BLACKBOOK PRIVACY POLICY
Last updated: 25th July, 2024
1. INTRODUCTION
1.1 Roksia, Limited (doing business as, BlackBook) ("BlackBook", "we", "our" , or "us") is a networking platform for professionals available through the BlackBook website (www.bbk.me) (the "BlackBook Website") and through the BlackBook application (the "BlackBook Application").
1.2 This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information”) when you access and browse the BlackBook Website and/or BlackBook Application.
1.3 If you have any questions about this privacy policy or how we use your personal information, please contact us using the details in paragraph 2 below.
2. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION
2.1 BlackBook is the data controller of the personal information about you that we hold and use as set out in this privacy notice. This means that we determine and are responsible for how your personal information is used.
2.2 If you have any questions, comments and requests regarding this privacy notice or how we use your personal information, please contact epic@roksia.com.
3. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
3.1 We collect personal information that you voluntarily submit directly to us when you use the BlackBook Website and/or BlackBook Application. This can include information you provide to us when you make a request on the BlackBook Website and/or BlackBook Application, correspond with us by phone, e-mail or otherwise, subscribe for our marketing communications, or use some other features of the BlackBook Website and/or BlackBook Application.
3.2 Like all online services, we also collect certain personal information about you automatically when you use the BlackBook Website and/or BlackBook Application in order to understand how the BlackBook Website and/or BlackBook Application is used and how we can improve it, as well as to tailor the adverts you see online to your interests.
3.3 We have set out the categories of personal information we collect and how we use them in detail below.
Personal information you submit to us
3.4 We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, we may not be able to respond to your queries or provide other services to you.
Category of personal informationHow we may use itLegal basis for the processing
Personal details include first name, last name, username or similar identifier, date of birth, gender, billing address, email address and telephone number.

We use this information to set up your account on the BlackBook Website/BlackBook Application to enable you to share content with users on the BlackBook Website/BlackBook Application.

This processing is for the performance of a contract and to take steps prior to entering into a contract with you.

We use this information to permit others to find you through the BlackBook Website/BlackBook Application.

This processing is for the performance of a contract and to take steps prior to entering into a contract with you.

We use this information to send service-related communications and handle your customer service requests, including:

  • communicating with you regarding services you have purchased and/or requested;
  • communicating with you about your account;
  • directing your questions to the appropriate team members; and
  • investigating and addressing any concerns.

The processing is necessary for our legitimate interests, namely to communicate with you and respond to and appropriately investigate specific information requests made by you.

We use this information to send notifications and alerts to users that have signed up to receive our newsletter or other marketing emails, surveys and/or information about promotions, competitions and challenges.

We will only process your personal information in this way to the extent that you have given us your consent to do so.

Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the BlackBook Website/BlackBook Application, including identifying and preventing unlawful, fraudulent, or malicious use of the BlackBook Website/BlackBook Application.

The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behaviour to protect the BlackBook Website, BlackBook Application, BlackBook and its users.

We may use this information to improve our recommendation systems, suggest potential users to connect with, brands to follow and/or jobs to apply for.

The processing is necessary for our legitimate interests, namely providing you with a personalised service.

Content you publish on the BlackBook Website/BlackBook Application, including photos, videos or text you have posted (comments to a post, captions to your photos/videos or chat messages exchanged through the BlackBook Website/BlackBook Application) and geolocation tags attached to a post.

We may use this information to facilitate the service offered and enable you to share content on the BlackBook Website/BlackBook Application.

The processing is necessary for the performance of a contract with you.

We may use this information to suggest potential users to connect with, brands to follow and/or jobs to apply for.

The processing is necessary for our legitimate interests, namely providing you with a personalised service.

Chat and comments, when you contact us directly e.g., by email or phone, we will record your comments and opinions.

We use this information to handle your customer service requests including:

  • directing your questions to the appropriate team members; and;
  • investigating and addressing any concerns.

The processing is necessary for our legitimate interests, namely to respond to and appropriately investigate your request.

We may use this information to suggest potential users to connect with, brands to follow and/or jobs to apply for.

The processing is necessary for our legitimate interests, namely providing you with a personalised service.

Professional details including job title, skills, interests, work experience, employer (or business name) and professional contact details.

We use this information to set up your account on the BlackBook Website/BlackBook Application to enable you to share content with users on the BlackBook Website/BlackBook Application.

This processing is for the performance of a contract and to take steps prior to entering into a contract with you.

We use this information to permit others to find you through the BlackBook Website/BlackBook Application.

This processing is for the performance of a contract and to take steps prior to entering into a contract with you.

Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the BlackBook Website/BlackBook Application, including identifying and preventing unlawful, fraudulent, or malicious use of the BlackBook Website/BlackBook Application.

The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behaviour to protect the BlackBook Website, BlackBook Application, BlackBook and its users.

We may use this information to improve our recommendation systems, suggest potential users to connect with, brands to follow and/or jobs to apply for.

The processing is necessary for our legitimate interests, namely providing you with a personalised service.

Financial Data includes payment card details.

We use this information to facilitate transactions if you buy a product on the BlackBook Website/BlackBook Application.

The processing is necessary for the performance of a contract with you.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

We use this information to fulfil purchases of products or services and process payments.at your request.

This processing is for the performance of a contract and in order to take steps prior to entering into a contract with you.

We use this information to send marketing emails, surveys and/or information about promotions.

We will only process your personal information in this way to the extent that you have given us your consent to do so.

Profile Data includes your username and password, purchases or orders made by you, your interests and preferences and feedback and survey responses.

We use this information to authenticate you when using the BlackBook Website/BlackBook Application and to allow you to log into your account on the BlackBook Website/BlackBook Application.

The processing is necessary for our legitimate interests, namely to provide you with an account and respond to specific information requests regarding your account.

We use this information to fulfil purchases of products and / or services at your request.

This processing is for the performance of a contract and in order to take steps prior to entering into a contract with you.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We use this information to send notifications and alerts to users that have signed up to receive our newsletter or other marketing emails, surveys and/or information about promotions in accordance with your preferences.

We will only process your personal information in this way to the extent that you have given us your consent to do so.

Personal information we collect automatically
3.5 We also automatically collect personal information indirectly about how you access and use BlackBook Website and/or BlackBook Application, and information about the device you use to access BlackBook Website and/or BlackBook Application.
3.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
3.7 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the BlackBook Website and BlackBook Application and developing new services and features. We may also share such anonymised and aggregated information with others.
3.8 We typically collect this information through a variety of tracking technologies, including cookies, server-side tracking and similar tracking technologies. For more detailed information about the cookies we use, including details of how to opt-out, please see our Cookies Notice.
Category of personal informationHow we may use itLegal basis for the processing
Location Information or your IP address, including longitude, latitude, date and time (the precision of this data varies greatly and is determined by factors controlled by your device or mobile service providers).

Where relevant and where permitted under applicable law, we use this information to identify potential risk or unlawful behaviour including fraud detection, theft prevention, emergency response purposes and legal compliance.

We will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.

Information about how you access and use the BlackBook Website and/or BlackBook Application, the time you access the BlackBook Website/BlackBook Application and how long you access it for, the approximate location that you access the BlackBook Website/BlackBook Application, the site from which you came and the site to which you are going when you leave the BlackBook Website/BlackBook Application, the pages you visit, the links you click, your interactions on the BlackBook Website/BlackBook Application and other actions you take on the BlackBook Website/BlackBook Application.

We use information about how you use the BlackBook Website/BlackBook Application to present the BlackBook Website/BlackBook Application to you on your device.

We will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.

We use this information to monitor and improve the BlackBook Website/BlackBook Application and to resolve any issues.

Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the BlackBook Website/BlackBook Application, including identifying and preventing unlawful, fraudulent, or malicious use of the BlackBook Website/BlackBook Application.

Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to connect to the BlackBook Website/BlackBook Application. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the BlackBook Website/BlackBook Application through the device, your mobile network, your IP address and your device's telephone number (if it has one).

We use information about how you use the BlackBook Website/BlackBook Application to present the BlackBook Website/BlackBook Application to you on your device.

We will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.

We use this information to monitor and improve the BlackBook Website/BlackBook Application and to resolve any issues.

Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the BlackBook Website/BlackBook Application, including identifying and preventing unlawful, fraudulent, or malicious use of the BlackBook Website/BlackBook Application.

We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google's practices here and view its opt-out options here.

We may collect analytics data or use third-party analytics tools to help us measure traffic and usage trends for the BlackBook Website/BlackBook Application and to understand more about the demographics of our users.

We will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.

4. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
4.1 We will store the personal information we collect for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.
4.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
5. RECIPIENTS
5.1 As required in accordance with how we use your personal information, we may share your personal information with the following:
RecipientWhy we share it and how they will use it Lawful basis
Service providers, such as providers of web hosting or other technical services such as analytic services or communication services.

These third-party vendors and other service providers perform services for us or on our behalf.

These service providers will use your personal information as processors on our instructions.

Advisors, such as legal advisors or accountants.

These advisors will use your personal information to provide advisory services to us.

The lawful basis we rely on for these transfers is that the processing is necessary for our legitimate interests, namely obtaining legal, accounting and other

Purchasers and third parties in connection with a business transaction. Your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, re-organisation, financing, change of control or acquisition of all or a portion of our business.

These recipients will use your personal information to review and assess a potential transaction to purchase our business or assets.

The lawful basis we rely on for these transfers is that they are necessary for our and the purchaser's legitimate interests, namely to conduct due diligence on our business and assets in connection with a potential acquisition.

Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and / or (iii) exercise or protect the rights, property or personal safety of BlackBook, its users or others.

These recipients will use your personal information in the performance of their regulatory or law enforcement role, or to advise us in connection with a potential claim or regulatory enforcement action.

The lawful basis we rely on for sharing personal information with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject or, where there is no applicable legal obligation to share this data, that the sharing is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities.

Third party ad networks and advertising partners, such as advertising agencies and exchanges that use personal information to serve adverts to you based on your browsing history when you browse the internet.

We may share personal information with advertising networks or permit these partners to collect information from you directly on the BlackBook Website/BlackBook Application, to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms.

We will only share your personal information in this way to the extent you have given us your consent to do so.

6. MARKETING AND COMMUNICATIONS
6.1 From time to time, we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
6.2 Our marketing messages will be sent by newsletter, marketing emails and text messages. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
6.3 We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link in the footer of our marketing emails or by contacting us at epic@roksia.com. We make every effort to promptly process all unsubscribe requests. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to the features of the BlackBook, technical and security notices).
7. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
7.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your ID, password, credit or debit card information or national identification numbers.
7.2 International Transfers of your personal information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the United Kingdom ("UK") or European Economic Area ( "EEA"), your personal information may be processed outside of the UK or EEA, including in the United States. We will ensure that these international transfers of your personal information are made pursuant to appropriate safeguards, such as:
  • (a) ensuring that the personal information is only transferred to countries recognised by the UK Secretary of State or the European Commission (as applicable) as offering an equivalent level of protection as compared to the level of protection in the country you are located; or
  • (b) the transfer is to a third party who uses appropriate safeguards in respect of the processing in question, included but not limited to the UK or EU standard contractual clauses, which are recognised as offering adequate protection for the rights and freedoms of data subject, as adopted by the UK Secretary of State or the European Commission (as applicable).
7.3 We may transfer your personal information to, or store your personal information in, the following countries:
CountryAppropriate Safeguard

Ghana

The Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/914.

USA

Either:

  • the Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/914; or
  • the recipient is certified to the EU-U.S Data Privacy Framework (the “DPF”), the Swiss – US DPF and/ or the UK extension to the DPF (the UK-US Data Bridge), as set forth by the U.S. Department of Commerce.

South Africa

The Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/914.

(For UK users) EU

Adequacy decision as set out in Schedule 21 the Data Protection Act 2018.

7.4 We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy regardless of where it is processed.
7.5 If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy policy.
8. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
8.1 If you are resident in the UK or EEA, in accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:
  • (a) Right of access . You have the right to obtain:
    • (i) confirmation of whether, and where, we are processing your personal information;
    • (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
    • (iii) information about the categories of recipients with whom we may share your personal information; and
    • (iv) a copy of the personal information we hold about you.
  • (b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
  • (c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
  • (d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
  • (e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  • (f) Right to withdraw consent. Where we rely on your consent for processing your personal information, you have the right to withdraw your consent. Withdrawal of your consent will not affect the lawfulness of the processing of your personal information before you withdrew your consent.
8.2 You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
8.3 If you wish to exercise one of these rights, please contact us using the contact details at the top of this privacy policy.
8.4 We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs.
8.5 You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, your local data protection authority is the Information Commissioner's Office, which can be contacted using the details at https://ico.org.uk/global/contact-us/. If you are in the EEA, further information about how to contact your local data protection authority is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
9. LINKS TO THIRD PARTY SITESWe will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs.
10. OUR POLICY TOWARDS CHILDREN
10.1 The BlackBook Website and BlackBook Application are not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, either directly or by other means, then please contact us using the details below so that we can take steps to delete such information and terminate any account your child has created with us.
11.CHANGES TO THIS POLICYWe may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
12.NOTICE TO YOUIf we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the BlackBook Website.