Privacy Policy

Your privacy is very important to us. This notice (“Privacy Notice”) is provided by BlackRobin Limited (“we” or “us”) and sets out our policies with respect to the collection, sharing and use of personal information.

Use of Cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to understand how you use our website. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.

Privacy Policies of Other Websites

Our website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy. 

Changes to Our Privacy Policy

Our Company keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 5 November 2022.

Who to Contact About This Privacy Notice

This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). We are considered to be data controllers in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that we determine the purposes and the means of the processing of your personal information.

Please contact info[at]black-robin.com with any questions about this Privacy Notice or requests with regards to the personal data we hold.

The Types of Personal Data We May Hold

The categories of personal data we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches.

How We Collect Personal Data

We may collect your personal data in a number of ways, for example: from the information you provide to us in meetings, correspondence or other; communications with us; from third parties, for example broker/dealers, your agents, or our distribution agents; from publicly available sources; from your computer and software when you view our website.

How We May Use Personal Information

We may process your personal data for the purposes of administering the relationship between you and us, marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.

We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:

i. processing is necessary to perform our obligations;

ii. we are required to comply with a legal or regulatory obligation applicable to us; or

iii. we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose.

What Are The Consequences Of Failing To Provide Personal Information

Where personal data is required to satisfy a statutory obligation or a contractual requirement, failure to provide such information may result in us being unable to provide a service to you.

Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How We May Share Personal Data

We may disclose information about you to our affiliates, service providers or other third parties to perform our contractual obligations. We may also need to share your personal information with regulatory, tax or law enforcement authorities comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so.

We may also disclose information about you, or your transactions and experiences with us, to our affiliates or service providers for our everyday business purposes.

Retention Periods and Security Measures

We will retain your personal data for as long as there is a business relationship between you and us. After that time, other than your basic business contact information, we will retain your personal data only as long as it is required in order to satisfy our legal obligations.

Monitoring of Communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with authorities; and/or (iii) detecting and preventing the commission of financial crime.

January 2023.