms are used in the CCPA.
Under the Virginia Consumer Data Protection Act (“VCDPA”), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of Virginia Residents (“Virginia Consumers”). Virginia Consumers are also afforded additional rights with regard to the personal data we collect about them that include the rights of access, deletion, and correction. This section of our Privacy Policy directs you to the disclosures required by the VCDPA and describes the rights afforded to Virginia Consumers. We also describe the methods by which a Virginia Consumer may exercise these rights.
Required VCDPA Disclosures
Consumer Requests: Under the VCPDA, we are a controller of your personal data. If you are a Virginia Consumer, the VCDPA grants you the following rights regarding your personal data. If we are unable to authenticate your request to exercise one or more of these rights using commercially reasonable efforts, we may request that you provide additional information, such as name, email address, phone number, or postal address, to authenticate your request. We will deliver a response to you within 45 days of receiving your verifiable consumer request.
Process to Appeal Declined Requests: If we decline to take action on your request, we will notify you within 45 days of receipt of your request. In the event we decline to take action on your request, you may submit an appeal within 30 days of receiving such notice. You may submit an appeal through email at: admin@blackmarlindev.com. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason(s) for the decision(s). If your appeal is denied, we will provide you with an online mechanism, if available, or other method through which you may contact the Virginia Attorney General to submit a complaint.
To exercise your rights under the VCDPA, please follow the instructions described in this section:
Right to Access Personal Data: Virginia Consumers have the right to confirm whether or not we are processing their personal data and to access such personal data. Verifiable consumer requests to confirm and access may be submitted through email at: admin@blackmarlindev.com.
Right to Correct Personal Data: Virginia Consumers have the right to correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data. Verifiable consumer requests to correct may be submitted through email at: admin@blackmarlindev.com.
Right to Delete Personal Data: Virginia Consumers have the right to delete personal data provided by or obtained about the consumer. Verifiable consumer requests to delete may be submitted through email at: admin@blackmarlindev.com.
Right to Data Portability: Virginia Consumers have the right to obtain a copy of their personal data that the consumer previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means. Verifiable consumer requests for data portability may be submitted through email at: admin@blackmarlindev.com.
Right to Opt-Out: Virginia Consumers have the right to opt out of the processing of personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in connection with automated decisions that produce legal or similarly significant effects concerning the consumer. Verifiable consumer opt-out requests may be submitted through email at: admin@blackmarlindev.com.
Under the Colorado Privacy Act (“CPA”), we, the data controller, must disclose our practices regarding the collection, use, and disclosure of the Personal Information of Colorado Residents (“Colorado Consumers”). Colorado Consumers are also afforded additional rights with regard to the personal data we collect about them that include the rights of access, deletion, and correction. This section of our Privacy Policy directs you to the disclosures required by the CPA and describes the rights afforded to Colorado Consumers. We also describe the methods by which a Colorado Consumer may exercise these rights.
Required CPA Disclosures
Consumer Requests: Under the CPA, we are a controller of your personal data. If you are a Colorado Consumer, the CPA grants you the following rights regarding your personal data. If we are unable to authenticate your request to exercise one or more of these rights using commercially reasonable efforts, we may request that you provide additional information, such as name, email address, phone number, or postal address, to authenticate your request. We will deliver a response to you within 45 days of receiving your verifiable consumer request.
Process to Appeal Declined Requests: If we decline to take action on your request, we will notify you within 45 days of receipt of your request. In the event we decline to take action on your request, you may submit an appeal within 30 days of receiving such notice. You may submit an appeal through email at: admin@blackmarlindev.com. Within 45 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reason(s) for the decision(s). If your appeal is denied, we will provide you with an online mechanism, if available, or other method through which you may contact the Colorado Attorney General to submit a complaint.
To exercise your rights under the CPA, please follow the instructions described in this section:
Right to Access Personal Data: Colorado Consumers have the right to confirm whether or not we are processing their personal data and to access such personal data. Verifiable consumer requests to confirm and access may be submitted through email at: admin@blackmarlindev.com.
Right to Correct Personal Data: Colorado Consumers have the right to correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data. Verifiable consumer requests to correct may be submitted through email at: admin@blackmarlindev.com.
Right to Delete Personal Data: Colorado Consumers have the right to delete personal data provided by or obtained about the consumer. Verifiable consumer requests to delete may be submitted through email at: admin@blackmarlindev.com.
Right to Data Portability: Colorado Consumers have the right to obtain a copy of their personal data that the consumer previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means. Verifiable consumer requests for data portability may be submitted through email at: admin@blackmarlindev.com.
Right to Opt-Out: Colorado Consumers have the right to opt out of the processing of personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in connection with automated decisions that produce legal or similarly significant effects concerning the consumer. Verifiable consumer opt-out requests may be submitted through email at: admin@blackmarlindev.com.
Authorized Agent. Under the CPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.
Under the Connecticut Data Privacy Act (“CTDPA”), we, the data controller, must disclose our practices regarding the collection, use, and disclosure of the Personal Information of Connecticut Residents (“Connecticut Consumers”). Connecticut Consumers are also afforded additional rights with regard to the personal data we collect about them that include the rights of access, deletion, and correction. This section of our Privacy Policy directs you to the disclosures required by the CTDPA and describes the rights afforded to Connecticut Consumers. We also describe the methods by which a Connecticut Consumer may exercise these rights.
Required CTDPA Disclosures
Consumer Requests: Under the CTDPA, we are a controller of your personal data. If you are a Connecticut Consumer, the CTDPA grants you the following rights regarding your personal data. If we are unable to authenticate your request to exercise one or more of these rights using commercially reasonable efforts, we may request that you provide additional information, such as name, email address, phone number, or postal address, to authenticate your request. We will deliver a response to you within 45 days of receiving your verifiable request.
Process to Appeal Declined Requests: If we decline to take action on your request, we will notify you within 45 days of receipt of your request. In the event we decline to take action on your request, you may submit an appeal within 30 days of receiving such notice. You may submit an appeal through email at: admin@blackmarlindev.com. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, we will provide you with an online mechanism, if available, or other method through which you may contact the Connecticut Attorney General to submit a complaint.
To exercise your rights under the CTDPA, please follow the instructions described in this section:
Right to Access Personal Data: Connecticut Consumers have the right to confirm whether or not we are processing their personal data and to access such personal data. Verifiable consumer requests to confirm and access may be submitted through email at: admin@blackmarlindev.com.
Right to Correct Personal Data: Connecticut Consumers have the right to correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data. Verifiable consumer requests to correct may be submitted through email at: admin@blackmarlindev.com.
Right to Delete Personal Data: Connecticut Consumers have the right to delete personal data provided by or obtained about the consumer. Verifiable consumer requests to delete may be submitted through email at: admin@blackmarlindev.com.
Right to Data Portability: Connecticut Consumers have the right to obtain a copy of their personal data that the consumer previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means. Verifiable consumer requests for data portability may be submitted through email at: admin@blackmarlindev.com.
Right to Opt-Out: Connecticut Consumers have the right to opt out of the processing of personal data for purposes of (i) targeted advertising, (ii) the sale of personal data or (iii) profiling in connection with automated decisions that produce legal or similarly significant effects concerning the consumer. Verifiable consumer opt-out requests may be submitted through email at: admin@blackmarlindev.com.
Authorized Agent. Under the CTDPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.
Under the Utah Consumer Privacy Act (“UCPA”), we, the data controller, must disclose our practices regarding the collection, use, and disclosure of the Personal Information of Utah Residents (“Utah Consumers”). Utah Consumers are also afforded additional rights with regard to the personal data we collect about them that include the rights of access, deletion, and correction. This section of our Privacy Policy directs you to the disclosures required by the UCPA and describes the rights afforded to Utah Consumers. We also describe the methods by which a Utah Consumer may exercise these rights.
Required UCPA Disclosures
Consumer Requests: Under the UCPA, we are a controller of your personal data. If you are a Utah Consumer, the UCPA grants you the following rights regarding your personal data. If we are unable to authenticate your request to exercise one or more of these rights using commercially reasonable efforts, we may request that you provide additional information, such as name, email address, phone number, or postal address, to authenticate your request. We will deliver a response to you within 45 days of receiving your verifiable request.
To exercise your rights under the UCPA, please follow the instructions described in this section:
Right to Access Personal Data: Utah Consumers have the right to confirm whether or not we are processing their personal data and to access such personal data. Verifiable consumer requests to confirm and access may be submitted through email at: admin@blackmarlindev.com.
Right to Correct Personal Data: Utah Consumers have the right to correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data. Verifiable consumer requests to correct may be submitted through email at: admin@blackmarlindev.com.
Right to Delete Personal Data: Utah Consumers have the right to delete personal data provided by or obtained about the consumer. Verifiable consumer requests to delete may be submitted through email at: admin@blackmarlindev.com.
Right to Data Portability: Utah Consumers have the right to obtain a copy of their personal data that the consumer previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means. Verifiable consumer requests for data portability may be submitted through email at: admin@blackmarlindev.com.
Right to Opt-Out: Utah Consumers have the right to opt out of the processing of personal data for purposes of (i) targeted advertising, (ii) the sale of personal data or (iii) profiling in connection with automated decisions that produce legal or similarly significant effects concerning the consumer. Verifiable consumer opt-out requests may be submitted through email at: admin@blackmarlindev.com.
Authorized Agent. Under the UCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.
We do not currently conduct sales of personal information as defined by applicable law in Nevada.
“CCPA” means the California Consumer Privacy Act, as amended by the California Privacy Rights Act.
“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy Policy, a reference to a “cookie” includes analogous technologies such as pixels, web beacons, and clear GIFs. For more information on cookies and similar tools, see Section 12 above.
“Personal Information” means 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.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Profiling” means any form of automated Processing of Personal Information consisting of the use of Personal Information to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
“Sensitive Personal Information” is a specific subset of Personal Information that includes certain government identifiers (such as social security numbers); an account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of mail, email, and text messages; genetic data; biometric information Processed to identify a consumer; information concerning a consumer’s health, sex life, or sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership.
“Site” means any website operated, or maintained, by us or on our behalf, including but not limited to the site available at URL https://blackmarlingroup.us/.
Effective: February 26, 2024
