Important Information

Who we are

BLACKSWAN HOLDINGS LIMITED (ADGM company number 17983) is the data controller for personal data processed through this Site. Where data is processed in the context of the Polish affiliate, Blackswan Poland Management sp. z o.o. (KRS 0001212638) acts as joint controller.

Data Protection Contact Person: Malek Jamal Mahmoud Hammad. All privacy enquiries and data-subject requests should be sent to office@blacksn.com with the subject line “Privacy request”.

Note: at the time of incorporation in March 2024, Maciej Knapik was registered with the ADGM Registration Authority as the Data Protection Contact Person. The Company is updating this designation to Malek Jamal Mahmoud Hammad and will file the corresponding update with the Registrar.

Categories of data we collect

• Identification and contact data (name, email, employer, role, country).
• Investor classification data (declared status, jurisdiction).
• Technical data (IP address, browser, device, log data, cookies).
• Communication data (correspondence with info@blacksn.com or office@blacksn.com, meeting notes, recordings where consented).
• Where required for AML / KYC of counterparties: identity documents, source of wealth, beneficial ownership.

As notified to the ADGM Registration Authority on incorporation, the Company does not currently process Sensitive Personal Data and does not currently transfer personal data outside the ADGM. If either position changes we will update this notice and notify the Registrar.

Purposes and legal bases

• Responding to enquiries — Article 6(1)(b) GDPR (steps prior to a contract) or Article 6(1)(f) (legitimate interest).
• Investor verification — Article 6(1)(c) (legal obligation) and Article 6(1)(f) (legitimate interest).
• Marketing communications — Article 6(1)(a) (consent), withdrawable at any time.
• Site security and analytics — Article 6(1)(f) (legitimate interest).
• Compliance with AML, sanctions, and tax reporting laws — Article 6(1)(c).

Recipients

We share personal data with selected service providers (hosting, CRM, email, analytics, AML screening, professional advisors) under written processing agreements, and with regulators or law enforcement where legally required. The Site is hosted by Hostinger International Ltd.

International transfers

Where any future transfer of personal data is made between the EEA and the United Arab Emirates (ADGM), it will be protected by Standard Contractual Clauses or by the European Commission's adequacy decision for the ADGM where applicable.

Retention

We retain personal data for as long as necessary for the purposes stated, or for the period required by law (typically 5–10 years for AML and tax records, 6 years for contractual records, 24 months for general enquiries).

Your rights

Under the GDPR, the Polish RODO regime, and the ADGM Data Protection Regulations 2021, you have the right of access, rectification, erasure, restriction, portability, objection, and the right not to be subject to solely automated decision-making. EU/EEA residents may lodge a complaint with their national supervisory authority (in Poland, the Prezes Urzędu Ochrony Danych Osobowych — UODO); UAE residents may complain to the ADGM Office of Data Protection.

California residents (CCPA / CPRA)

If you are a California resident, you have additional rights including the right to know, the right to delete, the right to correct, and the right to opt out of the sale or sharing of personal information.