Privacy Policy

IMPORTANT INFORMATION

This Privacy Policy explains how The Black Circle Group ("TBC", "we", "us" or "our") collects, uses, processes, stores and shares Personal Data in connection with your use of our website and your interactions with The Black Circle Group.

The Black Circle Group operates through affiliated entities across multiple jurisdictions, including:

TBCWM International Limited, a company incorporated in the British Virgin Islands with company number 2202526;
The Black Circle Investment SPC, a segregated portfolio company incorporated in the Cayman Islands with company number 432397; and
The Black Circle SPV Limited, an entity established in the Abu Dhabi Global Market, United Arab Emirates, with registration number 32099.

TBCWM International Limited is the data controller responsible for Personal Data collected directly through this Website, including information submitted through website enquiry forms and Personal Data initially recorded within The Black Circle Group's customer relationship management ("CRM") systems.

Personal Data may subsequently be shared with or processed by other entities within The Black Circle Group where necessary in connection with an investment, segregated portfolio, service, transaction, onboarding process or other legitimate business purpose. In such circumstances, another Group entity may act as a separate or joint data controller in respect of the relevant processing activity.

The relevant Group entity or entities will process Personal Data in accordance with the data protection and privacy laws applicable to the relevant processing activity and, where appropriate, will be identified in applicable legal, offering, subscription, onboarding or contractual documentation.

ABOUT OUR WEBSITE AND SERVICES

The website at theblackcircle.com (the "Website") is the official website of The Black Circle Group and provides information about the Group, its affiliated entities, investment structures, solutions and related activities.

Personal Data submitted directly through the Website, including through enquiry forms, is initially collected by TBCWM International Limited.

We may subsequently share Personal Data with other entities within The Black Circle Group and relevant third-party providers where necessary in connection with enquiries, prospective investments, relationship management, onboarding, due diligence, compliance reviews, investment administration, business introducer relationships, events or other legitimate interactions with The Black Circle Group.

Investment-related information on the Website is intended for professional, institutional, sophisticated or other eligible investors, as applicable under the laws and regulations of their respective jurisdictions, together with prospective investors, business partners, introducers, counterparties and other professional contacts.

The specific Group entity or entities, and where applicable any segregated portfolio, relevant to a particular investment, structure or service will be identified in the applicable legal, offering and/or contractual documentation.

CONTACT

For questions concerning Personal Data collected through this Website, to exercise your applicable data protection rights or if you have concerns about how your Personal Data is handled, please contact:

TBCWM International Limited

Email: legal@theblackcircle.com

WHAT IS PERSONAL DATA?

"Personal Data" means information relating to an identified or identifiable individual.

Depending on the circumstances, this may include:

name and contact information;
identification and verification information;
date of birth and nationality;
professional and employment information;
financial, investment and transactional information;
source of wealth and source of funds information;
information concerning beneficial ownership, control or authorised representation;
correspondence and communications with us; and
online and technical identifiers, including IP addresses and device information.

INFORMATION WE COLLECT

We may collect and process the following categories of Personal Data.

Information you provide to us

This may include:

name, email address, telephone number and other contact details;
professional, financial and investment information;
identification and verification documents;
source of wealth and source of funds information;
corporate ownership and control information;
information provided during onboarding, due diligence or compliance processes; and
information submitted through forms, correspondence, meetings or other communications.

Technical information

When you use the Website, we may collect certain technical information, including:

IP address;
browser type and version;
device and operating system information;
Website usage and interaction data; and
cookie and similar technology information.

Information received from third parties

We may receive Personal Data from third parties, including:

identity verification providers;
compliance, KYC and screening providers;
business introducers and intermediaries;
financial institutions and counterparties;
professional advisers;
corporate service providers; and
publicly available and legally accessible sources.

HOW WE USE YOUR PERSONAL DATA

We may use Personal Data for purposes including:

responding to enquiries and communicating with you;
providing information about The Black Circle Group, its affiliated entities, investment structures and solutions;
assessing eligibility for investments, structures or services;
facilitating prospective investments and onboarding;
conducting identity verification, KYC, AML, sanctions screening, source-of-funds and source-of-wealth checks and other due diligence;
establishing and administering client, investor, counterparty and business relationships;
managing investments, structures and related operational requirements where applicable;
communicating with business introducers, intermediaries, counterparties, service providers and professional advisers;
administering invitations, events and business development activities;
sending marketing and other communications where permitted by applicable law;
complying with legal, regulatory, compliance, governance and record-keeping requirements;
preventing and detecting fraud, financial crime and misuse of our systems;
establishing, exercising or defending legal claims; and
operating, monitoring, securing and improving the Website and our systems.

CATEGORIES OF DATA SUBJECTS

We may process Personal Data relating to:

Website visitors;
prospective and existing clients and investors;
beneficial owners, shareholders, controllers, directors, authorised signatories and representatives of corporate clients or investors;
business introducers, intermediaries and referral partners;
counterparties and their representatives;
service providers and professional advisers;
attendees and invitees to events or meetings; and
other individuals who interact with The Black Circle Group.

LEGAL BASES FOR PROCESSING

The lawful basis on which we process Personal Data will depend on the relevant processing activity and applicable law.

Where required under applicable data protection law, we may process Personal Data on one or more of the following bases:

your consent;
taking steps at your request before entering into a contract or performing a contract;
compliance with a legal or regulatory obligation;
our legitimate interests or those of a third party, where those interests are not overridden by your rights and interests; and
any other lawful basis available under applicable data protection law.

Where we process special categories of Personal Data or other information subject to additional legal protection, we will do so only where an appropriate legal basis or condition applies.

MARKETING COMMUNICATIONS

Where permitted by applicable law, we may use your contact details to provide information about The Black Circle Group, relevant investment opportunities, services, events or other business developments.

You may opt out of marketing communications at any time by using the unsubscribe mechanism contained in the relevant communication or by contacting legal@theblackcircle.com.

Opting out of marketing communications will not prevent us from sending communications that are necessary in connection with an existing business, contractual, investment or regulatory relationship.

DATA SHARING

We may share Personal Data, where appropriate and permitted by applicable law, with:

affiliated entities within The Black Circle Group;
The Black Circle Investment SPC and, where applicable, relevant segregated portfolios;
financial institutions, brokers, lenders, custodians and counterparties;
identity verification, KYC, AML and screening providers;
insurers, fiduciaries, corporate service providers and other specialist third-party providers;
IT, hosting, CRM, security and other operational service providers;
auditors, lawyers, accountants, tax advisers and other professional advisers;
regulators, governmental bodies, law enforcement agencies, courts and other competent authorities where required or permitted by law; and
other parties where necessary in connection with a transaction, investment, restructuring or corporate event.

We do not sell Personal Data.

Where a third party acts as an independent data controller, its processing of your Personal Data will also be subject to its own privacy terms and applicable data protection obligations.

INTERNATIONAL TRANSFERS

The Black Circle Group operates internationally. As a result, Personal Data may be transferred to, accessed from or processed in jurisdictions other than the jurisdiction in which it was originally collected.

These jurisdictions may include the British Virgin Islands, Cayman Islands, United Arab Emirates and other jurisdictions in which our Group entities, service providers, counterparties or professional advisers operate.

Where applicable data protection law restricts international transfers of Personal Data, the relevant Group entity will take appropriate steps to ensure that the transfer is made in accordance with applicable legal requirements. This may include reliance on adequacy decisions, approved contractual safeguards or other lawful transfer mechanisms.

DATA RETENTION

We retain Personal Data for as long as reasonably necessary for the purposes for which it was collected, including to:

maintain and administer business, client and investor relationships;
comply with legal, regulatory, AML/KYC and record-keeping requirements;
establish, exercise or defend legal claims;
resolve disputes; and
enforce contractual rights.

The applicable retention period will depend on the nature of the Personal Data, the purpose for which it is processed, the relevant relationship and applicable legal and regulatory requirements.

Where Personal Data is no longer required, it will be deleted, anonymised or otherwise handled in accordance with applicable law and our retention procedures.

DATA SECURITY

We implement appropriate technical and organisational measures designed to protect Personal Data against unauthorised or unlawful access, use, disclosure, alteration, loss or destruction.

Access to Personal Data is limited to persons who require access for legitimate business, operational, legal or regulatory purposes.

However, no electronic transmission, storage system or security measure can be guaranteed to be completely secure.

YOUR RIGHTS

Depending on the data protection laws applicable to you and the relevant processing activity, you may have rights including the right to:

request access to Personal Data we hold about you;
request correction of inaccurate or incomplete Personal Data;
request deletion of Personal Data in certain circumstances;
request restriction of processing;
object to certain processing;
withdraw consent where processing is based on consent;
request portability of Personal Data where applicable; and
lodge a complaint with an applicable data protection or supervisory authority.

These rights may be subject to limitations or exemptions under applicable law.

To exercise your rights, please contact legal@theblackcircle.com.

Where applicable, you may also have the right to raise a complaint with the data protection or supervisory authority responsible for the relevant processing activity.

COOKIES AND TRACKING TECHNOLOGIES

We may use cookies and similar technologies to:

operate and secure the Website;
remember preferences;
improve Website functionality;
understand how visitors interact with the Website; and
perform analytics and, where permitted, support marketing activities.

Further information regarding the cookies and technologies used on the Website is available in our Cookies Policy.

Where required by applicable law, non-essential cookies will only be used with the appropriate consent.

THIRD-PARTY LINKS

The Website may contain links to third-party websites or services.

The Black Circle Group is not responsible for the privacy, security or data processing practices of third parties. You should review the privacy policies applicable to any third-party website or service you access.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our business, legal or regulatory requirements or data processing practices.

Any updated Privacy Policy will be published on this page. Where appropriate or required by law, we may provide additional notice of material changes.

APPLICABLE DATA PROTECTION LAW

The processing of Personal Data by The Black Circle Group and its affiliated entities is subject to the data protection and privacy laws applicable to the relevant Group entity, processing activity and data subject.

Nothing in this Privacy Policy is intended to limit any rights available to an individual under mandatory applicable data protection law.