PRIVACY POLICY

BlackVault Management LLC
Last updated: 13/12/2025

1. Introduction

BlackVault Management LLC (“BlackVault”) respects the privacy of its clients and processes personal data in accordance with applicable privacy principles, including GDPR-aligned standards for international clients.

This policy describes:

• what data we collect
• how and why we process it
• with whom it may be shared
• how long it is retained
• user rights

2. Data Collected

We may collect and process:

Identification data

• passport / ID documents
• proof of address
• IRS forms (W-7, SS-4, BOI, etc.)
• signatures

Contact information

• email address
• phone number

Corporate information

• company documents
• ownership structure
• UBO data
• business activity descriptions

Compliance Information

• KYC/KYB documentation
• AML risk assessments

Technical Data

• website usage logs
• IP address
• device and browser information

3. Legal Basis & Purpose of Processing

We process personal data for purposes including:

• service delivery and execution
• corporate formation and filings
• IRS administrative assistance (EIN, ITIN/CAA, BOI)
• compliance with AML/KYC requirements
• communication with clients
• maintaining legal records

We only collect what is necessary for the services requested.

4. Data Sharing

Data may be shared only as necessary with:

• Payment processors (e.g., Stripe)
• Service delivery infrastructure (e.g., hosting, email)
• Compliance platforms
• External authorities (IRS, state registries, free zones, etc.)
• Third-party providers involved in administrative processes

BlackVault does not sell personal data.

5. International Transfers

Because BlackVault operates across multiple jurisdictions, data may be transferred internationally.
We take reasonable measures to ensure appropriate data protection, regardless of location.

6. Data Retention

Data is retained only as long as necessary to meet:

• legal obligations
• compliance requirements
• administrative record-keeping

Retention periods may vary depending on jurisdiction and service type.

7. Security Measures

We implement appropriate technical and organizational security measures to protect data from unauthorized access, disclosure or misuse.

8. User Rights

Where applicable (e.g., GDPR jurisdictions), users may request:

• access to their data
• correction of inaccurate data
• deletion (where legally permissible)
• restriction or objection to processing

Requests can be made to:
contact@blackvaultstrategies.com

9. Children’s Privacy

Services are intended for clients 18 years or older, unless expressly and exceptionally approved.

10. Updates to This Policy

BlackVault may modify this Privacy Policy to reflect changes in regulations or operations.