The footer link must read exactly: Do Not Sell or Share My Personal Information. California prescribes that wording, and abbreviation of it is a common finding upon enforcement.
Preamble
Black Swan Ventures Group LLC (the "Company") furnishes this notice to residents of California and of every other State whose privacy statute confers a right to opt out of the sale of personal information, of the sharing of personal information for cross-context behavioural advertising, and of targeted advertising. It supplements the Privacy Policy and the Cookie Policy.
1. The Company's Position
1.1 The Company does not sell personal information for monetary consideration. It has never received monetary consideration in exchange for personal information and does not intend to do so.
1.2 The definitions of "sale" and "sharing" under the California Consumer Privacy Act are nonetheless wider than that of an ordinary sale. Where the Company operates advertising or analytics technologies transmitting identifiers to a third party for the purposes of cross-context behavioural advertising, such transmission may constitute a sale or a sharing under that Act, and targeted advertising under the statutes of Colorado, Connecticut, Virginia, Texas, Oregon, Montana, and cognate jurisdictions.
1.3 The facility of objection at clause 2 is accordingly afforded irrespective of the characterisation of the activity. [CONFIRM: where no advertising technology whatsoever is deployed, substitute the following at this clause and retain the page notwithstanding. The absence of the link being itself a frequent finding upon enforcement: "The Company neither sells nor shares personal information within the meaning of any applicable State privacy statute, and operates no advertising or targeting technology."]
1.4 The Company has not sold or shared the personal information of any person known to it to be under the age of sixteen years.
2. Exercise of the Right to Opt Out
2.1 Any one of the following suffices.
(a) Cookie preferences. Open the Cookie Preferences control in the footer and disable the Marketing and Analytics categories. Effect is immediate upon that browser and device.
(b) Global Privacy Control. The Company honours the Global Privacy Control signal as a valid exercise of the right to opt out of sale and sharing. A person enabling that signal within a supporting browser or extension requires no further step. The signal operates per browser and per device.
(c) Electronic mail. Write to mgmt@blackswanventuresgroup.com, prefixing the subject line with the words DO NOT SELL, and stating the address or identifier in respect of which the request is made.
(d) Post or telephone. Black Swan Ventures Group LLC, 30 N Gould Street, Ste N, Sheridan, Wyoming 82801, United States of America; +1 872-375-3144.
2.2 Authorised agents. An authorised agent may submit a request upon production of written authority. The Company may require the consumer to confirm that authority directly.
2.3 Verification. The Company requires neither the creation of an account nor verification of identity in respect of an opt-out request as such, but only such information as enables the request to be applied to the correct record.
2.4 Timing. Opt-out requests are given effect within fifteen business days, and the Company shall notify every third party to whom the data were sold or shared within the ninety days preceding.
3. Further Rights
3.1 Depending upon the State of residence, a consumer may additionally enjoy the rights:
(a) to know and to access the categories and specific items of personal information collected, the sources thereof, the business purpose, and the categories of third parties concerned;
(b) to require deletion, subject to the exceptions prescribed by statute;
(c) to require correction of inaccurate personal information;
(d) to obtain a portable copy in a readily usable format;
(e) to limit the use and disclosure of sensitive personal information, see clause 5;
(f) to opt out of profiling producing legal effects or effects of similar significance; and
(g) to appeal a refusal, where the relevant statute so provides.
3.2 Appeals. An appeal is to be addressed to mgmt@blackswanventuresgroup.com with the word APPEAL in the subject line. The Company shall determine an appeal within forty-five days, furnishing written reasons. Where an appeal is refused, the consumer may contact the Attorney General of that consumer's State.
3.3 Manner of exercise. Requests under this clause 3 are to be addressed to mgmt@blackswanventuresgroup.com. The Company shall respond within forty-five days, extensible once by a further forty-five days where reasonably necessary and upon notice.
4. No Discrimination
The Company shall not deny services, charge a different price, supply a different quality of service, or retaliate in any manner by reason of the exercise of any right conferred by this notice or by any privacy statute.
5. Sensitive Personal Information
5.1 The Company does not collect or process sensitive personal information within the meaning of the California Consumer Privacy Act: government identifiers; financial account credentials; precise geolocation; racial or ethnic origin; religious belief; union membership; genetic or biometric data; health data; or the contents of private communications not directed to the Company.
5.2 The Company employing no sensitive personal information for any purpose beyond those permitted without a right of limitation, no separate notice entitled Limit the Use of My Sensitive Personal Information is required. Should that circumstance alter, such a notice shall be published.
6. Notice at Collection
| Category (Cal. Civ. Code § 1798.140) | Collected | Purpose | Disclosed to | Retention |
|---|---|---|---|---|
| Identifiers (name, business electronic mail address, business telephone number, IP address) | Yes | Correspondence; delivery of services; security | Service providers | Per clause 7, Privacy Policy |
| Commercial information (services enquired of or procured) | Yes | Delivery; billing | Payment processor; accountant | 7 years |
| Internet activity upon the Website | Yes | Analytics; security | Analytics provider | 13 months |
| Professional and employment information (office held, employer) | Yes | Assessment of business fit | Service providers | 24 months |
| Audio (recordings of calls) | Yes | Deliverables; quality review | Transcription provider | 24 months |
| Sensitive personal information | No | , | , | , |
| Biometric, geolocation, education, inferences drawn for profiling | No | , | , | , |
Full particulars appear in the Privacy Policy.
7. Metrics
[CONFIRM: an undertaking buying, selling, or sharing the personal information of ten million or more California residents in a calendar year must publish annual request metrics. The Company is far below that threshold and this clause may accordingly be deleted, to be reinstated should the position alter.]
8. The Company
Black Swan Ventures Group LLC
30 N Gould Street, Ste N, Sheridan, Wyoming 82801, United States of America
mgmt@blackswanventuresgroup.com · +1 872-375-3144
Residents of California may in addition contact the California Privacy Protection Agency at cppa.ca.gov, or the Attorney General at oag.ca.gov/privacy.
Correspondence
Black Swan Ventures Group LLC30 N Gould Street, Ste N
Sheridan, Wyoming 82801
United States of America
mgmt@blackswanventuresgroup.com
+1 872-375-3144
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