What does this policy cover?

This policy describes how Black (referred to as "we" or "us") will make use of your data when you interact with us through our websites and all of the webpages, subdomains and subparts of the platform (our "Platform").

It also describes your data protection rights, including the right to object to some of the processing that we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” below. If you are under the age of 18 you are not permitted to create a profile on our Platform. If an adult creates a profile on your behalf, it is the adult who enters into this policy and agrees to its terms.

Summary of how we use your data

  • We use your personal data in order to provide the services to you, for service administration purposes, to personalize the content you see on the Platform, to identify your location and to improve the services offered to you.
  • Data is shared with companies or entities processing your data on our behalf and on our instruction.
  • Where we rely on your consent, such as for processing your data in order to provide personalized services to you, or sending direct marketing in relation to our relevant products and services, or other products and services provided by us, you can withdraw this consent at any time.

What information do we collect?

We collect and process personal data about you when you interact with our Platform or if you interact with us in person.

Collecting information for Sdara When you subscribe to our mailing list, we may collect  information from you such as your name, position, company, email and mobile number. The supply of your information is voluntary, but the more you tell us about yourself, the better we can tailor our content to you. Information requested in connection with your application will be set out at the relevant section of the Platform and may include (by way of example only):

  • General information such as your first and last name, email address, phone number, and company name.

How do we use this information, and what is the legal basis for this use?

We process this personal data for the following purposes:

  • As required to conduct our business and pursue our legitimate interests, in particular:
    • verifying your identity
    • communicating with you
    • sharing your data as required for the service from time to time
    • to monitor use of our Platform and online services, and use your information to help us monitor, improve and protect our content, services and Platform, to provide you with the most user-friendly navigation experience (both online and offline)
    • to personalize our Platform (including any future platforms), programs or services for you
    • we use information you provide to investigate any complaints received from you or from others about our Platform or our products or services
    • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation)
  • Where you give us consent:
    • we may send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates, and carefully selected partners
    • we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used
    • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time, such as for the purposes of preparing user recommendations.
  • For purposes which are required by law in response to requests by government or law enforcement authorities conducting an investigation.

Withdrawing consent or otherwise objecting to direct marketing

Where we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests.  You have the right to opt-out of direct marketing. You can do this by contacting us at platform@sdara.co.

Who will we share this data with, where and when?

We will keep your data generally confidential but we may share your data in the following instances:

  • We will share your personal data with third parties where we obtain your consent at that time. We will only share the specific personal data which you authorize us to share with such third party. In such case they will be a data controller and they may have their own privacy terms detailing how they use that personal data.
  • Personal data may be shared with government authorities and/or law enforcement officials if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
  • Personal data may also be shared with third party service providers, who will process it on behalf of us for the purposes identified above. Such third parties include (without limitation) providers of website hosting, maintenance, and other related services.
  • Personal data may also be shared with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to us.
  • In the event that our service is privatized, sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new supplier of such services.
  • If you are accessing our Platform from within the European Economic Area ("EEA"), your data might be accessed, collected and/or stored on servers outside of the EEA.

What rights do I have?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format. In some cases where you have requested that your personal data is deleted, we may still have to keep this data on our Platform as the removal of such data will impact other data. In such cases, you can request that such data is anonymized.

In addition, you can object to the processing of your personal data in some circumstances in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or where we have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us using the details set out below.

The provision of certain information is mandatory for the provision of certain services: if the relevant data is not provided, then we might not be able to provide you with certain services. All other provision of your information is optional. However, note that failure to provide the optional data means that we will not be able to send you communications about the goods and services that may be of interest to you, nor personalise the way that our content is presented to you.

How do I get in touch with you?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt-out of direct marketing, you can get in touch by emailing us at privacy@sdara.co.

How long will you retain my data?

In the event that you wish to deactivate your account, a red flag goes on our database and, whilst people cannot use the personal information, it stays on the system for a period of one year for administration purposes before being deleted. We will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a reasonable period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in the future.

In respect of children's data, parents and guardians give us their consent to collect and use the data of minors by providing their details.

Changes to the policy

This policy may be updated from time to time. When updated the “last updated" date below will be amended and the new privacy policy will be posted online.

Last updated: 08 July 2020