Privacy Policy


California residents should refer to our California Section below, which supplements this Privacy Policy.

Residents of the United Kingdom and the European Union should refer to our EU & UK Section below, which supplements this Privacy Policy. 

Your privacy is important to Blackpoll Capital Partners, LLC and its affiliates (collectively, “Blackpoll,” “our,” “us” or “we”).  This Privacy Policy provides you with information about our policies and practices with respect to information collected in association with our website,

Please read this Privacy Policy carefully. If you object to the policies and practices described herein, please do not access or otherwise use this website.


We collect various types of information in association with the operation of the website.  That information may include:


We collect personal information in the following ways:

We may combine any of the information we collect. 


We and third-party providers use cookies, pixels, web beacons, and similar technologies to learn about your access to and use of the website.  These technologies collect information about your device and browser types, access times, content viewed, search terms made, IP address, and other network connection information.  We use the information for the purposes described below.  You may wish to visit,  which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences. 


We use the information we collect for the following purposes:


We share personal information within the Blackpoll. 

We share personal information with service providers that we engage to perform services on our behalf, such as entities that provide data storage services, email and other communications vendors, security and information technology vendors, entities that provide us with marketing or analytics services, consultants, and advisors. 

We share personal information with government entities and others to comply with legal requirements.  We may disclose personal information in response to valid legal process or reasonable requests when, as determined in our sole discretion, such disclosure will reasonably protect the safety or rights of us, you, or others.

We may share personal information with third parties in the event of an actual or potential reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business or assets.


We subject the personal information we collect to safeguards designed to reduce the risks of loss, misuse, unauthorized access, unauthorized disclosure, and alteration.  However, no information system and no networks transmissions are completely secure. We cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.


We reserve the right to amend this Privacy Policy from time to time and for any reason.  We encourage you to review this Privacy Policy regularly. If we decide to change this Privacy Policy, we will post the updated version here.  And we may provide you with notice of changes via email or other channels.   


If you have questions about our policies or practices, or wish to exercise rights you may have, please email us at:


Please read the Policy above for general information about our collection, use, and disclosure practices with respect to personal information collected in association with the website. 

We do not sell any of the personal information we collect about you to third parties.

We share all of the categories of information noted in the “Information We Collect” section with members of the Blackpoll and service providers.  And we may, on occasion, share personal information with government entities, consultants, advisors and others. 


Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.  We may, however, provide a different level of service where that is reasonably related to the value of your personal information impacted by the exercise of your rights. 

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or those of a California resident for whom you are submitting a request, email us at  We will ask you to provide the name and contact information that the requestor provided to us to verify the requestor’s identity based on the information available to us, and we may request additional information as reasonably necessary to verify the request.  Authorized agents submitting requests on behalf of others must provide evidence of the requestor’s signed, written permission. 



Please read the general content above for information about our collection, use, and disclosure practices with respect to personal information collected in association with the website. 

For the purposes of applicable United Kingdom, European Union, and European Economic Area laws, Blackpoll Capital Partners, LLC is the data controller of any personal information collected by us.  If you have any questions regarding our use of your personal data, or this EU Website Privacy Policy, please contact us at

We rely on various legal bases under applicable data protection legislation in order to process your personal information. 

We process information as necessary to enter into contracts with you or to fulfill our contractual obligations when we:

We process information for compliance purposes when we:

And we process personal information for our legitimate interests in operating, maintaining and expanding our business when we:

When we process personal information to meet our legitimate interests, we put in place safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

If we require you to provide certain personal information due to legal or contractual requirements, we will inform you at the time of collection and inform you about the consequences of not providing such information. 

We retain keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by applicable law.


Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy. 

We seek to ensure that anyone who provides a service to, or for us, involving personal information enters into an agreement with us and meets our standards for data security. To the extent your personal information is transferred from within the UK, EU, or EEA to countries outside of the UK, EU and EEA that are not deemed to provide adequate protections for personal data, we take steps to put safeguards in place to for the personal information transferred, such as entering into European Commission approved standard contractual clauses.  For further information about the safeguards used, please contact us at


You may have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please email us at:

We may need to request specific information from you to help us confirm your identity.  And we may contact you to ask you for further information in relation to your request to speed up our response.


If you have any questions or concerns about this Privacy Policy, please contact us at: or Blackpoll Capital Partners, LLC, 1717 Pennsylvania Avenue NW, Suite 1025, Washington, D.C., 20006.