Introduction

Blachorse Holdings LLC understands that your privacy is important and that you care about how your data is used and shared online. We respect and value the privacy of everyone who visits this website, www.blackhorseinternationaltrade.com  (“Our Site”) and will only collect and use personal data in ways described here and consistently with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy and Cookie Policy is required when you first use Our Site, and you should read and accept this Privacy Policy when signing up for an Account. If you disagree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation

In this policy, the following terms shall have the following meanings:

1.“Account”

means an account is required to access and/or use certain areas and features of Our Site;

2.“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or use certain features. Details of the Cookies used by Our Site are set out in section 13 below;

2.b“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (Blackhorse Directive) Regulations 2023;

3.“Personal Data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means the Personal Data you give us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the [Data Protection Act 1998] OR [EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)]; and

3.b “We/Us/Our”

Means Blackhorse Holdings LLC, a limited company registered in Chicago, United States of America, under company number xxxxx, whose registered address is 136 Madison Avenue, 5th & 6th Floors, New York, 10016, United States of America

Information about us

Our site is owned and operated by Blackhorse Holdings LLC.

Our Data Protection Officer is Richard Daniel and can be contacted by email at compliance @blackhorse internationaltrade.com, telephone at , +1 332-233-4140 or by post at 136 Madison Avenue, 5th & 6th Floors, New York, New York, 10016, United States of America

What does this policy cover?

This Privacy Policy applies only to your use of Our Site. Our site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites, and we advise you to check the privacy policies of any such websites before providing any data to them.

Your rights

– i.e. the right to ask us to delete any Personal Data we hold about you (we only hold your Personal Data for a limited time, as explained in section 6, but if you would like us to delete it sooner, please contact us using the details in section 14);

The right to restrict (i.e. prevent) the processing of your Personal Data;

The right to data portability (obtaining a copy of your Personal Data to re-use with another service or organisation);

The right to object to our use as a data subject, you have the following rights under the GDPR, which this Policy and Our use of Personal Data have been designed to uphold:

The right to be informed about our collection and use of Personal Data;

The right of access to the Personal Data We hold about you (see section 12);

The right to rectification if any Personal Data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);

The right to remove your Personal Data for particular purposes; and

Rights concerning automated decision-making and profiling.

If you have any cause for complaint about our use of your Personal Data, please contact us using the details provided in section 14, and we will do our best to solve the problem for you. If we cannot help, you also have the right to complain to the USA supervisory authority, the Information Commissioner’s Office.

For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

What data do we collect?

Depending upon your use of our site, we may collect some or all of the following personal and non-Personal Data (please also see section 13 on our use of Cookies and similar technologies.

 Our Cookies Policy.

• Salutation;
• name;
• date of birth;
• gender;
• business/company name
• job title;
• profession;
• contact information such as email addresses and telephone numbers;
• demographic information such as postcode, preferences, and interests;
• financial information such as credit/debit card numbers;
• IP address;
• web browser type and version;
• operating system;
• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

How do we use your Data?

All Personal Data is processed and stored securely for no longer than is necessary in light of the reason(s) for which it was first collected. We will always comply with our obligations and safeguard your rights under the GDPR. For more details on security, see section 7 below.

Our use of your Personal Data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

• Providing and managing your Account;
• Providing and managing your access to Our Site;
• Personalising and tailoring your experience on Our Site;
• Supplying our products and services to you (please note that we require your Personal Data in order to enter into a contract with you);
• Personalising and tailoring our products and services for you;
• Replying to emails from you;

Supplying you with emails that you have opted into (you may unsubscribe or opt out at any time by logging into Our website, www.blackhorseintrenationaltrade.com, under the MyBlackhorse section and changing your email subscriptions or contact the Membership department by calling +1 332-233-4140

Market research, including product usage and transactional data.

With your permission and/or where permitted by law, We may also use your data for marketing purposes, including contacting you by email and/or telephone and text message with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications. 

You have the right to withdraw your consent to us using your Personal Data at any time and to request that we delete it.

We do not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for Blackhorse as stated within Our Retention Policy.

How and Where Do We Store Your Data?

We only keep your Personal Data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).

Data security is very important to us, and to protect your data, we have taken suitable measures to safeguard and secure data collected through Our Site.

Do we share data?

Subject to section 8.2, we will not share any of your data with any third parties for any purpose.

We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. Third parties may sometimes require access to some or all of your data. Where any of your data is necessary for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

We may compile statistics about our site’s use, including traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data or any anonymised data that can be combined with other data and used to identify you. We may occasionally share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

We may sometimes use third-party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any Personal Data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the USA and UK and under the GDPR.

In certain circumstances, we may be legally required to share specific data held by us, which may include your Personal Data, for example, where we are involved in legal proceedings, complying with legal requirements, a court order, or a governmental authority.

What Happens If Our Business Changes Hands?

We may occasionally expand or reduce our business, which may involve the sale and/or transfer of control of all or part of our business. Any Personal Data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part, and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which we originally collected it.

In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted, you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

How Can You Control Your Data?

In addition to your rights under the GDPR in section 4, when you submit Personal Data via Our Site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

You may also wish to sign up for one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications you have consented to receive.

Your right to withhold information

You may access our site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for collecting certain data.

You may restrict our use of Cookies. For more information, see section 13 and Our Cookies Policy.

How can you access your Data?

You have the right to request a copy of any of your Personal Data held by us (where such data is held). Under the GDPR, no fee is payable, and we will provide any information in response to your request free of charge. Please contact us for more details at compliance@blackhorseinternational trade.com or using the contact details below in section 14.

Our use of Cookies

Please refer to the Blackhorse Cookie Policy for more information.

Contacting us

If you have an y questions about our Site or this Privacy Policy, please contact us by email at info@blackhorseinternationaltrade.com, by telephone at, +1 332-233-4140 or by post at 136 Madison Avenue, 5th & 6th Floors, New York, 10016, United States of America. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above)

Changes to our Privacy Policy

We may change this Privacy Policy occasionally (for example, if the law changes). Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.