Cold Outreach & Communications Policy

Preamble

Black Swan Ventures Group LLC (the "Company") initiates contact with undertakings by electronic mail and by telephone. A recipient of such contact is entitled to know who the Company is, whence the recipient's particulars were obtained, and by what means contact may be brought to an end. This instrument answers each of those questions. It supplements the Privacy Policy and is to be read together with the Full Disclosure and Acceptable Use Policy instruments.

1. The Sender

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

Correspondence may be despatched from cashflowpositive.ai, from blackswansales.com, from salessignal.one, or from a domain maintained solely for delivery. Every communication despatched by the Company identifies Black Swan Ventures Group LLC as its sender.

2. Cessation of Contact

2.1 Any of the following suffices. No account, no authentication, and no reason is required.

(a) Reply to any communication with the word "unsubscribe", "remove", or "stop".
(b) Employ the facility of objection provided in any electronic communication.
(c) Write to mgmt@blackswanventuresgroup.com, prefixing the subject line with the word OPT-OUT, helpful in routing, but not a condition of validity.
(d) Say so upon the telephone. The record is marked immediately.
(e) Telephone +1 872-375-3144.

2.2 Effect. The recipient's particulars are entered upon a permanent suppression register within two business days, and in every case within the ten business days prescribed by the CAN-SPAM Act. Suppression operates across every brand and every sending domain of the Company, and not merely the one from which contact was made.

2.3 Retention consequent upon objection. The Company retains the minimum data necessary to give effect to the objection: electronic mail address, telephone number, and undertaking, indefinitely and exclusively for that purpose. Such retention is itself a legitimate interest within Article 6(1)(f) GDPR, the erasure of such data being the very thing that would occasion renewed contact upon the next refresh of data.

2.4 Erasure in the alternative. A person preferring complete erasure may request it by writing to mgmt@blackswanventuresgroup.com prefixed PRIVACY. The Company shall erase all data held and, where suppression is also desired, shall retain solely a one-way cryptographic digest of the address, by which suppression is maintained without the Company holding the data in intelligible form.

3. Provenance of Contact Particulars

3.1 The Company compiles records comprising business particulars: name; office held; employer; business electronic mail address; business telephone number; and publicly available professional profile.

3.2 Such particulars are derived from: publicly accessible corporate websites and professional networks; public registers; licensed business-to-business data providers, identified in the Sub-processor Register; and publicly reported indicators of recruitment, funding, and technology in use.

3.3 The Company does not purchase consumer data; does not scrape private or access-controlled content; does not process special categories of personal data; and does not contact personal electronic mail addresses or personal mobile numbers where it is able to identify them as such.

3.4 Every person enjoys the right to be informed precisely what the Company holds concerning that person, and to require its rectification or erasure. See clause 9 of the Privacy Policy.

4. Electronic Mail

4.1 Outside the Union and the United Kingdom. Every communication conforms to the CAN-SPAM Act of 2003: accurate transmission and header information; a non-deceptive subject line; identification as a commercial communication where required; the Company's valid physical postal address; and a functioning facility of objection honoured for not less than thirty days from despatch. The Company employs no harvested address, no dictionary attack, and no open relay, and despatches from no falsified account.

4.2 Germany, the Union, and the United Kingdom. By operation of § 7(2) No. 2 of the Gesetz gegen den unlauteren Wettbewerb and of Directive 2002/58/EC, unsolicited commercial electronic mail requires prior express consent, and that requirement admits of no exception in favour of business recipients. The German courts have consistently held that a single unsolicited communication of that character constitutes an actionable interference with the recipient's established and operating business.

The Company accordingly despatches no cold commercial electronic mail into Germany, the Union, or the United Kingdom. Contact within those territories occurs solely where:

(a) the recipient has consented, subscribed, or requested contact;
(b) the narrow exception at § 7(3) of the aforesaid Act in respect of existing customers applies, with a facility of objection in every communication; or
(c) the communication is a genuine and non-commercial reply to a matter initiated by the recipient.

Geographic and domain-level exclusions are configured within the Company's sending platform to give effect to this clause.

4.3 Volume and infrastructure. The Company warms sending domains, observes the rate limits of receiving providers, monitors rates of bounce and complaint, and suspends any campaign exceeding its internal complaint threshold. It despatches from no domain it does not own and from no infrastructure it is not authorised to employ.

5. Telephone

5.1 United States. The Company telephones business numbers in a business context. Lists are screened against the National Do Not Call Registry and against applicable State registries prior to dialling. The Company maintains an internal do-not-call register, gives effect to requests immediately and permanently, telephones only within the hours permitted in the recipient's local time zone (08:00 to 21:00, or such narrower hours as a State rule may prescribe), and identifies itself and the Company at the outset of every call.

5.2 The Company does not employ automatic telephone dialling systems, artificial or prerecorded voice, or ringless voicemail deposit to mobile numbers absent prior express consent, as required by the Telephone Consumer Protection Act and its State analogues, including the Florida Telephone Solicitation Act.

5.3 Germany and the Union. § 7(2) No. 1 of the Gesetz gegen den unlauteren Wettbewerb requires express prior consent in respect of consumers, and at minimum presumed consent (mutmaßliche Einwilligung) in respect of undertakings, being a concrete and objective indication that the particular undertaking would welcome the particular call upon the particular subject. The Company conducts no volume telephone campaign into Germany or the Union.

5.4 Text and messaging services. The Company despatches no unsolicited commercial short message service or messaging-application communication.

6. Recording of Calls

6.1 The Company records and transcribes calls, such recordings and transcripts informing its intelligence deliverables and its internal quality review.

6.2 Recording commences only following an audible announcement given at the outset of the call.

6.3 Where any participant is situate within a jurisdiction requiring the consent of all parties, including California, Florida, Illinois, Maryland, Massachusetts, Pennsylvania, and Washington within the United States, and Germany by operation of § 201 of the Strafgesetzbuch, recording proceeds solely upon the affirmative consent of every participant.

6.4 Recording ceases immediately upon request, and any recording made shall be erased upon request. Neither affects the person's ability to deal with the Company in any respect.

6.5 Recordings are retained for twenty-four months, or for the life of the engagement where forming part of a client deliverable. Access is confined to personnel having an operational need. The technical measures applicable to capture devices are described at clause 5 of the Cybersecurity Disclosure.

7. Practices Not Engaged In

The Company does not, in any circumstance:

(a) falsify sender identity, domain, or header information;
(b) employ pretext, impersonation, or false claim of referral in order to open a conversation;
(c) assert a mutual connection, prior meeting, or existing relationship which does not subsist;
(d) fabricate scarcity, deadline, or social proof;
(e) contact any person who has objected;
(f) sell, let, or otherwise disclose its contact database to any third party;
(g) contact personal electronic mail addresses or personal mobile numbers for commercial purposes; or
(h) persist after being asked to desist.

8. Complaint

8.1 A person believing that contact was made unlawfully may write to mgmt@blackswanventuresgroup.com, prefixing the subject line with the word COMPLAINT, enclosing the communication complained of or the date and time of the call.

8.2 The Company shall acknowledge within two business days and respond substantively within ten business days, stating what occurred, what has been rectified, and confirming suppression.

8.3 A person may in addition complain to a supervisory authority: within Germany, to the data protection authority of the relevant federal state, or to the Wettbewerbszentrale in respect of matters of unfair competition; within the United States, to the Federal Trade Commission at reportfraud.ftc.gov.

8.4 The Company would prefer to resolve the matter directly, and would in every case prefer to be told.

9. 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

Objection: prefix OPT-OUT. Complaint: prefix COMPLAINT. Privacy rights: prefix PRIVACY.