Privacy Policy

NEW BLACK B.V.

Privacy Policy

Version: October 2026

1. Responsible New Black Entity

New Black B.V. is the controller of your Personal Data as described in this Privacy Statement, unless specified otherwise.

Registered address: W.T.C. Almere, 29th floor, P.J. Oudweg 4, 1314 CH Almere, The Netherlands

Chamber of Commerce (KvK): 64148793

Privacy Contact: legal@newblack.io


This Privacy Statement does not apply to the extent we process Personal Data in the role of a processor or service provider on behalf of our customers, including where we offer to our customers various cloud products and services through which our customers (or their affiliates): (i) create their own websites and applications running on our platforms; (ii) sell or offer their own products and services; (iii) send electronic communications to others; or (iv) otherwise collect, use, share or process Personal Data via our cloud products and services.

For detailed privacy information related to a New Black customer or a customer affiliate who uses New Black cloud products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Statement. For more information, please also see Section 10.3 below.

2. Processing Activities Covered

This Privacy Statement applies to the processing of Personal Data collected by us when you:

  • Visit our websites that display or link to this Privacy Statement
  • Visit or interact with our branded social media pages
  • Visit our offices
  • Receive communications from us, including emails or other correspondence
  • Are a contact person at one of our customers, partners or suppliers
  • Register for, attend, or take part in our events, webinars, or contests
  • Participate in community and open-source development
  • Register for or participate in our Nerd Community, Brand Community Program, or related loyalty and rewards initiatives operated by New Black
  • Create an account on or use our New Black portal, including its documentation, AI Chat and expert session booking
  • Download or use our mobile applications


We also host a number of demand generation, joint marketing, joint development, and community platforms that run on New Black infrastructure and may be provided by us or by third parties. When applications on those platforms are provided by us and link to this Privacy Statement, this Privacy Statement applies. When applications are provided by third parties, the privacy statement of that third party applies and this Privacy Statement does not.

When you visit or interact with our branded pages on social media platforms, such as LinkedIn and YouTube, the platform provider collects information about your activity and may provide us with aggregated statistics about how people engage with our pages. For some platforms, such as LinkedIn, New Black and the platform provider act as joint controllers for the processing used to create these statistics. In those cases, the platform provider has primary responsibility for this processing and for handling related rights requests, as described in its own privacy statement and joint controller terms. For LinkedIn, these are available at https://legal.linkedin.com/pages-joint-controller-addendum. You may also contact us, and we will forward your request where appropriate.

Our websites and services may contain links to other websites, applications, and services maintained by third parties. The information practices of those services, or of social media platforms that host our branded social media pages, are governed by their own privacy statements, which you should review to better understand their privacy practices. More information about some of our specific services is set out in the subsections below.

2.1 Nerd Community and Brand Community Program

We operate the Nerd Community website and related Brand Community initiatives designed to foster engagement, reward participation, and provide loyalty benefits, badges, and other recognition features. When you register for or participate in these programmes, we process your Personal Data to create and manage your membership profile, administer loyalty and reward activities, communicate with you about your participation, and personalise your experience. We may also invite or pre-enroll individuals who have previously signed up to receive communications from New Black into the Nerd Community or Brand Community Program. In such cases, we will provide clear notice of this enrolment and offer a simple and accessible means to opt out or decline participation at any time.

2.2 Mobile Applications

We offer mobile applications, including the Nerd Community app, that link to this Privacy Statement. When you use our apps, we process your Personal Data to provide the app and your account, deliver the features you use, send notifications you have enabled, keep the app stable and secure, understand how the app is used so we can improve it, and personalise your experience. Our apps use software development kits (SDKs) from third-party providers to support functions such as analytics, crash reporting and notifications. You can manage notifications and device permissions at any time through your device settings.

3. What Personal Data Do We Collect?

3.1 Personal Data we collect directly from you

The Personal Data we collect directly from you includes identifiers, professional or employment-related information, commercial information, visual information, and internet activity information. We collect such information in the following situations:

  • If you express an interest in obtaining additional information about our services, request customer support, register to use our websites, sign up for an event, webinar or contest, or download certain content, we may require your contact information such as your name, job title, company name, address, phone number, email address, or username and password.
  • If you are a contact person at one of our customers, partners or suppliers, we collect your business contact details, such as your name, job title, company, work email address and phone number, together with information arising from our business relationship, such as contract signatures, correspondence, meeting notes and billing details.
  • If you attend an event, we may, with your further consent, scan your attendee badge, providing us with your name, title, company name, address, country, phone number and email address. We may also take photographs, make audio or video recordings and collect quotes.
  • If you attend or speak at our events or webinars, or take part in a customer story, testimonial or case study, we may take photographs, make audio or video recordings, and collect quotes, which may include your name, job title, company, image and voice.
  • If you follow, comment on, message or otherwise interact with our social media pages, we receive your public profile information and the content of your interaction.
  • If you register for an online community or collaboration platform that we host, we may ask you to provide a username, photo or other biographical information such as your occupation, location, social media profiles, company name, areas of expertise and interests.
  • If you register for or participate in the Nerd Community, Brand Community Program, or related loyalty and rewards initiatives, including through our mobile app, we collect your name, email address, and other information you voluntarily provide to create and manage your community account, award points, badges, or rewards, track engagement activity, and communicate with you about your participation.
  • If you redeem rewards or benefits associated with the programme, we may process additional information necessary to deliver or verify your rewards.
  • If you interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails using cookies, web beacons, or similar technologies, see Section 4 below.
  • If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request.
  • If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.


If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Statement.

3.2 Personal Data we collect from other sources

We also collect information about you from other sources, including publicly available information. We may combine this information with Personal Data provided by you to keep our records accurate and up to date. We collect such Personal Data from the following sources:

  • Another individual at your organisation who provides us with your business contact information for the purposes of obtaining services.
  • Platforms such as GitHub, if you participate in an open source or community development project — we may link your code repository username to your community account to keep you informed about changes to the programme.

4. What Device and Usage Data Do We Process?

We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.

4.1 Device and usage data

When individual users visit our websites, we gather certain information automatically. This may include IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, internet service provider and/or mobile carrier, pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits.

In addition, we automatically collect technical information when you use our cloud products and services, including our mobile apps, community website and New Black portal. This may include IP address, device and application identifiers, approximate location (for example derived from your IP address), browser type, internet service provider or mobile carrier, the pages and features you use, actions you take, operating system and system configuration, and date and time stamps. We use this information to keep our services secure, provide their functionality, improve performance and user experience, check compliance with usage terms, plan capacity and identify customer opportunities. This does not include the content that customers and their users enter into our services, which we process on the customer's behalf as described in Section 10.3.

4.2 Cookies, web beacons and other tracking technologies

We use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather information about the use of our websites and how people interact with our emails. Cookies allow us to track use, infer browsing preferences, and improve and customise your browsing experience. We use both session-based and persistent cookies.

Full details of the cookies we use, including categories, purposes, and how to manage your preferences, are set out in our Cookie Statement at newblack.io/cookie-statement. You can manage your cookie preferences at any time by clicking the Cookie Preferences link in the footer of newblack.io.

4.3 Mobile Applications

When you use our mobile apps, we collect your device type, operating system and app version, device and notification identifiers, crash and performance data, and information about how you use the app, such as the features and content you interact with. This data is collected through software development kits (SDKs) built into the app rather than cookies. You can limit it through your device settings, or by uninstalling the app. If you allow location access in our app, we also collect your device's location, which we use to send you notifications relevant to where you are, for example about events near you. We share it with our notification provider so it can target those notifications. You can turn this off at any time in your device settings or by deleting the app, and the app works without it.

We collect and process your Personal Data for the following purposes. Where required by law, we obtain your consent. Otherwise, we rely on a valid legal basis as set out below.

Purpose

Legal Basis

Specific Legitimate Interest (where applicable)

Providing and operating our websites and services, including necessary functionality and user accounts

Contract (Art. 6(1)(b)) / Legitimate interests (Art. 6(1)(f))

Operating and administering our websites and services, providing the functionality users need, and giving users access to the content they request

Security of our websites and services

Legitimate interests (Art. 6(1)(f))

Promoting safety and security of our services, systems and applications and protecting our rights and those of others

Handling contact and support requests

Contract (Art. 6(1)(b)) / Legitimate interests (Art. 6(1)(f))

Fulfilling user requests and maintaining effective communication with people who contact us

Entering into and managing agreements with customers, partners and suppliers, including account management, service delivery and partner collaboration

Legitimate interests (Art. 6(1)(f))

Entering into, performing and administering agreements with the organisations we do business with, maintaining effective working relationships with their contact persons, and working with partners on joint projects, integrations and go-to-market activities

Invoicing, payments and financial administration

Legal obligation (Art. 6(1)(c)) / Legitimate interests (Art. 6(1)(f))

Managing our finances and complying with tax and accounting obligations

Managing event registrations and attendance

Contract (Art. 6(1)(b))

—

Operating the Nerd Community and Brand Community Program

Legitimate interests (Art. 6(1)(f)) for running your membership. Consent (Art. 6(1)(a)) for optional features such as notifications, location and marketing

Fostering community engagement, strengthening customer relationships, and enhancing our products and services

Managing contests and promotions

Contract (Art. 6(1)(b))

—

Developing and improving our websites and services, including user experience and capacity planning

Developing and improving our websites and services, including user experience and capacity planning

Developing and improving our websites and services, including user experience and capacity planning

Reviewing compliance with applicable usage terms

Legitimate interests (Art. 6(1)(f))

Ensuring customers and users adhere to contractual terms governing use of our services

Identifying customer opportunities

Legitimate interests (Art. 6(1)(f))

Understanding market demand and ensuring we develop products and services that meet customer needs

Registering office visitors

Legitimate interests (Art. 6(1)(f))

Protecting our offices and confidential information against unauthorised access

Displaying personalised content and advertising

Consent (Art. 6(1)(a))

—

Operating our social media pages and analysing page statistics

Legitimate interests (Art. 6(1)(f))

Communicating with our audience and understanding how our content performs

Photographing and recording events and webinars, and publishing this content

Legitimate interests (Art. 6(1)(f))

Documenting and promoting our events and sharing their content with our community

Publishing testimonials, case studies, speaker profiles and other content featuring identifiable individuals

Consent (Art. 6(1)(a))

—

Sending marketing communications

Consent (Art. 6(1)(a)). Legitimate interests (Art. 6(1)(f)) only for existing customers, about similar products and services, where applicable law allows

Keeping existing customers informed about similar products and services

Sending push notifications through our mobile apps, including notifications based on your location if you allow location access

Consent (Art. 6(1)(a))

—

Providing the AI Chat assistant on our New Black portal

Legitimate interests (Art. 6(1)(f))

Giving users fast, self-service answers to questions about our products

Complying with legal obligations

Legal obligation (Art. 6(1)(c))

—


Where we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you or provide the services you have requested. We will make clear at the point of collection whether providing particular data is mandatory or optional.


Where we rely on legitimate interests as our legal basis, you have the right to object to that processing at any time — see Section 10. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Who Do We Share Personal Data With?

New Black does not sell your Personal Data. We may share your Personal Data as follows:

Service Providers

With our contracted service providers, who provide services such as IT and system administration and hosting, payment processing, AI services, app analytics, crash reporting and notification services, research and analytics, marketing, and customer support, for the purposes and pursuant to the legal bases described above. Such service providers comprise companies located in the countries in which we operate. A current list of our sub-processors is available at trust.newblack.io.

Affiliates

If you use our websites to register for an event or webinar organised by one of our affiliates, we may share your Personal Data with that affiliate to the extent required to process your registration and ensure your participation. In such instances, our affiliate will process the relevant Personal Data as a separate controller and will provide you with further information on their processing of your Personal Data where required.

Event Sponsors

If you attend an event or webinar organised by us, we may share your Personal Data with sponsors of the event where you have given specific consent via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors' own privacy statements. If you do not wish for your information to be shared, you may opt out during registration or decline to have your badge scanned.

Contest and Promotion Sponsors

With sponsors of contests or promotions for which you register, to the extent necessary to administer the contest or promotion.

Third-Party Networks and Advertising Platforms

With third-party social media networks, advertising networks and websites, so that New Black can market and advertise on third-party platforms and websites. This sharing is subject to your consent.

Social Media Platforms

When you interact with our social media pages, the platform provider processes your Personal Data under its own privacy statement. Where we act as joint controllers with a platform provider, we do so under the joint controller arrangements provided by that platform.

App Store Providers

When you download our mobile apps, the app store provider processes your Personal Data under its own privacy statement.

Third-Party Community Partners

In relation to our demand generation and community platforms, if you choose to interact with or use third-party tools, we may share your Personal Data with our third-party partners who may contact you regarding their products or services.

New Black Group Companies

With affiliates within the New Black group and companies that we acquire in the future after they are made part of the New Black group, to the extent such sharing of data is necessary to fulfil a request you have submitted via our websites or for customer support, marketing, technical operations and account management purposes.

Third Parties Involved in a Corporate Transaction

If we are involved in a merger, reorganisation, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party, your Personal Data may be transferred to that third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.

Anonymised and Aggregated Data

We may share anonymous or de-identified usage data with our service providers for analysis and improvement purposes, and on an aggregate basis in the normal course of operating our business.

Community and Public Forums

Anyone using our communities, forums, blogs, or chat rooms on our websites may read any Personal Data or other information you choose to submit and post. Please be mindful of what you share in public community spaces.

Published Content

Photographs, recordings, testimonials, case studies and speaker content may be published on our websites, social media channels and marketing materials, where they are visible to the public.

Legal and Regulatory Disclosures

We may disclose your Personal Data to courts, law enforcement authorities, regulators, or other public bodies where we are legally required to do so. Where permitted by law, we will notify you of any such request. We will only disclose the minimum amount of data necessary to comply with the legal obligation, and we will challenge requests we believe to be unlawful. We may also disclose data where we reasonably believe it is necessary to protect the rights, property, or safety of New Black, our customers, or others.

7. International Transfer of Personal Data

New Black is based in the Netherlands. Your Personal Data may be collected, transferred to and stored by us or our affiliates and third-party service providers in countries outside the EEA.

Where Personal Data is transferred outside the EEA to countries not subject to an adequacy decision by the European Commission, we ensure that an adequate level of protection is in place through one or more of the following safeguards:

  • Standard Contractual Clauses (SCCs) approved by the European Commission under Implementing Decision (EU) 2021/914 of 4 June 2021
  • Adequacy decisions — where the European Commission has determined that the destination country provides an adequate level of data protection

United Kingdom: For transfers of Personal Data subject to UK GDPR, we use the safeguards required under UK law, such as the UK Addendum to the EU Standard Contractual Clauses.

Where required by applicable law, we will only share, transfer or store your Personal Data outside of your jurisdiction with appropriate safeguards in place or, where required, with your prior consent.

You may request details of the specific transfer mechanism applicable to your data by contacting us using the details in Section 13.

8. Children

Our websites and apps are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us using the information in Section 13 and we will take steps to delete their Personal Data from our systems.

9. How Long Do We Keep Your Personal Data?

We retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following periods apply:

Category of Data

Retention Period

Basis

Website visitor and analytics data

For as long as your account exists. Automatically deleted when you delete your account. If you don't have an account, until 24 months after your last visit to our website. Aggregated statistics that don't identify you may be kept longer.

Consent

Mobile app notification and location data (notification identifiers and, if you allow it, device location)

For as long as your account exists. Automatically deleted when you delete your account.

Consent

Business relationship contact data (customers, partners, suppliers)

For the duration of the business relationship.

For the duration of the business relationship.

New Black Portal AI Chat Conversations

For as long as your New Black Portal Account exists. Automatically deleted when the account is deleted.

For as long as your New Black Portal Account exists. Automatically deleted when the account is deleted.

Support and correspondence records

For the duration of the business relationship.

Legitimate interests

Legal, financial, and compliance records

7 years

Legal obligation


10. Your Rights Relating to Your Personal Data

10.1 Your rights

You may have the following rights relating to your Personal Data, subject to local data protection laws:

  • Right of access: you may request a copy of the Personal Data we hold about you and information about how we process it.
  • Right to rectification: you may request correction of inaccurate or incomplete Personal Data.
  • Right to erasure: you may request deletion of your Personal Data where there is no longer a lawful basis for processing, also referred to as the right to be forgotten, to the extent permitted by applicable law.
  • Right to restriction: you may request that we limit processing of your Personal Data in certain circumstances, for example while the accuracy of data is contested.
  • Right to data portability: you may receive your Personal Data in a structured, commonly used, machine-readable format and request that it be transmitted to another controller where processing is based on consent or contract.
  • Right to object: you may object to processing based on legitimate interests. Where we process your Personal Data for direct marketing purposes, you can object at any time without having to provide any specific reason.
  • Right not to be subject to automated decision-making: automated decision-making with legal or similarly significant effects does not currently take place on our websites or in our services.
  • Right to withdraw consent: where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.
  • Right to lodge a complaint: you have the right to lodge a complaint with the Autoriteit Persoonsgegevens (AP), the Dutch Data Protection Authority, at autoriteitpersoonsgegevens.nl or Bezuidenhoutseweg 30, 2594 AV Den Haag, The Netherlands. If you are based in another EU member state, you may also contact the supervisory authority in your country of residence.

10.2 How to exercise your rights

To exercise your rights, please contact us using the information in Section 13. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honour your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive, we will notify you if this is the case.

Some registered users may update their user settings, profiles, organisation settings and event registrations by logging into their accounts and editing their settings or profiles.

10.3 Your rights relating to customer data

We may also process Personal Data submitted by or for a customer to our cloud products and services. In those cases, we process such Personal Data as a processor on behalf of our customer who is the controller of the Personal Data. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Statement.

If your data has been submitted to us by or on behalf of a New Black customer and you wish to exercise any rights you may have under applicable data protection laws, please contact that customer directly. If you wish to make your request directly to us, please provide us with the name of the New Black customer who submitted your data and we will refer your request to that customer and support them in responding within a reasonable timeframe.

10.4 Your preferences for email and marketing communications

If we process your Personal Data for the purpose of sending you marketing communications, community updates, or non-transactional communications, you may manage your receipt of such communications by clicking the 'unsubscribe' link at the bottom of any marketing or community-related email. If you have been pre-enrolled or invited to join the Nerd Community, Brand Community Program, or a related loyalty initiative, you may decline participation or opt out at any time by following the instructions provided in our communications or by contacting us using the information in Section 13. You can turn off push notifications at any time in your device settings.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements, or security information.

11. How We Secure Your Personal Data

We take appropriate technical and organisational measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorised disclosure of, or access to, the Personal Data we process or use.

Our security programme is independently certified to ISO 27001, ISO 27017, ISO 27018, and ISO 27701. Full details of our compliance frameworks, audit reports, and security controls are available at trust.newblack.io.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Autoriteit Persoonsgegevens within 72 hours of becoming aware of the breach and, where required, will notify affected individuals without undue delay.

While we follow industry-accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are responsible for protecting your own credentials, limiting access to your devices, and signing out of your accounts after each session.

12. Changes to This Privacy Statement

We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the version date at the top of this document. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law, seek your consent to these changes.

We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.

13. Ready for more?

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices, please contact us:


Email: legal@newblack.io

Postal address: New Black B.V., W.T.C. Almere, 29th floor, P.J. Oudweg 4, 1314 CH Almere, The Netherlands


We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the Autoriteit Persoonsgegevens (AP) at autoriteitpersoonsgegevens.nl.

14. Additional Disclosures for California Residents

This section applies to residents of the State of California and supplements the rest of this Privacy Statement.

Sale and sharing of Personal Data

New Black does not sell Personal Data. New Black does not share Personal Data for cross-context behavioural advertising without your consent. We may share Personal Data with third parties or allow them to collect Personal Data from our sites or services if those third parties are authorised service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data, or if you use New Black sites or services to interact with third parties or direct us to disclose your Personal Data to third parties.

Categories of Personal Data disclosed for business purposes

In the preceding 12 months, we have disclosed the following categories of Personal Data for our business purposes:

  • Identifiers
  • Commercial information
  • Internet or other electronic network activity information
  • Financial information
  • Professional and employment-related information
  • Education information
  • Inferences drawn from any of the above categories

California privacy rights

California residents have the following rights under the CCPA and CPRA:

  • Right to know: request details of the categories and specific pieces of Personal Data collected, the sources, our purposes, and categories of third parties we share it with
  • Right to delete: request deletion of Personal Data we have collected, subject to certain exceptions
  • Right to correct: request correction of inaccurate Personal Data
  • Right to opt out: as stated above, New Black does not sell or share Personal Data for cross-context behavioural advertising
  • Right to non-discrimination: we will not discriminate against you for exercising any of your California privacy rights

To exercise your California privacy rights, please contact us using the details in Section 13.