Privacy Policy
Last Updated: 30 JUNE 1986
Draft for review. Bracketed items must be completed, the policy reconciled against Blackgrove's actual data practices and vendors, and the whole document reviewed by qualified counsel, before publication. A privacy policy is only accurate if it describes what the organization actually does; see the notes accompanying this draft.
Scope
This Privacy Policy explains how Blackgrove Global Risk ("Blackgrove," "we," or "us") collects, uses, and discloses information about you in connection with our websites, our applications, and our subscriptions, publications, and other products and services (collectively, the "Services"). It applies when you use the Services or otherwise interact with us. It does not apply to third-party websites or services that we may link to, which have their own privacy practices that we encourage you to review.
Information We Collect
Information you provide to us. We collect information you give us directly, for example when you create an account, subscribe to or purchase a Service, sign up for a newsletter or briefing, register for an event, complete a form or survey, request support, or otherwise communicate with us. Depending on the interaction, this may include:
Account and contact information, such as your name, email address, username and password, employer or organization, job title, business address, and phone number.
Payment information, such as billing details and payment-method information. Payment-card data is collected and processed by our third-party payment processor; we do not store full payment-card numbers ourselves.
Communications and submissions, such as the content of messages you send us and information you choose to provide in surveys, forms, or event registrations.
Information we collect automatically. When you use the Services, we and our service providers may automatically collect:
Usage and log information, such as your IP address, browser type, access times, pages and content viewed, links clicked, and the page visited before you came to the Services.
Device information, such as device type, operating system, and identifiers.
Approximate location, derived from your IP address.
Information collected through cookies and similar technologies, as described in our Cookie Policy.
Information from other sources. We may receive information about you from service providers, such as our payment processor and analytics providers, and combine it with information we hold.
How We Use Information
We use the information we collect to: provide, maintain, secure, and improve the Services; create and manage your account and process your subscription and payments; deliver the briefings, publications, and other products you request; send administrative and transactional messages, including security and support notices; respond to your inquiries and provide customer service; communicate with you about products, offers, and events, subject to your preferences and applicable law; understand how the Services are used and develop new features and products; protect against fraud, abuse, and security risks; and comply with legal obligations, resolve disputes, and enforce our agreements.
Legal Bases for Processing (EU, UK, and Similar Jurisdictions)
If you are in a jurisdiction whose law requires it, we process your personal information on one or more of these bases: your consent; the performance of a contract with you or steps taken at your request before entering into one; compliance with a legal obligation; and our legitimate interests, such as operating and improving the Services, securing our systems, preventing fraud, and conducting direct marketing, except where those interests are overridden by your rights. Where we rely on consent, you may withdraw it at any time; where we rely on legitimate interests, you may object.
International Transfers
We are based in the United States, and information we collect may be processed in the United States and other countries whose data-protection laws may differ from those of your own. Where we transfer personal information across borders, we take steps to ensure it receives appropriate protection consistent with applicable law and this Policy.
How We Share Information
We do not sell your personal information for money. We share information only as described here:
Service providers who process information on our behalf, such as hosting, payment processing, email delivery, and analytics providers, under obligations of confidentiality and limited use.
Legal and safety disclosures, where we believe disclosure is required by law or legal process, or is necessary to protect the rights, property, or safety of Blackgrove, our users, or others, or to enforce our terms.
Business transfers, in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.
Aggregated or de-identified information that cannot reasonably be used to identify you.
With your consent or at your direction.
Analytics
We may use analytics providers that use cookies and similar technologies to help us understand how the Services are used. Information these providers collect is subject to their own privacy practices. See our Cookie Policy for details and options.
Your Rights and Choices
Depending on where you are, you may have rights regarding your personal information, which may include the right to: access the information we hold about you; correct inaccurate information; delete your information; obtain a copy in a portable form; and object to or restrict certain processing. Residents of the European Economic Area, the United Kingdom, and certain US states, including California, may have specific rights under applicable law, including, where applicable, the right not to be discriminated against for exercising them.
To exercise a right, contact us using the details below. We will respond as required by applicable law and may need to verify your identity first. We may retain certain information where the law permits or requires, for example to comply with legal obligations, resolve disputes, or enforce our agreements.
You can opt out of marketing emails by following the unsubscribe instructions in those messages or by contacting us; we may still send you non-promotional messages about your account or our relationship. You can control cookies as described in our Cookie Policy.
Data Retention
We retain personal information for as long as necessary to provide the Services and fulfill the purposes described in this Policy, and thereafter as needed to comply with our legal obligations, maintain business and financial records, resolve disputes, and enforce our agreements.
Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, misuse, and unauthorized access, disclosure, alteration, and destruction, including encryption of data in transit, periodic review of our practices, and access controls that limit access to those who need it. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
Children's Privacy
The Services are intended for adults and are not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us personal information, please contact us so we can delete it.
Changes to This Policy
We may update this Policy from time to time. When we do, we will revise the "Last Updated" date above and, where appropriate, provide additional notice. We will not reduce your rights under this Policy without your consent. We encourage you to review it periodically.
Contact Us
If you have questions about this Policy or our privacy practices, contact us at:
Blackgrove Global Risk, Inc. info@blackgroeglobalrisk.com
