Privacy Policy

IMPORTANT INFORMATION

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

The Black Circle Group operates through affiliated entities across multiple jurisdictions. The entity responsible for processing your Personal Data will depend on the context in which it is collected and will be identified in any relevant contractual documentation where applicable.

For the purposes of applicable data protection laws, including the Abu Dhabi Global Market (ADGM) Data Protection Regulations 2021, an appropriate affiliated entity of The Black Circle Group will act as the data controller depending on the context in which your Personal Data is collected and processed.

ABOUT OUR WEBSITE AND SERVICES

The website at theblackcircle.com is the official website of The Black Circle Group and is intended to provide information about the Group, its affiliated entities, and its offerings.

We may collect and process Personal Data submitted through the website in connection with enquiries, relationship management, onboarding, due diligence, compliance reviews, business introducer relationships, event participation, and requests relating to our products, services, or structures.

The website is intended for professional clients, eligible counterparties, prospective investors, business partners, introducers, and other professional contacts. The specific entity providing any services will be identified in the relevant contractual or onboarding documentation.

CONTACT

If you have any questions regarding this Privacy Policy or how your Personal Data is handled, you may contact us at: Email: legal@theblackcircle.com

WHAT IS PERSONAL DATA

"Personal Data" means any information that relates to an identified or identifiable individual, including but not limited to:

  • name and contact details
  • identification information
  • financial or transactional information
  • online identifiers (e.g. IP address)

INFORMATION WE COLLECT

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

Information you provide:

  • name, email, phone number
  • professional and financial background (where voluntarily provided)
  • identification documents (in onboarding contexts only)
  • any information submitted via forms or correspondence

Technical information:

  • IP address
  • browser type and version
  • device information
  • website usage data

Third-party information:

We may receive Personal Data from:

  • identity verification providers
  • compliance and screening providers
  • professional advisers or introducers

HOW WE USE YOUR DATA

We may use your Personal Data for the following purposes:

  • to respond to enquiries and provide information about The Black Circle Group, its affiliated entities, and its offerings;
  • to assess interest in our products, structures, and services;
  • to communicate with prospective professional clients, counterparties, business partners, introducers, and other professional contacts;
  • to support onboarding, due diligence, identity verification, KYC, AML, sanctions screening, source-of-funds checks, and related compliance processes where applicable;
  • to manage ongoing business and relationship communications;
  • to administer invitations, events, marketing communications, and other business development activity, where permitted by law;
  • to comply with legal, regulatory, risk management, governance, and record-keeping obligations;
  • to operate, monitor, secure, and improve the website and related systems.

CATEGORIES OF DATA SUBJECTS

We may collect Personal Data relating to:

  • visitors to theblackcircle.com;
  • prospective and existing clients or investors;
  • beneficial owners, controllers, directors, authorised signatories, and representatives of corporate clients;
  • business introducers, intermediaries, and referral partners;
  • service providers, counterparties, and professional advisers;
  • attendees or invitees to events or meetings.

Where we send marketing or business communications, you may opt out at any time by using the unsubscribe mechanism in the communication or by contacting us at legal@theblackcircle.com.

LEGAL BASIS FOR PROCESSING

We process Personal Data only where we have a lawful basis, including:

  • your consent
  • performance of a contract or pre-contractual steps
  • compliance with legal or regulatory obligations
  • legitimate interests (e.g. operating and improving our business)

DATA SHARING

We may share your Personal Data with:

  • affiliated entities within The Black Circle Group
  • service providers (e.g. IT, compliance, verification providers)
  • professional advisers
  • regulators, courts, or authorities where required by law

We do not sell your Personal Data.

INTERNATIONAL TRANSFERS

Your Personal Data may be transferred to jurisdictions outside the Abu Dhabi Global Market (ADGM). Where such transfers occur, we will ensure that appropriate safeguards are implemented in accordance with applicable data protection laws to protect your Personal Data.

DATA RETENTION

We retain Personal Data only for as long as necessary to:

  • fulfil the purposes outlined in this policy
  • comply with legal and regulatory obligations
  • resolve disputes and enforce agreements

Retention periods will vary depending on the nature of the data.

DATA SECURITY

We implement appropriate technical and organisational measures to protect Personal Data. However, no system can be guaranteed to be completely secure.

YOUR RIGHTS

Subject to applicable law, you may have the right to:

  • access your Personal Data
  • request correction or deletion
  • restrict or object to processing
  • withdraw consent
  • lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with the Abu Dhabi Global Market Office of Data Protection (ODP), or any other relevant supervisory authority.  To exercise your rights, contact: legal@theblackcircle.com

COOKIES AND TRACKING

We use cookies and similar technologies to:

  • operate the website
  • improve functionality
  • analyse usage

Further details are available in our Cookies Policy.

THIRD-PARTY LINKS

Our website may contain links to third-party websites. We are not responsible for their privacy practices.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Updates will be posted on this page.

JURISDICTION

This Privacy Policy is governed by the laws of the Abu Dhabi Global Market (ADGM).