How BLACKBOOK collects, uses and protects the personal data you give us on our websites and waitlists, and the choices you have.
1. Who we are
This policy explains how BLACKBOOK HOLDINGS Limited, incorporated in the Dubai International Financial Centre under DIFC Law No. 5 of 2018, registered number 11281, and its related company Black Book Holdings Pty Ltd, ACN 646 293 316 (together, “BLACKBOOK”, “we”, “us”) collect and use personal data through our websites, including blackbookapp.co and b2b.blackbookapp.co, and through our waitlists, forms and emails.
BLACKBOOK is in development and goes live in the UAE in 2027, with the rest of the world to follow. This policy covers the websites and the waitlist. When the app launches, it will have its own privacy notice, which we will show you before you create an account.
For the purposes of data protection law, BLACKBOOK HOLDINGS Limited is the controller of the personal data described here. You can reach us about anything in this policy at hello@blackbookapp.co.
2. What we collect
We collect only what you give us and what is needed to run the websites.
| When | What |
|---|---|
| You join the waitlist | Your name, email address, the city or country you are in, and, if you give it, a mobile number and how you heard about us. |
| You ask for a brochure or a white paper | Your name, business email, mobile number, company and role, and which document you asked for. |
| You send an enquiry, book a demo or apply as an ambassador, merchant, photographer or developer | What you enter in the form, which may include your name, contact details, company, role, city, a link to your work and your message. |
| You use the websites | Technical data your browser sends to any website, such as your IP address, browser type, the page requested and the time, which our hosting provider records in its logs. If you choose “Allow” on the cookie bar, HubSpot and Google Analytics also record how you use the websites, as set out in our cookie notice. |
We do not ask for, and ask you not to send us, payment details, identity documents or sensitive personal data through the websites.
3. How we use it
- To keep your place on the waitlist and tell you when BLACKBOOK is available where you are, including the waitlist offer.
- To send you the brochure or paper you asked for, as a link that works for seven days.
- To reply to your enquiry, arrange a demo, and assess applications from ambassadors, merchants, photographers and developers.
- To keep the websites secure, working and free of abuse.
- To send you occasional news about BLACKBOOK, where you have agreed to it. Every email has a way to stop them.
We do not sell your personal data, and we do not use it to build advertising profiles.
4. Our legal basis
We rely on your consent when you join the waitlist or ask for news from us, and you can withdraw it at any time. We rely on our legitimate interests to answer business enquiries, send documents you have requested, and keep the websites secure, and we have balanced those interests against your rights. Where we need your data to take steps you have asked for before entering into an agreement with you, we rely on that.
5. Who we share it with
We share personal data only with service providers who process it for us under contract, and only as far as they need it:
| Provider | What they do |
|---|---|
| Vercel | Hosts the websites and runs the forms. |
| Upstash | Stores waitlist and form entries. |
| Resend | Sends the emails you ask for, such as a brochure link. |
| Serves some of the fonts on the websites, and runs the calendar we use when you book a demo. |
We may also disclose personal data where the law requires it, to protect our rights, or to a buyer or successor if our business is reorganised or sold, in which case this policy will continue to apply to your data.
6. Where it is kept
Our providers may process data outside the country you are in, including in the United States and the European Union. Where data leaves the DIFC, the UAE or the European Economic Area, we rely on the safeguards the law allows, such as an adequacy decision or standard contractual clauses.
7. How long we keep it
We keep waitlist entries until BLACKBOOK is available to you and for a reasonable period afterwards, or until you ask us to remove you. We keep enquiries and applications for as long as we need them to deal with you, and for up to two years afterwards. Hosting logs are kept for a short period by our hosting provider.
8. How we protect it
Data is encrypted in transit and stored with providers who encrypt it at rest. Access is limited to the people who need it. Document links are signed and expire after seven days. No system is perfectly secure, and if something goes wrong we will tell you and the regulator where the law requires it.
9. Your rights
Depending on where you live, you can ask us to tell you what personal data we hold about you, give you a copy, correct it, delete it, stop or limit using it, or move it to someone else, and you can withdraw your consent at any time. Write to hello@blackbookapp.co and we will reply within one month.
If you are unhappy with how we have handled your data, please tell us first. You can also complain to the DIFC Commissioner of Data Protection, or to the data protection authority where you live.
10. Children
The websites and the waitlist are for people aged 18 and over. We do not knowingly collect personal data from anyone under 18, and we delete it if we learn that we have.
11. Changes to this policy
We will update this policy as BLACKBOOK develops, and show the date of the latest version at the top. If a change affects how we use data you have already given us, we will tell you before it takes effect.