Privacy Policy

PRIVACY POLICY Black Sea Group LLC Effective Date: September 28, 2026 1. Who We Are Black Sea Group LLC is a New Mexico limited liability company providing B2B international commercial intermediary services. Our registered address is 1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110, United States. You can contact us at contact@blackseagroup.io or visit our website at blackseagroup.io. We offer commercial representation, business development, international expansion support, background checks and due diligence on potential business partners, introductions, meeting coordination, and negotiation support. We do not buy, sell, hold title to goods, ship products, hold client funds, act as a bank, operate as a broker-dealer, serve as a payment institution, function as a customs broker, or operate as a freight forwarder. 2. Information We Collect We collect information in two contexts: Contact Form and Website Communications. When you use our website contact form, we collect the information you voluntarily provide: your name, company name, email address, telephone number, the service you are interested in, and your message. This information is transmitted via our mail server to our business email. Business Communications and Mandate Processing. When you engage us under a written proposal or mandate agreement, we collect, process, and exchange business contact information necessary to perform our services. This includes names, titles, company affiliations, email addresses, telephone numbers, and other business identification data of the counterparts you introduce us to or who are involved in the commercial operations we coordinate. We collect this information as part of fulfilling our contractual obligations to you and supporting your international business development. 3. How We Use Your Information We use contact form information to respond to your inquiry, assess the fit of our services for your needs, and prepare a proposal or mandate agreement if appropriate. We use business information collected during mandates to perform the specific services you have requested and contracted with us to provide. This includes conducting business development, facilitating introductions, coordinating negotiations, performing background checks and due diligence, and supporting your commercial operations with buyers, distributors, and suppliers. We do not use your information for marketing, analytics, profiling, or any purpose beyond providing the services you have contracted with us to deliver. 4. Legal Bases for Processing Our processing of your information is based on one or more of the following legal bases under the General Data Protection Regulation (GDPR): Consent. You have explicitly consented to the processing of your information, such as when you submit our contact form or sign a written proposal or mandate agreement. Pre-contractual Steps and Contract Performance. Processing is necessary to take steps you request prior to entering into a contract with us and to perform the services outlined in our written proposal or mandate agreement with you. Legitimate Interests. We process business contact information of counterparts as part of our legitimate interest in performing our contractual obligations to our clients and conducting proper business due diligence and background verification. Legal Obligation. We may process information to comply with applicable laws, regulations, tax requirements, and legal obligations in the United States and jurisdictions where we operate. 5. Cookies and Local Storage Our website does not use analytics cookies, advertising cookies, or tracking technologies. We use only strictly necessary local storage to remember your language preference and your cookie consent choices. This local storage is essential to the basic functioning of the website and does not track your behavior or enable third-party tracking. 6. Processors and Recipients Our hosting provider and email service provider process information on our behalf under data processing agreements. These are our only service processors. Your information is not sold, shared, rented, or disclosed to third parties for their commercial purposes or for advertising. When you specifically request and authorize us to make an introduction between you and a potential buyer, distributor, or supplier, we will share your contact information with that counterpart only as necessary to facilitate the introduction you have requested. Such sharing occurs only at your explicit instruction as part of the mandate services you have contracted with us to provide. 7. Data Retention Contact form inquiries that do not develop into a mandate agreement are retained for twenty-four months and then deleted. When you engage us under a written proposal or mandate agreement, we retain business records, including business contact information of counterparts, for seven years to comply with applicable business and tax recordkeeping requirements. After seven years, we delete this information unless we are required to retain it by law. 8. International Data Transfers Our hosting infrastructure and email services are located in the United States. When we transfer personal information outside of the European Economic Area or United Kingdom, we rely on the Standard Contractual Clauses approved by the European Commission or other adequacy mechanisms permitted under the GDPR and UK GDPR to ensure your information receives adequate protection. 9. Security We maintain appropriate technical and organizational security measures to protect your information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access. However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to use commercially reasonable security measures, we cannot guarantee absolute security. 10. Your Rights Under GDPR and UK GDPR If you are located in the European Union, European Economic Area, or United Kingdom, you have the following rights: Right of Access. You have the right to request access to the personal information we hold about you. Right to Rectification. You have the right to request that we correct inaccurate or incomplete information. Right to Erasure. You have the right to request deletion of your personal information, subject to certain exceptions for legal and contractual obligations. Right to Restrict Processing. You have the right to request that we limit how we use your information. Right to Data Portability. You have the right to receive a copy of your information in a structured, commonly used, and machine-readable format. Right to Object. You have the right to object to certain processing activities, including processing for legitimate interests. Right to Lodge a Complaint. You have the right to lodge a complaint with your supervisory authority if you believe your rights have been violated. To exercise any of these rights, contact us at contact@blackseagroup.io with your request. 11. Your Rights Under CCPA, CPRA, and Other US State Privacy Laws If you are a resident of California or another US state that has enacted privacy legislation including the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), or similar state laws, you may have certain rights depending on your state's requirements. Right to Know. You may have the right to request what personal information we collect, use, and share about you. Right to Delete. You may have the right to request deletion of personal information we have collected from you, subject to certain exceptions. Right to Correct. You may have the right to request correction of inaccurate personal information. Right to Opt Out of Sale or Sharing. We do not sell or share your personal information for commercial purposes or for targeted advertising. Accordingly, there is no sale or sharing to opt out of. Non-Discrimination. We will not discriminate against you for exercising your privacy rights. To submit a request under US state privacy laws, contact us at contact@blackseagroup.io with your request and state of residence. 12. Children Our website and services are not directed to individuals under eighteen years of age. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without verifiable parental consent, we will delete such information promptly. 13. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Privacy Policy on our website and update the Effective Date. Your continued use of our website and services following the posting of changes constitutes your acceptance of those changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. 14. Contact Us If you have questions about this Privacy Policy, our privacy practices, or wish to exercise your rights, please contact us: Black Sea Group LLC 1209 Mountain Road Pl NE, Ste R Albuquerque, NM 87110 United States Email: contact@blackseagroup.io Website: blackseagroup.io 15. Effective Date This Privacy Policy is effective as of September 28, 2026, and governs all information we collect and process on and after this date. This Privacy Policy is governed by and construed in accordance with the laws of the State of New Mexico, United States, without regard to its conflict of laws principles.