PRIVACY POLICY

When you submit a KYC / Buyer Application, Broker/Seller Application, or otherwise request access to the Blackline Portal, we may collect, directly from you or through independent verification, information including but not limited to:

• Company and entity information (legal name, DBA, registration number, incorporation details, registered and operating addresses, tax ID/VAT/EIN, parent company or holding structure);
• Beneficial ownership and management details (names, nationality, country of residence, ownership percentages, director and officer identities);
• Authorized representative and signatory information (name, title, email address, direct phone/WhatsApp number, and proof of authority such as powers of attorney or board resolutions);
• Banking information (bank name and address, account name and number/IBAN, SWIFT/BIC code, and bank officer contact details used solely for verification purposes);
• Trade references, transaction profile details, and intended volumes, terms, ports, and payment instruments;
• Government-issued identification, passport copies, proof of address, corporate charter documents, financial statements, and other supporting documentation you upload;
• Technical and usage data automatically collected when you access the Services, including IP address, device and browser type, access times, and pages viewed, to the extent such data is logged by our hosting or security infrastructure.

You represent and warrant that you have the authority to submit the information and documents you provide, including information relating to beneficial owners, officers, and other individuals, and that such individuals have been made aware of, and consented to, the collection and processing of their information as described in this Policy.

Blackline collects and processes the information described above solely for the following purposes:

1. To verify the identity, legitimacy, and creditworthiness of prospective counterparties (Know Your Customer / Anti-Money Laundering compliance);
2. To conduct independent due diligence, including bank-to-bank and SWIFT verification, corporate registry checks, and reference verification;
3. To screen Applicants, their beneficial owners, and affiliated parties against sanctions, watch, and denied-party lists maintained by OFAC, the United Nations, the European Union, and other applicable governmental or supranational authorities;
4. To evaluate, process, and respond to applications for counterparty, broker/seller, or portal access;
5. To detect, investigate, and prevent fraud, money laundering, terrorist financing, corruption, and other unlawful conduct;
6. To establish, exercise, or defend legal claims, and to comply with applicable legal, regulatory, contractual, and anti-corruption obligations, including recordkeeping requirements under U.S. and applicable foreign law;
7. To maintain the security, integrity, and proper functioning of the Services.

Where applicable law requires a legal basis for processing (including under foreign data protection regimes), Blackline relies on your consent, the necessity of processing to perform pre-contractual due diligence and any resulting contract, Blackline's legitimate business and compliance interests, and/or compliance with legal obligations.

Submitted information and documents are treated as confidential business information. Access is restricted, on a need-to-know basis, to authorized Blackline personnel, officers, and service providers directly involved in the review, verification, compliance, and onboarding process. Blackline implements reasonable administrative, technical, and physical safeguards designed to protect information against unauthorized access, disclosure, alteration, loss, or destruction.

Notwithstanding the foregoing, no method of transmission over the internet or electronic storage is completely secure, and Blackline cannot and does not guarantee absolute security. You acknowledge that you submit information at your own risk, and Blackline disclaims liability for unauthorized access, interception, or disclosure resulting from circumstances beyond its reasonable control, including cyberattacks, third-party service provider failures, or Applicant error (such as transmitting information over unsecured channels).

Blackline does not sell, rent, or trade your information. Information may be accessed, shared, or disclosed only where reasonably necessary, including with:

• Financial institutions and correspondent banks, for the purpose of bank-to-bank or SWIFT verification you have authorized by submitting your application;
• Compliance, screening, and due-diligence service providers engaged to verify identity, ownership, sanctions status, or creditworthiness;
• Regulatory, law enforcement, customs, tax, or judicial authorities, where required or requested under applicable law, subpoena, court order, or governmental investigation;
• Professional advisors, including legal counsel, auditors, and insurers, on a confidential basis and as reasonably necessary to protect Blackline's legal and business interests;
• Successors or assigns in connection with a merger, acquisition, financing, reorganization, or sale of all or substantially all of Blackline's assets, subject to customary confidentiality protections;
• Hosting, infrastructure, and IT service providers who process information on Blackline's behalf under confidentiality and data-protection obligations consistent with this Policy.

Blackline reserves the right to disclose information where it believes in good faith that disclosure is necessary to comply with legal process, protect Blackline's rights or property, prevent fraud or illegal activity, or protect the safety of Blackline, its personnel, or the public.

Blackline is based in the United States and information you submit will generally be processed and stored in the United States. If you submit information from outside the United States, you acknowledge and consent that your information will be transferred to, processed, and stored in the United States and other jurisdictions in which Blackline or its service providers operate, which may have data protection laws different from, and potentially less protective than, those of your home jurisdiction. By submitting information, you consent to such transfer, processing, and storage.

Application information and supporting documents are retained for as long as reasonably necessary to fulfill the purposes described in this Policy, including satisfying applicable legal, regulatory, AML/KYC, tax, and recordkeeping obligations (which, for certain records, may extend for a period of years following the end of any business relationship or the rejection of an application), to resolve disputes, and to enforce Blackline's agreements. Where no such obligation applies, Blackline will take reasonable steps to delete or anonymize information upon request, subject to Section 7.

Subject to applicable law and Blackline's legal and regulatory retention obligations, you may request access to, correction of, or deletion of the information you have submitted by contacting us at the email address below. Blackline may decline or limit such requests where retention or processing is required to comply with legal, regulatory, AML/KYC, tax, or contractual obligations, or to establish, exercise, or defend legal claims. Blackline reserves the right to verify your identity and authority before acting on any such request.

You are solely responsible for the accuracy, completeness, and currency of all information and documents you submit. Submission of false, misleading, or incomplete information may result in immediate rejection of your application, termination of any existing relationship, and referral to applicable law enforcement or regulatory authorities. Submission of an application, and provision of information under this Policy, does not constitute an offer, commitment, or guarantee of approval, counterparty status, or entry into any transaction with Blackline. All applications are subject to independent verification and review at Blackline's sole discretion.

THE SERVICES AND ANY INFORMATION MADE AVAILABLE THROUGH THEM ARE PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR THAT ACCESS TO THE SERVICES WILL BE UNINTERRUPTED, SECURE, OR ERROR-FREE.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, BLACKLINE, ITS OFFICERS, MEMBERS, EMPLOYEES, AGENTS, AND SERVICE PROVIDERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, REVENUE, DATA, OR BUSINESS OPPORTUNITY, ARISING OUT OF OR RELATING TO THE SUBMISSION OF INFORMATION, THE PROCESSING OF AN APPLICATION, ANY UNAUTHORIZED ACCESS TO OR DISCLOSURE OF INFORMATION NOT CAUSED BY BLACKLINE'S GROSS NEGLIGENCE OR WILLFUL MISCONDUCT, OR THE USE OF OR INABILITY TO USE THE SERVICES, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL BLACKLINE'S AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THIS POLICY OR THE SERVICES EXCEED ONE HUNDRED U.S. DOLLARS (US $100).

You agree to indemnify, defend, and hold harmless Blackline, its officers, members, employees, agents, and service providers from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising out of or relating to: (a) your submission of false, inaccurate, or misleading information; (b) your breach of this Policy or any representation or warranty made herein; (c) your violation of applicable law, including sanctions, anti-money-laundering, or anti-corruption law; or (d) your submission of information relating to third parties (including beneficial owners, officers, or references) without proper authorization or consent.

The Services may reference or link to third-party websites, banks, or service providers not controlled by Blackline. Blackline is not responsible for the privacy practices, content, or security of any third party, and this Policy does not apply to information you provide directly to third parties. Access to any third-party site or service is at your own risk.

The Services may use cookies, log files, or similar technologies to support essential site functionality, security, and basic usage analytics. You may configure your browser to refuse cookies; however, certain features of the Services may not function properly as a result.

The Services are intended solely for use by businesses and individuals acting in a professional capacity who are at least eighteen (18) years of age. Blackline does not knowingly collect information from individuals under eighteen. If Blackline becomes aware that it has inadvertently collected such information, it will take reasonable steps to delete it.

Blackline reserves the right to amend or update this Policy at any time, at its sole discretion, to reflect changes in its practices, legal requirements, or the Services. Any changes will be posted on this page with an updated "Last updated" date. Your continued submission of information or use of the Services following the posting of changes constitutes acceptance of the revised Policy. It is your responsibility to review this Policy periodically.

This Policy, and any dispute arising out of or relating to it or the Services, shall be governed by and construed in accordance with the laws of the State of Texas, without regard to its conflict-of- laws principles, and, where applicable, U.S. federal law (including sanctions and anti-money- laundering law). Any dispute, controversy, or claim arising out of or relating to this Policy shall be resolved by binding arbitration administered by the American Arbitration Association (AAA) in Houston, Harris County, Texas, in accordance with its applicable rules then in effect, and judgment on the award rendered may be entered in any court having jurisdiction thereof. Nothing in this Section shall preclude Blackline from seeking injunctive or equitable relief in a court of competent jurisdiction to protect its confidential information, intellectual property, or other legal rights.

If any provision of this Policy is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. This Policy, together with any applicable certifications made within an application, constitutes the entire understanding between you and Blackline with respect to the collection, use, and protection of information submitted through the Services, and supersedes all prior or contemporaneous understandings on that subject.

Questions, requests, or notices regarding this Policy or your information should be directed to:

Blackline Global Trading
17350 State Highway 249, Suite 220, Houston, TX 77064, USA
Email: support@blacklineglobaltrading.com