Privacy Policy

We operate The Black Book, a private, invitation-based membership community. For any privacy-related queries, please contact us at waitlist@theblackbook.club

2.1 Information You Provide Directly

• Identity information: full legal name, date of birth, nationality, passport or Emirates ID details, and photograph;
• Application and due diligence information: professional background, business affiliations, references, source of wealth and source of funds documentation, and any other information submitted as part of our membership application, due diligence, or background screening process;
• Contact information: email address, phone number, and mailing address;
• Communications: messages, enquiries, or feedback you send to us;
• Payment information: billing details submitted in connection with the Annual Membership Fee or Event costs — these are processed by our third-party payment processor and we do not store full card or bank details on our own systems;
• Event and guest information: dietary requirements, travel details, and information you provide about any Guest you invite to an Event.

2.2 Information Collected Automatically

• Device and technical data: IP address, browser type and version, operating system, and device identifiers;
• Usage data: pages viewed, features used, referral URLs, and timestamps;
• Cookies and similar technologies: see Section 8 for full details.

2.3 Information From Third Parties

We receive information about you from: (a) the Member who referred or invited you; (b) third-party due diligence, identity verification, and sanctions/AML screening providers; (c) event operators, venues, and travel providers, in connection with your attendance at Events; and (d) publicly available sources, as part of our due diligence process. We do not purchase personal data from data brokers for marketing purposes.

2.4 Photography and Video

We, or photographers and videographers we appoint, may capture photography and video of you at Events, as described in our Membership Agreement.

3.1 Legal Bases for Processing

Where applicable law requires a legal basis for processing (including under the DIFC Data Protection Law, the GDPR, and similar frameworks), we rely on the following:

• Contract: processing necessary to assess your application and administer your Membership;
• Legitimate interests: due diligence, security, fraud prevention, and protecting the reputation and exclusivity of the Club, where these interests are not overridden by your rights;
• Legal obligation: compliance with applicable AML, sanctions, and other regulatory requirements;
• Consent: where you have provided explicit consent, including for certain photography use and marketing communications.

If you provide your phone number, you consent to receive communications from us via WhatsApp, SMS, or similar messaging channels, including Event notifications, account-related alerts, and, where you have opted in, limited promotional communications.

Opt-out: you may withdraw consent at any time by contacting us at waitlist@theblackbook.club. We do not use your messaging data for any purpose other than delivering these communications, and it is never shared with third parties for advertising profiling.

We do not sell your personal information. We may share it only in the following circumstances:

5.1 Service Providers

We engage carefully selected third parties to support the Club, including: identity verification and due diligence providers; payment processors; event operators, venues, and travel providers; hosting and IT infrastructure providers; and communications and customer relationship tools. These providers are contractually bound to process personal data only as instructed by us and only to the extent necessary to provide their services.

5.2 Other Members and Guests

Limited information (such as your name, professional background, and photograph) may be made available to other Members through the Member Directory, and to Event operators as necessary to facilitate your attendance, in each case as described in the Membership Agreement.

5.3 Legal and Regulatory Requirements

We may disclose personal information where we reasonably believe disclosure is required to: (a) comply with applicable law, regulation, or legal process, including AML and sanctions reporting obligations; (b) respond to a lawful request from a governmental or regulatory authority; or (c) protect the rights, property, or safety of the Company, our Members, or the public.

5.4 Business Transfers

In the event of a merger, acquisition, financing, reorganisation, or sale of all or substantially all of our assets, personal information may be transferred to the acquiring or successor entity, with notice provided where required by applicable law.

5.5 With Your Consent

We may share your information in other ways where you have provided explicit prior consent.

We retain personal information for as long as reasonably necessary to fulfil the purposes described in this Policy, including for as long as your Membership remains active, and thereafter for as long as required to comply with legal, regulatory, AML, tax, or accounting obligations, or to enforce our agreements and resolve disputes. Due diligence records relating to unsuccessful applications and former Members are retained for a reasonable period in accordance with our internal retention schedule and applicable AML record-keeping requirements. When personal information is no longer required, we delete or anonymise it.

Subject to applicable law, you may have the right to: access a copy of the personal information we hold about you; request correction of inaccurate or incomplete information; request erasure, subject to legal and AML retention requirements; request restriction of processing in certain circumstances; object to processing based on legitimate interests; request a portable copy of information you have provided; and withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at waitlist@theblackbook.club. We may need to verify your identity before processing your request. We will not discriminate against you for exercising your privacy rights.

We use cookies and similar technologies to operate and improve the Site:

• Strictly necessary cookies: required for core functionality, such as security. These cannot be disabled.
• Analytics cookies: help us understand how visitors interact with the Site.
• Functional cookies: remember your preferences.
• Marketing cookies: used to measure the effectiveness of communications, where you have consented.

You can manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Site.

We operate from the United Arab Emirates, and personal information may be stored and processed in the UAE and other jurisdictions where our service providers or Event operators are located. Where transfers of personal information from the European Economic Area, United Kingdom, or Switzerland to third countries are required, we implement appropriate safeguards, including Standard Contractual Clauses approved by the European Commission or other legally recognised transfer mechanisms.

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorised access, disclosure, alteration, and destruction, including encryption of data in transit and at rest and access controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a data breach likely to result in a risk to your rights and freedoms, we will notify you and any applicable regulatory authority as required by law.

The Services are not directed to, and are not intended for use by, individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child under 18, please contact us immediately at waitlist@theblackbook.club and we will take steps to delete it promptly.

If you are located in the European Economic Area or United Kingdom, the Company acts as a data controller in respect of personal information processed in connection with the Services. You have the rights described in Section 7 above and may lodge a complaint with your local supervisory authority if you believe your rights have been infringed. Our legal bases for processing are set out in Section 3.1.

The Site may contain links to third-party websites or services. This Privacy Policy does not apply to those sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will update the "Last Updated" date and, where appropriate, provide additional notice by email. Your continued use of the Services after any update constitutes acceptance of the revised Policy. If you do not agree, you must discontinue use of the Services.

This Privacy Policy is governed by the laws applicable in the DIFC, Dubai, United Arab Emirates, consistent with our Terms of Service and Membership Agreement.

If you have any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us at:

waitlist@theblackbook.club

We aim to respond to all privacy-related enquiries within 30 days.