Introduction

This Privacy Policy outlines the practices of Black Arrow Launchpad Ltd (“we,” “our,” or “the Company”) concerning the collection, use, and disclosure of information from users (“Users,” “you,” “your”) who access the Black Arrow Launchpad website at blackarrowlaunchpad.com (the “Site”), register for or use any of the Services (as defined in our Terms & Conditions), or communicate with us in any other manner.

We encourage you to read this Privacy Policy carefully to understand our practices regarding your information. This Privacy Policy should be read alongside our Terms of Use, including the definitions provided therein.

What Information Do We Collect?

We collect two types of data and information from Users who access the Services:

1. Non-Personal Information:

   This refers to non-identifiable information pertaining to a User(s), which may be collected through your access to the Services. Non-Personal Information may include aggregated usage data and technical information transmitted by your device, such as browser type, language preference, access time, and other usage statistics. This information is collected to enhance the functionality and performance of our Services.

2. Personal Information:

   This refers to information that identifies an individual or may identify an individual with reasonable effort (“Personal Information”). Such information includes:

   • Contact Information:

     When you register for the Services or contact us, you may be asked to provide your name, email address, phone number, or other relevant contact details.

   • Information Related to Token Sales:

     When participating in token sales, investing through our platform, or engaging in any fundraising activities, you may be asked to provide additional information such as your digital wallet address, home address, date of birth, identification documents (e.g., passport, driver’s license), and proof of residence. This information may be necessary for compliance with legal and regulatory obligations, including anti-money laundering (AML), combating the financing of terrorism (CTF), and Know Your Customer (KYC) requirements.

   • Device Information:

     We may collect information from your device, such as IP address, unique identifiers (e.g., MAC address), and other information related to your activity on the Services.

   • Communication Information:

     We may collect and retain information from your communications with us, including customer support inquiries.

   • Voluntary Information:

     We may collect voluntary information you provide (e.g., through surveys) to improve our Services.

If we associate Non-Personal Information with Personal Information, we will treat such information as Personal Information.

Information from Other Sources

The Company may work closely with third parties (e.g., business partners, sub-contractors) and may receive information about you from them. This may include data from digital wallets, social networks, and providers conducting KYC or AML procedures on our behalf.

Legal Bases for Processing

The legal bases for processing depend on the Services you use and how you use them. We collect or process your Personal Information only where:

• It is necessary for the performance of our contractual obligations towards you and for providing you with our Services.
• Subject to your consent.
• When we need to process your data to comply with a legal obligation to which we are subject.
• To protect and accomplish our legitimate interests and to comply with our legal obligations.

How is The Information Used?

With Whom Do We Share The Information?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy. We may use the information for the following purposes:

• Providing the Services: To offer, operate, and improve our Services.
• Communicating with You: To respond to your inquiries, provide customer support, and send you relevant information about your use of our Services.
• Analytics and Improvement: To conduct statistical and analytical purposes intended to improve the Services.
• Compliance: To ensure compliance with our terms, policies, and applicable laws and regulations.

In addition, we may share Personal Information with our trusted third-party providers and business partners for the following purposes:

• Providing the Services, including personalized display and functionality of our Site;
• Storing and processing information on our behalf;
• Performing research, technical diagnostics, or analytics;
• Conducting KYC, AML, or CTF-related procedures;
• Other identification and verification purposes;
• Marketing purposes.

We may also disclose information if we believe that disclosure is necessary to comply with legal obligations, enforce our policies, or protect the rights, property, or safety of us, our Users, or others.

User Rights

Depending on your jurisdiction, you may have the right to:

• Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
• Receive a copy of personal information you directly provided to us in a structured, commonly used, and machine-readable format.
• Request rectification of your personal information.
• Request erasure of your personal information.
• Object to the processing of personal information by us.
• Request to restrict processing of your personal information.
• Lodge a complaint with a supervisory authority.

To exercise any of these rights, please contact us at [insert contact email]. Please note that these rights may be subject to our own legitimate interests and legal requirements.

Retention

We will retain your personal information for as long as necessary to provide the Services and comply with our legal obligations. Retention periods will be determined based on the type of information collected and its purpose.

Third-Party Collection of Information

This Privacy Policy addresses the use and disclosure of information we collect from you. If you disclose your information to third parties (e.g., through our Site), their privacy practices may differ. We encourage you to review the privacy policies of any third-party services you interact with.

How Do We Safeguard Your Information?

We take reasonable steps to secure your information through industry-standard procedures and policies. However, we cannot guarantee absolute security and cannot be responsible for unauthorized access, misuse, or other security breaches beyond our control.

Transfer of Data Outside the European Economic Area (“EEA”)

Your information may be transferred to countries outside the EEA. We ensure such transfers are made in compliance with applicable laws, ensuring an adequate level of data protection.

Cookies and Tracking Technologies

We use cookies and other tracking technologies to enhance your experience on our Site, analyze performance, and personalize content. You can manage your cookie preferences through your browser settings.

Corporate Transaction

In the event of a corporate transaction (e.g., sale, merger), your information may be transferred as part of the transaction.

Minors

The Services are intended for individuals over the age of 18. If we become aware that a minor has shared information with us, we will take steps to delete such information.

Updates or Amendments to This Privacy Policy

We reserve the right to update or amend this Privacy Policy at any time. Changes will be effective upon posting the revised Privacy Policy on our Site. Your continued use of the Services constitutes your acknowledgment of the changes.

Controlling Version

This Privacy Policy has been drafted in English, and the English version shall prevail in case of any discrepancies between translations.

How to Contact Us

If you have any questions about the Services or the information we collect, please contact us at admin@blackarrowlaunchpad.com.