Owner-aligned. Capital-focused.
Privacy Policy
Last updated: April 2025
1. Who We Are
Black Maple Advisory LLC is a company registered in the United Arab Emirates. We operate the website at blackmaple.ch. Black Maple is the data controller for personal data collected through this Site. Our designated privacy contact is legal@blackmaple.ch.
Although incorporated in the UAE, this Site may be accessed by individuals worldwide. We apply the following frameworks to processing activities connected to this Site:
2. What Data We Collect
2.1 Information you provide
We collect personal data only when you voluntarily submit it through our contact and asset submission forms. This includes: name, email address, phone number (optional), asset type, asset location, and any information you choose to share about your asset situation.
2.2 Automatically collected
Where you have provided consent, we may collect device and browser information, usage data, IP address (anonymised), and interaction data via analytics tools (Google Analytics 4) and usability tools (Hotjar). No data is collected automatically without consent.
2.3 Data we do not collect
We do not collect special category data (health, ethnicity, religion, political views), payment or financial information, or government-issued identification.
3. How We Use Your Data
| Purpose | Data used | Legal basis |
|---|---|---|
| Responding to enquiries and assessing engagement fit | Name, email, asset description | Legitimate interests |
| Maintaining records of communications | Name, email, message | Legitimate interests |
| Understanding Site usage | Usage data, device data, IP (anonymised) | Consent (analytics) |
| LinkedIn professional audience insights | LinkedIn cookie data, IP | Consent (marketing) |
| Identifying usability issues | Session recordings, heatmaps (anonymised) | Consent (functionality) |
| Complying with legal obligations | Any data held | Legal obligation |
We do not sell, rent, or share your personal data with third parties for their own marketing purposes. We do not use your data for marketing without explicit consent.
4. Legal Basis (GDPR Article 6)
Article 6(1)(f) — Legitimate interests
Processing enquiries and maintaining business communication records, where our interests are not overridden by your rights.
Article 6(1)(a) — Consent
Non-essential cookies and associated tracking (analytics, marketing, functionality). You may withdraw consent at any time via Cookie Preferences in the footer.
Article 6(1)(c) — Legal obligation
Where processing is required to comply with applicable law.
We do not engage in automated decision-making with legal or similarly significant effects.
5. Third-Party Processors
| Provider | Purpose | Location | Safeguard |
|---|---|---|---|
| Google LLC (GA4) | Analytics | USA | Standard Contractual Clauses; IP anonymisation enabled |
| LinkedIn Ireland Unlimited Company | Professional audience insights | Ireland / USA | Standard Contractual Clauses |
| Hotjar Ltd | Session recordings, heatmaps | Malta / USA | Standard Contractual Clauses; keystroke suppression enabled |
| Vercel Inc. | Site hosting and infrastructure | USA | Standard Contractual Clauses |
6. International Transfers
Some of our third-party processors transfer data outside the UK and EEA. We ensure appropriate safeguards are in place for each transfer:
You may request a copy of the relevant transfer safeguards by writing to legal@blackmaple.ch.
7. Data Retention
| Data type | Retention | Reason |
|---|---|---|
| Enquiry form submissions | 3 years from last contact | Business records |
| Google Analytics | 14 months | Configured in GA4 |
| LinkedIn Insight Tag | 90 days | LinkedIn platform standard |
| Hotjar sessions | 365 days | UX analysis |
| Cookie consent records | 12 months from consent | Compliance evidence |
8. Your Rights
Request a copy of the personal data we hold about you.
Ask us to correct inaccurate or incomplete personal data.
Request deletion of your data where there is no compelling reason to continue processing.
Ask us to suspend processing of your data in certain circumstances.
Receive your data in a structured, machine-readable format.
Object to processing based on legitimate interests.
Withdraw consent at any time where processing is consent-based.
Lodge a complaint with your supervisory authority.
To exercise any of these rights, email legal@blackmaple.ch. We will respond within 30 calendar days.
Supervisory authorities: UK — Information Commissioner's Office (ico.org.uk) · EU — local data protection authority in your country of residence · Switzerland — Federal Data Protection and Information Commissioner (edoeb.admin.ch)
9. California Residents (CCPA / CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) grants you additional rights with respect to your personal information.
Right to Know
You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the purposes for which it is used, and the categories of third parties with whom it is shared.
Right to Delete
You may request deletion of your personal information, subject to certain exceptions.
Right to Correct
You may request correction of inaccurate personal information.
Right to Opt-Out
We do not sell or share personal information for cross-context behavioural advertising. There is nothing to opt out of in this respect.
Right of Non-Discrimination
We will not discriminate against you for exercising your CCPA rights.
To exercise any of these rights, contact us at legal@blackmaple.ch. We will verify your identity and respond within 45 calendar days.
10. Australian Residents
If you are located in Australia, the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs) apply to our handling of your personal information.
We collect personal information only by lawful and fair means. We will take reasonable steps to ensure personal information we hold is accurate, up-to-date, and complete. We will not use or disclose personal information for secondary purposes without your consent, unless a relevant exception applies.
You have the right to access and correct your personal information. You may also complain about a breach of the APPs to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
11. Canadian Residents (PIPEDA)
If you are located in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA), or applicable provincial privacy legislation, governs our collection, use, and disclosure of your personal information.
We collect personal information only for purposes that a reasonable person would consider appropriate. We obtain meaningful consent for the collection, use, or disclosure of personal information, and you may withdraw consent at any time (subject to legal or contractual restrictions).
You have the right to access personal information we hold about you and to challenge its accuracy. Complaints may be directed to the Office of the Privacy Commissioner of Canada at priv.gc.ca.
13. Children
This Site is directed exclusively at business professionals. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted data through this Site, please contact us immediately at legal@blackmaple.ch and we will delete it promptly.
14. Changes to This Policy
This Privacy Policy may be updated from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Where changes are material, we will communicate them prominently on the Site. Continued use of the Site after an update constitutes acceptance of the revised policy.
15. Contact
Black Maple Advisory LLC
##DUBAI_REGISTERED_ADDRESS##
legal@blackmaple.ch
We will respond to all privacy-related requests within 30 calendar days.