Section
Last updated: May 2025
Overview
This Privacy Policy sets forth how Blackbeard Asset Management Ltd (together with its subsidiaries, affiliates, and funds, sub-funds, compartments under management, “Blackbeard”, “we”, “us” and “our”), as a data controller, may collect, process and share personal information about visitors to this website, or any other websites controlled by Blackbeard (the “Site” or collectively the “Sites”), including job applicants, visitors to our offices, individuals who call Blackbeard personnel in our offices, third-party service providers, vendors and suppliers, business contacts and prospective clients and investors. Please note that certain of these disclosures may not apply to you.
If you provide personal information to us about any person other than yourself, you must ensure that the other person understands how their information will be used. You may only provide us with that person's details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.
This Privacy Policy should be carefully reviewed by you, in conjunction with the Terms and Conditions of the Sites, which detail other important information surrounding your use of the Site.
The Types of Information We Collect
There are instances where we invite or request individuals to provide us with their personal data, including through the Sites. In addition, individuals may volunteer their personal data to us by various means of communication, e.g. by telephone, email or via any one of the Sites. In the course of our business, we may also receive personal data indirectly. Categories of such personal data include names, addresses, contact information and other information that is relevant to the conduct of our business.
Our Use of Cookies and Similar Technologies
We use cookies, web beacons and other similar technologies on our Sites for a variety of purposes such as to better understand, customize, and improve the user experience of our Sites, services and offerings, and market to you.
For more detailed information and to update your preferences, go to the Cookies page.
Links to Other Websites
The Sites may contain links to websites operated by third parties, and your personal information may be collected by those third parties when you use their websites.
Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility or liability for the privacy policies and information collection, use, processing and sharing practices of any third-party website (whether or not such site is linked on or to the Sites). These links are provided to you for convenience purposes only, and you access them at your own risk.
How We Use the Information We Collect
Subject to any agreement in writing between the personal data provider and Blackbeard, your personal information will be processed: (i) in order to comply with our legal and regulatory obligations; (ii) to protect vital interests; (iii) in order to comply with our obligations under contract; and/or (iv) to support a legitimate business interest in processing it, including for the following purposes (as applicable):
- to respond to your questions and handle and resolve complaints;
- to perform research with respect to the usage of the Sites (applicable to Site visitors);
- to maintain the security of our premises, personnel, assets, systems, and intellectual property and to manage access to our premises and our disaster recovery procedures (applicable to office visitors);
- to pay you for your services (applicable to third-party service providers, vendors, and suppliers);
- in order to comply with our obligations, including without limitation, in connection with record-keeping requirements and applicable anti-money laundering, anti-corruption and bribery, terrorism financing rules, sanctions, and the prevention and detection of crime or other applicable laws or regulations of jurisdictions in which Blackbeard conducts business (applicable to office callers, third-party service providers, vendors and suppliers);
- to maintain and provide appropriate management of our relationship with you;
- to exchange mail correspondence or documentation which may involve providing your contact details to couriers and service providers;
- to engage your services in the future (applicable to third-party service providers, vendors, suppliers, and business contacts);
- to contact you to set up meetings and/or phone calls between you and your Blackbeard business contact(s); and
- to process your subscription requests and to send marketing communications about Blackbeard to you (if you choose to subscribe, you will have the option to opt out of receiving such marketing communications at any time by contacting us or unsubscribing via a link in the particular communication) (applicable to website visitors, business contacts and prospective clients and investors). Where required by applicable law, we will obtain your prior written consent before sending you direct marketing communications.
For information on how we use and process technology and cookies on the Sites, see the section above entitled “Our Use of Cookies and Similar Technologies”.
Where Blackbeard is relying on its legitimate interests as the ground for processing your personal information, we must carry out an assessment to ensure our interests do not override any rights you may have.
To Whom We Disclose Your Private Information
We may disclose Private Information in any jurisdiction to:
- Blackbeard affiliated entities, subsidiaries, funds, sub-funds;
- third-party service providers, vendors, contractors, and agents of Blackbeard as part of normal business operations, provided that the relevant third party is subject to a duty of confidentiality and to the extent necessary for the purposes of the provision of such services to us, including providers:
- engaged to assist in know your customer and identity verification and anti-money laundering and terrorism screening (applicable to third-party service providers, vendors, and suppliers);
- of accounting, auditing, business consulting, insurance, actuarial, tax services, human resources, business management / administration, security, (such as data security) banking, and other data processing services;
- of information technology services and platforms/applications;
- of courier services or other package delivery services;
- of call recording and storage services (applicable to office callers);
- competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their agents where Blackbeard is required or allowed to do so under applicable law or regulation;
- third parties acting on your behalf such as consultants and other agents;
- financial institutions to wire payments to you (applicable to third-party service providers, vendors, and suppliers);
- advisors who provide audit, financial, business, legal and other advice to Blackbeard;
- any person to whom disclosure is allowed or required by applicable law;
- third parties in the course of defending ourselves in proceedings anywhere in the world, to the extent that, acting in good faith and reasonably, we resolve that such disclosure is necessary to properly defend ourselves;
- third parties in the course of judicial or other proceedings for the settlement of any dispute between you and Blackbeard arising out of or in connection with any agreement, so long as the disclosure is made in good faith;
- third parties, to the extent such disclosure has been expressly and in writing authorised by you;
- third parties, to the extent such disclosure has already entered the public domain, in circumstances not engaging our liability.
The Security Measures We Take to Safeguard Information
We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. Please note that such safeguards, however, do not guarantee that personal information transmitted via the Internet or stored in our systems or is otherwise under Blackbeard’s care will be absolutely safe from unauthorized use or intrusion from third parties due to the inherent nature of the Internet.
Where we have given you a password which enables you to access certain parts of the Sites, you are responsible for keeping that password confidential, and not share it with anyone.
Updating Your Contact Information
You may update your contact information and/or modify your communication preferences by sending us an e-mail at privacy@blackbeard.eu.
Your Choices and Rights
To the extent that we are a controller of your personal data you may request access to, rectification, or erasure of your personal data, or restriction of processing or object to processing of your personal data, as well as the right to data portability. In each case, these rights are subject to restrictions as laid down by law and, to the maximum extent permitted by applicable law, this Privacy Statement as well as any agreement in writing between you and us.
The following is a summary of you rights (which, as stated above, are or may be subject to restrictions):
- The right of access enables you to receive a copy of your personal data;
- The right to rectification enables you to correct any inaccurate or incomplete personal data we hold about you;
- The right to erasure enables you to ask us to delete your personal data in certain circumstances;
- The right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances;
- The right to object enables you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party);
- The right to data portability enables you to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible.
You may exercise your rights at any time by emailing privacy@blackbeard.eu or using the details set out in the Contact Us section. To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights.
We may need to request specific information from you to help us confirm your identity and ensure your right to access to the Personal Information requested, or to exercise any of your other rights. This is to ensure that Personal Information is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the Personal Information processed in relation to you, including, for example, the nature and location of your relationship with us.
We will respond to all legitimate requests in line with the timescales set out in applicable law.
You will not be disadvantaged in any way by exercising your rights in relation to the processing of your Personal Information.
Third-Party Marketing and Sale of Personal Information
We do not share or sell your Personal Information to third parties for the third party to use for their own marketing or other purposes.
How Long is Information Retained?
To the maximum extent permitted by applicable law, we will process your Personal Information for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defence of legal claims.
Amendments to this Privacy Notice
To the maximum extent permitted by applicable law, Blackbeard reserves the right in its sole discretion to modify or amend this Privacy Policy in any way at any time. Any such changes are effective upon posting and we will indicate in the Privacy Policy when it was most recently updated. You should review this Privacy Policy periodically for changes applicable to you. Additionally, note that by accessing the Sites subsequent to any modification, to the maximum extent permitted by applicable law, you are deemed to have agreed to all terms of this Privacy Policy as modified or amended.
Complaints
If you have any concerns or complaints about the way your Personal Information is processed, please contact the Head of Compliance at complaints@blackbeard.eu. You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your Personal Information has arisen.
Please visit Complains Handling section of the Sites for more information and options on how to file a complaint.
How to Contact Us
Please direct any questions regarding Blackbeard’s Privacy Policy to privacy@blackbeard.eu.
Blackbeard Asset Management Ltd 224 Arch. Makarios III Ave., Achilleos Building 3 rd Floor, Office 32 3030 Limassol, Cyprus
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