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Privacy notice

It’s always good in life to have clarity and to know where you stand with things. Here’s where we set out all of that important stuff so you know what’s what.


Black Swan respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when using our website and tell you about your privacy rights and how the law protects you.

Purpose of this privacy notice

This privacy notice aims to give you information on how Black Swan collects and processes your personal data when using our website. This process is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notices, policies or fair processing policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.


Black Swan is made up of different legal entities, including Black Swan Hungary Kft (Hungary), Black Swan Data, Inc. (United States of America), Black Swan Avionics Limited (England & Wales), Black Swan Trends Limited (England & Wales), and Black Swan Innovate Limited (England & Wales). This privacy notice is issued on behalf of the Black Swan Group so when we mention ”COMPANY”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Black Swan Group responsible for processing your data. We will let you know which entity will be the controller for your data when you engage with us. Black Swan Data Ltd is the controller and responsible for the application process.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy notice, our privacy practices or wish to exercise your privacy rights, please contact our DPO in the following ways:

Full name of legal entity: Black Swan Data Ltd

Email address:

Postal address: DPO, Black Swan, 5th Floor, The Tower Building, 11 York Road, London SE1 7NX

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to this notice and your duty to inform us of changes

We keep this privacy notice under regular review and will update it when necessary. We will not inform you of these changes unless we change why we are processing your personal data, what we need, why we need it or what we do with it.

It is important that you return to review this notice regularly to ensure that you are aware of any changes that we have made. It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Links to other websites

Where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.


When you visit, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not identify anyone.

We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

If we do collect personal data through our website, we’ll be upfront about this. We’ll make it clear when we collect personal information and we’ll explain what we intend to do with it.


You can read more about how we use cookies on our Cookies page.

Contact us

You can contact us via our website, which emails a member of the Black Swan team with the details that you entered.

Security and performance

We use updated and industry leading technology to help maintain the security and performance of our website. The technology checks that traffic to the site is behaving as would be expected, it will also block traffic that is not using the site as expected. To enable us to achieve this, we process site visitors’ IP addresses.

We host our website in the UK and hold traffic information indefinitely.

Purpose and legal basis for processing

Our purpose for processing this information is to maintain and monitor the performance of our website and to constantly look to improve the site and the services it offers to our users. The legal basis we rely on to process your personal data is article 6(1)(f) of the GDPR, which allows us to process personal data when its necessary for the purposes of our legitimate interests.

Our purpose for collecting the information for “Contact us” is so that we can provide you with a service.

The legal basis we rely on for processing your personal data is your consent under article 6(1)(a) of the GDPR.

What will we do with the information you give us?

We will use the information that you give to us via “Contact us” for the purpose dealing with your enquiry effectively.

What information do we ask for, and why?

We do not collect more information than we need to fulfil our stated purposes and will not keep it longer than necessary.

The information we ask for is used to deal with your enquiry effectively.

How long is the information kept for?

We keep all email correspondence indefinitely due to our legal commitments in the US to ensure compliance with US Legislation.

Do we use any data processors?


International processing

We will process your personal data within the Black Swan Group. This will involve processing your data outside the European Economic Area (EEA). We will process your personal information from our offices in the UK, USA, EU and South Africa.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Protection Officer.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Your rights

As we are processing your personal data for our legitimate interests as stated above, you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.

Your right of access

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about this right here.

Your right to rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances. You can read more about this right here.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here.

Your right to object to processing

You have the right to object to processing if we can process your information because the process forms part of our public tasks or is in our Legitimate Interests. You can read more about this right here.

Your right to data portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about this right here.

If we are processing your information for criminal law enforcement purposes, your rights are slightly different. Please see the relevant section of the notice.

You are not required to pay any charge for exercising your rights. We have one month to respond to you. Please contact our DPO if you wish to make a request.