BlackBook Privacy Policy

Last updated: 2 September 2025

🇬🇧 🇪🇺 UK & EU Users Only

This privacy policy applies to users in the United Kingdom and European Union only. BlackBook is currently restricted to these regions to ensure full compliance with GDPR and UK data protection laws.

1. INTRODUCTION

1.1 Roksia, Limited (doing business as, BlackBook) ("BlackBook", "we", "our", or "us") is a networking platform for professionals available through the BlackBook website (www.blkbookroksia.com) (the "BlackBook Website") and through the BlackBook application (the "BlackBook Application").

1.2 This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access and browse the BlackBook Website and/or BlackBook Application.

1.3 If you have any questions about this privacy policy or how we use your personal information, please contact us using the details in paragraph 2 below.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION

2.1 BlackBook is the data controller of the personal information about you that we hold and use as set out in this privacy notice. This means that we determine and are responsible for how your personal information is used.

2.2 If you have any questions, comments and requests regarding this privacy notice or how we use your personal information, please contact help@roksia.com.

3. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

3.1 We collect personal information that you voluntarily submit directly to us when you use the BlackBook Website and/or BlackBook Application. This can include information you provide to us when you make a request on the BlackBook Website and/or BlackBook Application, correspond with us by phone, e-mail or otherwise, subscribe for our marketing communications, or use some other features of the BlackBook Website and/or BlackBook Application.

3.2 Like all online services, we also collect certain personal information about you automatically when you use the BlackBook Website and/or BlackBook Application in order to understand how the BlackBook Website and/or BlackBook Application is used and how we can improve it, as well as to tailor the adverts you see online to your interests.

3.3 We have set out the categories of personal information we collect and how we use them in detail below.

Personal information you submit to us

3.4 We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, we may not be able to respond to your queries or provide other services to you.

Categories of Personal Information

Personal Details

Include first name, last name, username or similar identifier, date of birth, gender, billing address, email address and telephone number.

We use this information to set up your account, enable content sharing, facilitate user discovery, send communications, and ensure platform security.

Content you publish

Including photos, videos or text you have posted, comments, captions, chat messages, and geolocation tags.

We use this information to facilitate the service and provide personalized recommendations.

Professional Details

Including job title, skills, interests, work experience, employer (or business name) and professional contact details.

We use this information for account setup, user discovery, security, and personalized recommendations.

Financial Data

Includes payment card details.

We use this information to facilitate transactions for products purchased on the platform.

Personal information we collect automatically

3.5 We also automatically collect personal information indirectly about how you access and use BlackBook Website and/or BlackBook Application, and information about the device you use to access BlackBook Website and/or BlackBook Application.

3.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

3.7 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the BlackBook Website and BlackBook Application and developing new services and features.

3.8 We typically collect this information through a variety of tracking technologies, including cookies, server-side tracking and similar tracking technologies. For more detailed information about the cookies we use, including details of how to opt-out, please see our Cookies Notice.

4. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

4.1 We will store the personal information we collect for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

4.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

5. RECIPIENTS

5.1 As required in accordance with how we use your personal information, we may share your personal information with the following:

Service Providers

Such as providers of web hosting or other technical services such as analytic services or communication services.

Advisors

Such as legal advisors or accountants who provide advisory services to us.

Business Transaction Partners

Your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition.

Law Enforcement

We may share your personal information with third parties as required by law or if we reasonably believe such action is necessary to comply with the law, detect illegal activities, or protect rights and safety.

Advertising Partners

Third party ad networks and advertising partners that use personal information to serve targeted advertisements (only with your consent).

6. MARKETING AND COMMUNICATIONS

6.1 From time to time, we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

6.2 Our marketing messages will be sent by newsletter, marketing emails and text messages. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

6.3 We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link in the footer of our marketing emails or by contacting us at help@roksia.com. We make every effort to promptly process all unsubscribe requests. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features, technical and security notices).

7. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

7.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your ID, password, credit or debit card information or national identification numbers.

7.2 International Transfers. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the United Kingdom ("UK") or European Economic Area ("EEA"), your personal information may be processed outside of the UK or EEA, including in the United States.

International Transfer Locations

USA: Standard Contractual Clauses or EU-U.S Data Privacy Framework certification
EU (for UK users): Adequacy decision as set out in Schedule 21 the Data Protection Act 2018

8. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

8.1 If you are resident in the UK or EEA, in accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:

Right of Access

You have the right to obtain confirmation of whether we are processing your personal information and to receive a copy of that information.

Right of Portability

You have the right to receive a copy of your personal information in a structured, machine-readable format or to request transfer to another person.

Right to Rectification

You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you.

Right to Erasure

You have the right, in some circumstances, to require us to erase your personal information if continued processing is not justified.

Right to Restriction

You have the right to require us to limit the purposes for which we process your personal information in certain circumstances.

Right to Withdraw Consent

Where we rely on your consent, you have the right to withdraw it at any time.

8.2 You have a right to object to any processing based on our legitimate interests. There may be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case.

8.3 If you wish to exercise one of these rights, please contact us using the contact details at the top of this privacy policy.

8.4 We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive.

8.5 You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, contact the Information Commissioner's Office at https://ico.org.uk/global/contact-us/. If you are in the EEA, visit https://edpb.europa.eu/about-edpb/about-edpb/members_en.

9. LINKS TO THIRD PARTY SITES

The BlackBook Website and BlackBook Application may contain links to third-party websites. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review their privacy policies before providing any personal information.

10. OUR POLICY TOWARDS CHILDREN

10.1 The BlackBook Website and BlackBook Application are not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, please contact us using the details below so that we can take steps to delete such information and terminate any account your child has created with us.

11. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

12. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the BlackBook Website.

For questions about this privacy policy, contact us at help@roksia.com