Privacy Policy

1. What Information Do We Collect?

Personal Information You Provide to Us

We collect personal information that you voluntarily provide when you:

• Contact us or request information about BlackSea, our products, or our services
• Submit information through a website contact or inquiry form
• Communicate with our sales, marketing, training, recruiting, or other personnel
• Register for or participate in an event, demonstration, training opportunity, or other activity
• Apply for employment
• Otherwise interact with BlackSea

The personal information we collect depends on the context of your interaction with us. It may include:

• Name
• Email address
• Telephone number
• Company or organization
• Job title
• Areas of interest
• Information included in messages, inquiries, or form submissions
• Résumés, employment history, education, qualifications, and other information submitted in connection with an employment application
• Other information you choose to provide

All personal information you provide should be true, complete, and accurate. You should notify us if information you have provided materially changes.

Sensitive Information

We do not knowingly request or process sensitive personal information through our general contact and information-request forms.

Information submitted in connection with employment applications may be processed separately through our recruiting systems and in accordance with applicable employment and privacy laws.

Information Automatically Collected

Certain information may be collected automatically when you visit, use, or navigate our website. This information generally does not directly identify you but may include device, browser, usage, and technical information, such as:

• Internet Protocol address
• Browser type and characteristics
• Device type and characteristics
• Operating system
• Language preferences
• Referring URLs
• General geographic location derived from an IP address
• Pages viewed
• Dates and times of visits
• Website interactions
• Other diagnostic, technical, and usage information

This information may be used to maintain the operation and security of our website, understand website use, improve performance and content, and support internal analytics and reporting.

We may collect this information through cookies, analytics tools, server logs, pixels, web beacons, embedded content, and similar technologies.

Analytics and Embedded Content

We use Google Analytics or similar analytics technologies to understand how visitors interact with our website. These technologies may collect information such as your IP address, browser type, device information, referring website, pages visited, and the duration of your visit.

Our website may also contain embedded content or functionality from third parties, including YouTube videos. When you interact with embedded content, the third-party provider may collect information about your device, browser, and interaction in accordance with its own privacy practices.

Location Information

We may derive an approximate location, such as a country, state, or general geographic area, from your IP address or similar technical information.

Unless a particular website feature expressly requests it, we do not intentionally collect precise GPS-based location information through our general website.

2. How Do We Process Your Information?

We may process personal information for purposes including:

• Operating, administering, maintaining, and improving our website and services
• Responding to questions, contact requests, and requests for additional information
• Communicating about BlackSea products, services, capabilities, training, events, or business opportunities
• Processing and evaluating employment applications
• Managing recruiting and employment-related communications
• Understanding website traffic and visitor interactions
• Improving website functionality, content, and user experience
• Maintaining the security and integrity of our systems
• Detecting, preventing, and responding to fraud, misuse, security threats, or unlawful activity
• Protecting BlackSea’s rights, property, personnel, customers, users, or other individuals
• Complying with applicable laws, regulations, legal processes, contractual requirements, and government requests
• Establishing, exercising, or defending legal claims
• Supporting a merger, acquisition, reorganization, financing, sale, or other business transaction
• Protecting an individual’s vital interests or preventing harm
• Carrying out another purpose disclosed when the information is collected
• Carrying out another purpose with your consent

3. What Legal Bases Do We Rely on to Process Your Personal Information?

We process personal information when we believe it is necessary and when we have a valid legal basis under applicable law. Depending on the circumstances and your location, those bases may include consent, performance of a contract, compliance with legal obligations, protection of vital interests, and our legitimate business interests.

If You Are Located in the European Economic Area or United Kingdom

The General Data Protection Regulation and UK General Data Protection Regulation require us to explain the legal bases on which we rely when processing personal information.

Consent. We may process personal information when you have given us permission to use it for a particular purpose. You may withdraw your consent at any time.

Performance of a Contract. We may process personal information when necessary to provide requested services, take steps at your request before entering into an agreement, or perform obligations under an agreement.

Legitimate Interests. We may process personal information when reasonably necessary to pursue our legitimate business interests, provided those interests are not overridden by your rights and interests. These interests may include operating and improving our website, responding to business inquiries, communicating about our services, securing our systems, and managing our business.

Legal Obligations. We may process personal information when necessary to comply with legal obligations, cooperate with law enforcement or regulatory authorities, exercise or defend legal rights, or use information as evidence in legal proceedings.

Vital Interests. We may process personal information when necessary to protect your vital interests or those of another person, including circumstances involving a potential threat to someone’s health or safety.

If You Are Located in Canada

We may process personal information when you have given express or implied consent, as permitted under applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions.

In certain circumstances, applicable law may permit the collection, use, or disclosure of personal information without consent, including:

• When collection is clearly in an individual’s interests and consent cannot be obtained in a timely manner
• For investigations, fraud detection, and fraud prevention
• In connection with certain business transactions
• To assess, process, or settle an insurance claim
• To identify an injured, ill, or deceased person and communicate with next of kin
• When there are reasonable grounds to believe an individual has been, is, or may be the victim of financial abuse
• When obtaining consent could compromise the availability or accuracy of information needed to investigate a breach of an agreement or a violation of law
• When disclosure is required to comply with a subpoena, warrant, court order, or applicable rules of court
• When information was produced in the course of an individual’s employment, business, or profession and the collection is consistent with the purpose for which the information was produced
• When collection is solely for journalistic, artistic, or literary purposes
• When the information is publicly available and its collection is permitted by applicable regulations

4. When and With Whom Do We Share Your Personal Information?

Service Providers

We may share personal information with vendors, consultants, contractors, and other service providers that perform services for us or on our behalf. These may include providers supporting:

• Website hosting and administration
• Website analytics
• Cybersecurity
• Email and communications
• Recruiting and applicant tracking
• Information technology
• Data storage
• Professional services
• Marketing and website functionality
• Embedded video and media content

These parties may process information only as necessary to provide services to BlackSea, subject to applicable contractual and legal requirements.

Business Partners

We may share information with business partners when necessary to respond to a request, support a joint activity, administer an event, provide a requested service, or pursue a legitimate business opportunity.

Legal and Regulatory Requirements

We may disclose information when we believe disclosure is necessary or appropriate to:

• Comply with applicable law, regulation, legal process, or government request
• Respond to a subpoena, warrant, court order, or other lawful demand
• Cooperate with law enforcement or regulatory authorities
• Protect or enforce our rights, agreements, policies, property, or systems
• Protect the rights, property, safety, or security of BlackSea, our personnel, website visitors, customers, partners, or others
• Investigate or prevent suspected fraud, security incidents, or unlawful activity

Professional Advisers

We may share information with lawyers, auditors, accountants, insurers, consultants, and other professional advisers when reasonably necessary to obtain their services or protect our legal and business interests.

Business Transfers

We may share or transfer personal information in connection with, or during negotiations relating to, a merger, acquisition, financing, reorganization, bankruptcy, sale of company assets, or acquisition of all or part of our business by another entity.

With Your Consent

We may share personal information for another purpose when you direct us to do so or provide your consent.

We do not sell personal information in exchange for money.

5. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and similar technologies, including pixels, web beacons, analytics tools, embedded media technologies, and server logs, to collect or store information.

These technologies may be used to:

• Operate and secure the website
• Remember website preferences
• Understand website traffic and usage
• Measure the effectiveness of website content or communications
• Diagnose technical problems
• Improve website performance
• Support embedded functionality and third-party content

Some cookies and tracking technologies may be placed by third parties that provide services or content through our website, including analytics providers and embedded video providers.

Most browsers allow you to control cookies through their settings. Depending on your browser, you may be able to delete existing cookies, block certain cookies, or receive a notification before a cookie is stored. Disabling cookies may affect the availability or functionality of certain website features.

6. How Long Do We Keep Your Information?

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

The appropriate retention period may depend on:

• The nature and sensitivity of the information
• The purposes for which the information was collected
• Whether we have an ongoing business relationship or legitimate business need
• Applicable legal, regulatory, contractual, tax, accounting, employment, or recordkeeping requirements
• The need to establish, exercise, or defend legal claims
• Security, fraud-prevention, or dispute-resolution considerations

When we no longer have an ongoing legitimate need to process personal information, we may delete, anonymize, or securely dispose of it.

If immediate deletion is not reasonably possible, such as when information is stored in backup archives, we may securely store and isolate the information from further use until deletion is possible, except when continued processing is required or permitted by law.

7. How Do We Keep Your Information Safe?

We use reasonable administrative, organizational, and technical safeguards designed to protect the personal information we process.

However, no electronic transmission over the internet, website, network, or information-storage system can be guaranteed to be completely secure. We therefore cannot guarantee that unauthorized third parties will never be able to defeat our safeguards or improperly collect, access, use, disclose, alter, or destroy information.

You are responsible for using appropriate caution when transmitting information electronically and should access our website only through a secure device and network.

8. Do We Collect Information From Minors?

Our website and services are not directed to children under 18 years of age, and we do not knowingly solicit or collect personal information from children under 18 through our general website services.

If we learn that we have collected personal information from a child under 18 without appropriate authorization, we will take reasonable measures to delete the information, subject to applicable law.

If you believe a child under 18 has provided personal information to us, please contact sales@blacksea.tech.

9. What Are Your Privacy Rights?

Depending on your location and applicable law, you may have certain rights relating to your personal information. These may include the right to:

• Request access to personal information we maintain about you
• Obtain a copy of certain personal information
• Request correction of inaccurate or incomplete information
• Request deletion or erasure of personal information
• Request restriction of certain processing
• Object to certain processing
• Withdraw consent when processing is based on consent
• Request data portability when applicable
• Appeal certain decisions concerning a privacy request
• Opt out of certain uses or disclosures when applicable
• Avoid being subject to certain solely automated decisions with legal or similarly significant effects

These rights are not absolute and may be subject to exceptions or limitations under applicable law.

To submit a request, contact us using the information in the section titled “How Can You Contact Us About This Policy?”

We may need to verify your identity before completing a request. We will consider and respond to valid requests in accordance with applicable privacy laws.

European Economic Area and United Kingdom

If you are located in the European Economic Area or United Kingdom and believe we are processing your personal information unlawfully, you may have the right to submit a complaint to the data protection authority in your country or region.

Switzerland

If you are located in Switzerland, you may have the right to contact the Swiss Federal Data Protection and Information Commissioner.

Withdrawing Consent

When we rely on consent to process personal information, you may withdraw that consent at any time by contacting us.

Withdrawal of consent will not affect the lawfulness of processing performed before the withdrawal. It may also not affect processing conducted under another valid legal basis.

10. Controls for Do-Not-Track Features

Some internet browsers and mobile operating systems include a Do-Not-Track setting or similar mechanism that allows users to express a preference regarding online tracking.

There is currently no universally accepted standard governing how websites should recognize or respond to Do-Not-Track signals. Accordingly, we do not currently respond to all browser-based Do-Not-Track signals.

If a standard for online tracking is adopted that we are required to follow, we will update our practices as appropriate.

11. Do United States Residents Have Specific Privacy Rights?

Residents of certain U.S. states may have additional rights under applicable state privacy laws. Depending on your state of residence and the scope of the applicable law, these rights may include the right to:

• Know whether we process your personal information
• Access certain personal information
• Correct inaccuracies
• Request deletion
• Obtain a portable copy of certain information
• Opt out of certain targeted advertising, profiling, sales, or sharing
• Limit certain uses of sensitive personal information
• Appeal a decision concerning a privacy request
• Receive equal service and treatment when exercising privacy rights

BlackSea does not discriminate against individuals for exercising rights provided by applicable privacy laws.

We may deny or limit a request when permitted by law, including when an exemption applies, we cannot verify the request, or retaining the information is necessary for a permitted legal or business purpose.

You may submit a request by contacting sales@blacksea.tech.

Where permitted by applicable law, you may designate an authorized agent to submit a request on your behalf. We may require documentation confirming the agent’s authority and may independently verify your identity.

12. Do We Make Updates to This Policy?

We may update this Privacy Policy from time to time to reflect changes in our website, services, business practices, technologies, legal requirements, or other operational needs.

The version posted on our website will be the current version. We encourage you to review this Privacy Policy periodically.

13. How Can You Contact Us About This Policy?

Questions, comments, concerns, or privacy requests may be directed to:

14. How Can You Review, Update, or Delete the Information We Collect From You?

Depending on applicable law, you may have the right to request access to the personal information we maintain about you, ask that it be corrected or updated, or request its deletion.

To submit a request, contact us at sales@blacksea.tech.

We may request additional information reasonably necessary to confirm your identity, understand your request, locate relevant records, or determine whether an applicable legal exception applies.