Privacy Policy


We collect several types of information from and about users of our services, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
  • that is about you but individually does not identify you, such as your IP address, referral data, and browser and platform type; and/or
  • about your internet connection, the equipment you use to access our services and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you use our services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us.

The information we collect through our services may include:

  • Information that you provide by filling in forms through our services. This includes information provided at the time of registering to use our services, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our services.
  • Records and copies of your correspondence (including email addresses), if you contact us.

Information We Collect Through Automatic Data Collection Technologies.

As you use our services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your use of our services, including traffic data, location data, logs, and other communication data and the resources that you use on our services.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our services and to deliver a better and more personalized service.


We use information that we collect about you or that you provide to us, including any personal information:

  • To present our services and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our services.
  • To allow you to participate in interactive features on our services.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target or objective criteria.


We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect our rights, property, or for our safety, and that of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • Under certain circumstances, we may be required to disclose your personal information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
  • Black Submarine’s accountability for data it receives pursuant to the EU-US and Swiss-US Privacy Shield and subsequent transfer of that data to third parties is detailed in the Privacy Shield Principles. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US or and Swiss-US Privacy Shield, Black Submarine is potentially liable. In particular, Black Submarine remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Black Submarine proves that it is not responsible for the event giving rise to the damage. With regards to any human resources related data that may be transferred from the EU to the US in connection with or in the context of any employment relationship with a EU-based employee, Black Submarine is committed to co-operating with EU data protection authorities (or DPAs) in the relevant country regarding any such EU-based employee and comply with the advice provided by such DPAs in connection with the foregoing.


This California Privacy Rights and Disclosure section addresses the legal obligations and rights laid out in the California Consumer Privacy Act (the “CCPA”) in order to comply with the requirements set forth in the CCPA for those businesses doing business in California and/or offer their services to California residents, including with respect to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (collectively, “California Information”).

California Information We Collected and/or Shared

This section of the Policy provides the information California residents need to exercise their rights over their California Information. Here is information about the California Information we may have collected from and shared about consumers over the twelve months prior to the Effective Date of this Policy.

In the year before the date this Policy was updated, on or through some of our Services we may have collected and/or shared (for operational purposes with providers who provide services for or to us in connection with developing, improving, providing and/or offering our Services) the following categories of California Information:

  • Address and other identifiers — such as email address, device type, web-browser, operating system or other similar identifiers;
  • Unique and online identifiers — such as IP address, device IDs derived from device type, or other similar identifiers;
  • Characteristics of protected classifications — such as race, ethnicity, or sexual orientation;
  • Certain commercial information — such as products or services purchased, obtained, or considered through our Services, or other purchasing or consuming histories or tendencies;
  • Internet, gaming or other electronic network activity information — such as browsing history, search history and information regarding an individual’s interaction with an internet website, application, or advertisement;
  • Location information – geo-location information about where you are accessing our Services (e.g. if you access our Services on your mobile or tablet device we may collect information about your device’s precise location to the extent feasible);
  • Online viewing activities and habits (e.g., videos viewed, pages viewed); and
  • Inferences drawn from California Information, such as individual profiles, preferences, characteristics and behaviors.

We may have collected these categories of California Information for the following purposes:

  • Performing services on behalf of our various businesses, such as user retention, providing content recommendations and/or processing information;
  • Fraud and crime prevention;
  • Debugging errors in systems;
  • Marketing and advertising;
  • Internal research, analytics and development — e.g., user-preference analytics; and
  • Developing, maintaining, provisioning or upgrading networks, products, services, or devices.

We may have obtained California Information from a variety of sources, including:

  • Directly from you, including technical and usage information when you use our Services;
  • Linked sites, such as social media sites, and other third-party platforms;
  • Our various affiliated entities;
  • Our joint-ventures and promotional and strategic partners;
  • Information suppliers;
  • Distributors, service providers and other vendors;
  • Marketing mailing lists;
  • Other users submitting California Information about you, such as to invite you to participate in an offering, make recommendations, or share content; and Publicly available sources.


We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the services.


It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will let you know through a notice in our services. The date the privacy policy was last revised is found at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.

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