BlackMINE, LLC (collectively “BlackMINE” or “We,” “Us,” or “Our”), have created this Privacy Policy to explain how we collect, use and share information we obtain through our websites. Because the Internet is global, information about you that we collect or that you submit may be transferred to, processed in, and held in countries (including the United States) other than the one in which you reside. By using the Internet you explicitly consent to such use of your information and agree to the terms of this Privacy Policy.

Information you Submit:  To obtain access to the Sites and to receive certain Internet Services, you may be required to login and provide certain personal data and information about yourself (“Personal Data”). We use Personal Data to fulfill requests for Internet Services, as well as other products and services (together, the “Services”).

Information we Collect: We may collect certain information to help us understand how you use the Internet Services (which we will refer to in this Privacy Policy collectively as “Usage Data”). For example, each time you visit the Sites we may automatically collect your IP address, browser and computer type, access time, the webpage from which you came, and the webpage(s) that you access during your visit.

Information Sharing Practices: Generally, except as otherwise described in this section of our Privacy Policy, we will not share your Personal Data or Usage Data (which we will refer to in this Privacy Policy collectively as “User Information”) with any third party without your permission.

Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf, these third-party service providers have access to personal information needed to perform their functions, but we require that they not use personal information for other purposes. Personal data is not shared with any unaffiliated third-parties for their marketing purposes.

Other Disclosure Scenarios. Notwithstanding anything in this Privacy Policy to the contrary, we reserve the right, and you hereby expressly authorize us to, share any User Information: (1) in response to subpoenas, court orders, regulatory requests or legal process, or to establish, protect, or exercise our legal rights and interests or defend against legal claims; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding inappropriate or illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent, or take action regarding abuse of the Sites infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information); (4) to our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); (5) as part of a corporate transaction with a successor or affiliate or in connected with any acquisition, merger, or sale of assets; or (6) with third parties who provide services to us; provided, however, that in those circumstances we request that our service providers not share your User Information in a manner inconsistent with this Privacy Policy.

Modifying/Deleting Your Personal Data:  If you would like to modify any Personal Data you previously submitted to us, please let us know by contacting your account representative or by accessing and updating your profile. Please note that any Personal Data that we have copied may remain in back-up storage. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law or regulation.

Privacy Notices: We must comply with SEC Regulation S-P, which requires registered advisers to adopt procedures to protect the “nonpublic personal information” of customers and to disclose to such persons policies and procedures for protecting that information.

BlackMINE places strong emphasis on your privacy and the importance of safeguarding client’s nonpublic personal information (“Personal Information”).  Personal Information is information we obtain in connection with providing our investment management services.

This notice outlines our privacy policy and describes how we use Personal Information.

Information We May Collect:

As part of our investment management business, we may gain access to Personal Information through:

• Information we receive from our investment management agreements;

• Subscription documents or other forms;

• Information about transactions with us, our affiliates or others; and

• Information we receive from non-affiliated third parties.

 

Information We May Disclose:

BlackMINE does not share any nonpublic personal information with nonaffiliated third parties, except, in the following circumstances:

• To provide services to our clients, as requested;

• To service our client’s accounts;

• As required by regulatory authorities or law enforcement officials;

• As otherwise required by applicable law;

• To the extent reasonably necessary to prevent fraud and unauthorized transactions.

 

Confidentiality and Security:  BlackMINE restricts access to nonpublic personal information to those employees who need to know such information in order to provide services to our clients. Employees are aware of the sensitivity of the treatment of nonpublic personal information.  An employee is permitted to disclose nonpublic personal information only to such other employees who need to have access to such information. Employees who are authorized to have access to nonpublic personal information keep such information in a secure location. Conversations regarding nonpublic personal information must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.

Initial and Annual Privacy Notices:  BlackMINE shall provide initial privacy notices upon the establishment of a relationship with our clients, whenever material changes are made to the policy and on an annual basis.

This policy applies to current and former clients of the firm.

Security:  We have implemented reasonable measures to help protect your User Information from loss, misuse, or unauthorized access or disclosure. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your User Information, we cannot guarantee its security.

Changes:  We may update this Privacy Policy from time to time. If under any such update we make any material change to the way in which we treat your User Information, we will inform you of such change by posting a notice on relevant areas of the Sites. Any updated version of this Privacy Policy will be effective as of the date set forth therein.