Privacy Policy

1. Purpose of this Policy

This Privacy Policy explains the general principles by which BlackHold Capital approaches the collection, use, handling, governance and protection of information in connection with its website, platform, communications and related services.

The purpose of this policy is to provide clarity and transparency to users, prospective clients, institutional stakeholders and other relevant parties regarding privacy-related considerations in a professional and enterprise-oriented context.

2. Information We May Collect

Depending on the nature of the interaction, BlackHold Capital may collect or receive information such as identification details, business contact information, technical access data, communication records, onboarding information, usage-related information and other categories relevant to the lawful provision, review or operation of services.

• Contact and business identification details
• Professional and organizational information
• Website, device or technical usage information
• Communications, inquiries and support-related information
• Information relevant to onboarding, contracting or institutional review

3. How Information May Be Used

Information may be used for purposes such as providing access to services, maintaining communications, handling inquiries, improving operational processes, supporting onboarding and contractual workflows, strengthening security, complying with legal obligations and supporting legitimate business administration.

The specific use of information may depend on the context in which it is provided, the type of relationship involved and any applicable contractual or regulatory requirements.

4. Legal Basis and Privacy Governance

BlackHold Capital’s privacy approach is intended to operate within applicable legal and regulatory frameworks, including the lawful handling of information where consent, contractual necessity, legal obligation, legitimate interests or other recognized legal bases may apply.

The exact legal basis for any specific processing activity should be assessed and documented according to the company’s actual jurisdiction, operating structure and legal obligations.

5. Data Sharing and Third Parties

Information may be shared with trusted service providers, professional advisors, infrastructure providers, compliance-related parties or other third parties where reasonably necessary for service delivery, operations, security, legal compliance or legitimate business purposes.

Any such sharing should be limited to what is necessary, subject to appropriate safeguards, and consistent with applicable law, contractual commitments and internal governance standards.

6. International Considerations

Because BlackHold Capital may operate across multiple jurisdictions or interact with international stakeholders, information may in some cases be processed, accessed or transferred across borders.

Where cross-border handling occurs, appropriate legal and operational safeguards should be considered, including contractual protections, transfer mechanisms and internal governance controls as required.

7. Data Retention

Information should be retained only for as long as reasonably necessary in light of the applicable purpose, legal obligations, operational requirements, dispute management, contractual needs or internal governance practices.

Actual retention periods should be defined in accordance with the company’s real operational model, jurisdictional requirements and internal records management policies.

8. Security and Protection Measures

BlackHold Capital seeks to approach privacy and information protection with seriousness, using appropriate administrative, organizational and technical measures designed to reduce risk and support the secure handling of relevant information.

No security measure can guarantee absolute protection, but privacy governance is intended to work alongside broader security posture and operational controls.

9. User Rights

Depending on the applicable legal framework, individuals may have rights in relation to their information, such as the right to access, rectify, erase, restrict, object, withdraw consent or request portability.

The availability and scope of such rights may depend on the individual’s jurisdiction, the nature of the information involved and the legal basis for the relevant handling activity.

10. Cookies and Similar Technologies

The BlackHold Capital website or digital services may use cookies, analytics tools or similar technologies to support functionality, performance, security, user experience and internal understanding of platform interaction.

A more detailed cookie notice or consent management framework may be required depending on the jurisdictions, technologies and actual usage practices involved.

11. Changes to this Policy

This Privacy Policy may be updated from time to time to reflect legal, operational, regulatory or technological changes. Updated versions may be published on this page or otherwise communicated through appropriate channels.

Users are encouraged to review the policy periodically to stay informed about the current privacy framework.

12. Contact Information

For questions regarding this Privacy Policy or privacy-related matters, users may contact BlackHold Capital through the official contact channels published on the website.