Legal Notes

Data Protection Policy (hereafter, the "Privacy Policy")

Last updated: 1 August 2025

We, at BLACKSHIP CAPITAL, a private limited company by shares (LTD), having its registered office at Office 107 Longcroft House, 2–8 Victoria Avenue, London EC2M 4NS, United Kingdom, registered with the Companies House in England under Company Number 14980479, (hereafter "BLACKSHIP CAPITAL", "we", "our" and "us"), have defined the following Privacy Policy.
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In accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, this Privacy Policy explains how BlackShip Capital processes personal data. It outlines the types of personal data we collect, the purposes for which we use it, your data protection rights, and how you can exercise those rights.
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This Privacy Policy applies to our use of personal data collected (as defined below), controlled and/or processed by us in relation to your use of our website (www.blackshipcapital.com) (hereafter, the "Website") and/or any interaction you may have with BLACKSHIP CAPITAL.
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In conformity with the UK General Data Protection Regulation (UK GDPR) and for the sake of good order, it is to be noted that BLACKSHIP CAPITAL acts both as a data controller and a data processor depending on the circumstances. The present policy only applies to situations where BLACKSHIP CAPITAL acts as a data controller.
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BLACKSHIP CAPITAL processes two types of personal data:

• Data processed by BLACKSHIP CAPITAL as processor (hereafter, the "End Users Data") and more precisely personal data concerning end users, i.e. individuals or entities using BLACKSHIP CAPITAL Services or any other service provided by BLACKSHIP CAPITAL and with whom BLACKSHIP CAPITAL has no contractual relationship, collected by BLACKSHIP CAPITAL's clients or directly submitted by BLACKSHIP CAPITAL Services' end users to BLACKSHIP CAPITAL acting as data processor; and

• Data processed by BLACKSHIP CAPITAL as controller  (hereafter, the "Other Data" ") and more precisely all data collected by BLACKSHIP CAPITAL within the scope of this privacy policy other than End Users Data.

BLACKSHIP CAPITAL's clients determine their own privacy policy for the sharing and/or disclosure of End Users' Data. For that reason, we are not responsible and do not control how/to what extent our clients decide to share/disclose End Users' Data collected by them. For information regarding the processing of End Users' Data by BLACKSHIP CAPITAL's clients, please refer to the relevant client's privacy policy.

2. Which types of personal data does BLACKSHIP CAPITAL collect about me?
We collect and/or process all personal data that you choose to communicate to us, such as your name, first name, civil and family status, home and/or office address, date of birth, nationality, social security number, profession, email address, mobile phone number, bank details and other financial data and your registration/login data, as well as other information we collect related to your use of our BLACKSHIP CAPITAL Services or our Website.

We also collect and/or process certain types of information automatically, whenever you interact with us in order to allow you to use the Website and/or BLACKSHIP CAPITAL Services.

When you visit the Website and/or BLACKSHIP CAPITAL Services, cookies may be installed on your browser software to obtain certain personal/usage data when your web browser accesses our Website and/or BLACKSHIP CAPITAL Services.

Those usage data are the following:

• the Internet protocol (IP) address used to connect your computer or mobile device to the Internet;

• the location of your computer or mobile device during the use of our Website;

• interface controls; and

• system information.

BLACKSHIP CAPITAL also collects the personal data of candidates interested in a vacancy with BLACKSHIP CAPITAL. If the interested candidate is subsequently hired, the personal data will be retained for at least the duration of the employment relationship and without prejudice to the above paragraph. In case of rejection, candidate data shall be retained no longer than necessary and deleted in accordance with applicable data retention and equal opportunities obligations, unless the candidate has consented to future consideration.

3. Who are the recipients of the personal data collected about me? Does BLACKSHIP CAPITAL share those data with third parties?
Depending on the concerned data, the persons occupying the following positions are the recipients of the personal data:

• Management Positions

• Security Officer

• Legal Counsel

• Data Protection Contact

BLACKSHIP CAPITAL may share and disclose personal data with third parties (i.e. outside BLACKSHIP CAPITAL) on the following grounds:

• With BLACKSHIP CAPITAL's subcontractors

BLACKSHIP CAPITAL may share/ disclose personal data with its subcontractors that will perform services at BLACKSHIP CAPITAL's direction and on its behalf (for example, a company providing services in order to systematically track BLACKSHIP CAPITAL's Website activity and a company providing Cloud storage solutions). In this case, service providers are either subject to this Privacy Policy or follow privacy rules at least as protective as those stated therein.

• If the disclosure is required or permitted by law

BLACKSHIP CAPITAL may also share/ disclose personal data if required or permitted by law, such as, for example:

• in order to protect and/ or defend BLACKSHIP CAPITAL's rights, including comply with a law or regulation, enforcing agreements or policies;

• to prevent fraud and/ or for safety reasons; and/or

• to protect the vital interests of a person.

• with your consent

If one or some of your personal data might be shared to third parties other than specified above, you will receive notice and will have the choice not to allow your data to be shared.

BLACKSHIP CAPITAL may share your personal data when it collects your consent to do so.

The need to collect your prior consent will also apply if you decide to instruct BLACKSHIP CAPITAL / give consent to BLACKSHIP CAPITAL to make an account connection on your behalf with a third-party account or platform. Personal data that BLACKSHIP CAPITAL may share with a third party based on an account connection will be used and disclosed in accordance with the third party's privacy policy. Before authorising an account connection, you should review the privacy policy of the relevant third party.

Unless on the grounds specified above, BlackShip Capital will not share your personal data with third parties. Where BlackShip Capital transfers personal data to an authorised recipient located outside the United Kingdom and/or the European Economic Area (EEA), such transfer will be carried out in accordance with this Privacy Policy and in compliance with the applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and any relevant safeguards such as standard contractual clauses or adequacy decisions.

4. How long does BLACKSHIP CAPITAL keep Personal Data?
BLACKSHIP CAPITAL only keeps personal data for the time strictly necessary in order to enable the use of our services and/or to fulfil the purposes identified above, and/or to comply with any legal or regulatory obligations. This may imply retaining personal data after the termination of your contractual relationship with BLACKSHIP CAPITAL and/or the deactivation of your personal or business account for the period of time needed for BLACKSHIP CAPITAL to, for instance, demonstrate compliance with its legal or regulatory obligation, resolve dispute and/or enforce our agreements. If you have questions regarding the specific period of storage of your personal data, please contact us by email at legal@blackshipcapital.com.

5. Are my personal data safe with BLACKSHIP CAPITAL?
Your personal data are stored securely in accordance with the principles set out in the General Data Protection Regulation.

BLACKSHIP CAPITAL will keep data, among others, in electronic form, and such data may only be stored for professional use, transferred to any other place of work of BLACKSHIP CAPITAL or of the group to which BLACKSHIP CAPITAL belongs to, including companies of the group that are established abroad, to subcontractors or other co-contractors of BLACKSHIP CAPITAL, as well as to any public administration or authority, provided that legal obligations applicable to BLACKSHIP CAPITAL require such a transfer, or  where the transfer is compliant with the purpose for which the data has been collected by BLACKSHIP CAPITAL.

BLACKSHIP CAPITAL uses physical (secured 2-step entry to the relevant buildings where the personal data are physically stored), administrative and software-based security safeguards (various security layers, such as passwords and restricted access rights) to provide reasonable protection for your personal data. All your personal data digitally stored are encrypted and protected by firewall and information access authorisation controls.

‍6. Who is responsible for processing personal data?
BLACKSHIP CAPITAL is the processor of the End Users' Data, while each of our relevant clients remains the controller of those data. For information regarding the processing of End Users' Data and the details of the controller of those data (i.e. BLACKSHIP CAPITAL's client), please refer to our client's privacy policy. The controller of Other Data is BLACKSHIP CAPITAL LIMITED, having its registered office at Office 107 Longcroft House, 2–8 Victoria Avenue, London EC2M 4NS, United Kingdom, registered with the Companies House in England under Company Number 14980479. If you have any question on BLACKSHIP CAPITAL's Privacy Policy or on our privacy practices that are not addressed in this Privacy Policy, please contact us by email (legal@blackshipcapital.com) or by mail (BLACKSHIP CAPITAL LIMITED, Office 107 Longcroft House, 2–8 Victoria Avenue, London EC2M 4NS, United Kingdom).

‍7. What are my rights regarding my personal data?
Subject to the limitations set out under applicable data protection laws in the United Kingdom, including the UK GDPR and the Data Protection Act 2018, you have: 

• the right to be duly informed about the use and processing of the personal data;

• the right to access the personal data;

• the right to rectify the personal data; 

• the right to request erasure of the personal data, provided that constraints and legal obligations applicable to BLACKSHIP CAPITAL do not conflict with such a request;

• the right to object to the processing of the personal data, provided that no legitimate grounds for the processing exist which override your interests, rights and freedoms or unless the personal data is necessary for the legal defence of BLACKSHIP CAPITAL’s interests.

• the right to obtain in particular situations specified in the GDPR, the restriction of processing so that the personal data may only be processed with your consent (without prejudice to our right to store the data in accordance with the applicable legal provisions). The execution of this right does not impact any previous processing’s;

• the right to receive in particular situations specified in the GDPR, all personal data relating to you and provided by you to BLACKSHIP CAPITAL and to transfer this data to another controller (right to data portability). BLACKSHIP CAPITAL reserves the right to charge a reasonable fee only where requests are manifestly unfounded or excessive for such transfer, especially in case of frequent requests and/or in the event of a request deemed excessive in terms of volume of data to be transferred. You have to inform BLACKSHIP CAPITAL in writing in due course before the end of the contract if you intend to make use of this right. Otherwise, BLACKSHIP CAPITAL can not be held responsible for the erasure of the personal data;

These rights may be exercised by contacting BlackShip Capital by email at legal@blackshipcapital.com or by mail at BlackShip Capital Limited, Office 107 Longcroft House, 2–8 Victoria Avenue, London EC2M 4NS, United Kingdom, along with a signed copy of valid identification.

If you are not satisfied with the way we handle your personal data or privacy concerns, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection, or with the competent supervisory authority in your country of residence.

8. Changes to the Privacy Policy
We may revise this Privacy Policy from time to time to keep it in line with changes in our business, services or applicable law.

All changes to this Privacy Policy will be published on the Website. In case of substantial changes, we will also notify BLACKSHIP CAPITAL Services users by email or through BLACKSHIP CAPITAL Services. If you disagree with any future changes to this Privacy Policy, you should immediately stop using BLACKSHIP CAPITAL Services and the Website and contact BLACKSHIP CAPITAL.

‍Contact Details: Any questions and requests relating to personal data should be addressed per mail to BLACKSHIP CAPITAL LIMITED, Office 107 Longcroft House, 2–8 Victoria Avenue, London EC2M 4NS, United Kingdom, or per e-mail to legal@blackshipcapital.com.