Privacy Notice

Version: blackglass-legal-effective-2026-07-12-hk
Effective date: 12 July 2026

Operator

Blackglass is operated by SLSBMB Limited, a limited company incorporated in Hong Kong ("SLSBMB", "we", "us"). This Notice is issued by SLSBMB as the operator of the Blackglass public site, private preview, intake, Contact Search and Contact Pack, AI Market Scan, Sending Engine, Client Hub commerce, invoice, receipt, and support flows.

We keep the public legal surface intentionally minimal. Company-registration detail, billing-entity detail, tax identifiers, banking coordinates, and transaction-specific payment data are not published here; they appear only in the buyer-facing invoice, receipt, order, or Client Hub commerce artifact issued for a specific purchase. Privacy and data-subject requests may be sent to a@slsbmb.com.

Scope And Roles

This Notice covers personal data we process to operate Blackglass. Depending on the processing, SLSBMB acts either on the documented instructions of a business buyer (processor) or as an independent controller for billing, audit, legal acceptance, security, abuse prevention, platform safety, provider-spend control, suppression evidence, and deliverability protection. The buyer remains the controller of buyer-provided campaign purposes, recipient targeting, and exported-contact use unless SLSBMB has explicitly accepted a managed Sending Engine role for a specific workspace and scope.

Data We Process

How We Use Data

We use data to operate Blackglass; prepare market research; generate buyer-requested contact intelligence; issue invoices; process and reconcile payments; provide Client Hub access; prevent abuse; enforce legal and safety boundaries; preserve audit evidence; and support customers. We may contact you about your intake, order, invoice, payment, delivery, support request, or related business relationship.

What We Do Not Do

Lawful Basis

Where a lawful basis is required, we process buyer and operational data on the basis of contract performance, legitimate interests in operating and securing the service, legal obligation, and, where applicable, consent. Public or business-contact information is not compliance-free: direct-marketing, privacy, unsubscribe, suppression, objection, and data-rights obligations depend on the buyer, recipient, channel, and jurisdiction, and remain the buyer's responsibility for campaign use as set out in the Outbound Compliance Policy, which owns the canonical buyer-responsibility terms.

Sharing And International Transfers

We use service providers for hosting, database, storage, email delivery, payment processing, AI, search and enrichment, monitoring, and support, as described on the Subprocessors and Providers page. We do not publish provider identities or internals on this public page. Because SLSBMB operates from Hong Kong and uses providers located in multiple jurisdictions, personal data may be processed, stored, or transferred outside the jurisdiction where it was collected. We rely on contractual, operational, and technical controls appropriate to the destination.

Retention

We keep personal data only as long as needed for the purposes above and for business records, security, auditability, legal claims, compliance, payment reconciliation, and service delivery. Raw first-party site-usage signals are retained for a limited operational period (90 days by default) and may later be kept only as aggregate counters. We may retain records where required or permitted for legal, audit, payment, security, suppression, or dispute reasons.

Your Rights

Where applicable law grants access, correction, deletion, restriction, objection, or portability rights, you may exercise them by contacting a@slsbmb.com. We respond in line with the obligations that actually apply to the relevant data and jurisdiction, and we may decline requests where retention is required or permitted for legal, audit, payment, security, or dispute reasons, or where the request concerns data we process on a buyer's instructions and is properly directed to that buyer.

Accuracy And Allocation

Contact intelligence, market scans, and AI outputs may be incomplete, outdated, duplicated, inaccurate, suppressed, or unsuitable for an intended use. We provide them as-is and as-available; they are informational business-research outputs, not legal, compliance, tax, financial, or other professional advice. The buyer is responsible for reviewing fitness, accuracy, recipient relevance, and lawful use before acting. The disclaimers, exclusion of consequential damages, aggregate liability cap, indemnity, and governing-law terms in the Terms of Service apply to this Notice and to all processing it describes.

Security

We use reasonable technical and organizational measures to protect personal data against unauthorized or accidental access, processing, erasure, loss, or use. Detail is on the Security page; security concerns may be sent to a@slsbmb.com.

Changes

We may update this Notice for future orders. The version recorded at order acceptance governs the related order unless a later written agreement says otherwise.

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