Last Updated: February 13, 2026

This Privacy Notice describes how we collect, use, disclose, and protect personal information within our customer relationship management (“CRM”) systems. It applies to customers, prospective customers, suppliers, partners, website visitors, and other individuals whose data we maintain in connection with our business activities.

We are committed to protecting privacy rights and complying with global privacy and data-protection laws, including but not limited to the laws of the United States, Canada, the European Union, and the United Kingdom.

1. Information We Collect

We may collect and store the following categories of personal information:

1.1 Contact and Identification Information

• Name, job title, organization

• Business email address, phone number, and address

• Job title/role

• Language and communication preferences
  
  

1.2 Relationship and Account Information

• Account details, purchase history, service interactions

• Contract information and customer support records

• Event attendance

• Meeting notes

• Information you voluntarily provide used to personalize professional outreach such as

  • Gender

  • Marital status

  • Spouse’s name

  • Children’s names

  • Anniversary
    
    

1.3 Technical Information

• Log data, IP address, device information

• Website interactions (if legally permitted)

• CRM access logs for authenticated users
  
  

1.4 Compliance and Due Diligence Information

• Information gathered for sanctions screening, regulatory checks, and identity or business verification

• Publicly available or third-party-supplied information used for compliance purposes

We do not intentionally collect sensitive personal information unless required for regulatory compliance or provided voluntarily for a specific purpose.

2. How We Use Personal Information

We use personal information in our CRM system to support:

2.1 Business Operations

• Developing, maintaining and growing our business relationships

• Providing products, services, support, and updates

• Managing accounts and business relationships

• Processing orders, contracts, and transactions
  
  

2.2 Communications

• Informing customers and potential customers of information relating to our business

• Inviting customers and potential customers to business-related meetings and events

• Sending service notices, product information, and newsletters (where allowed)

• Responding to inquiries and providing customer assistance
  
  

2.3 Compliance and Risk Management

• Screening for export-control, sanctions, anti-corruption, and fraud risks

• Satisfying legal and regulatory obligations
  
  

2.4 System Administration and Improvement

• Enhancing CRM performance and user experience

• Conducting analytics, reporting, and internal audits

We only use personal information in ways consistent with these purposes or as required by law.

3. Why We Share Personal Information

We may share personal information with:

3.1 Service Providers

Cloud providers, CRM platform vendors, analytics services, and other third parties that support our operations under strict confidentiality obligations.

3.2 Business Partners

Consultant, distributors, sales agents, and others involved in fulfilling orders or servicing customer relationships.

3.3 Legal or Regulatory Authorities

When disclosure is required by law or lawful request.

3.4 Corporate Events

In connection with mergers, acquisitions, reorganizations, or asset transfers, subject to adequate safeguards.

We do not sell personal information for monetary value.

4. International Data Transfers

Due to our global operations, personal information may be processed in countries outside your place of residence, including the United States.

We rely on appropriate legal mechanisms, such as:

• Standard Contractual Clauses (EU/UK)

• Adequacy decisions

• Contractual protections under Canada’s PIPEDA and Brazil’s LGPD

• Additional technical and organizational safeguards

Regardless of where data is processed, it is handled in accordance with this Notice.

5. Data Retention

We retain personal information only for as long as necessary to:

• Maintain customer accounts

• Meet legal or regulatory obligations

• Resolve disputes

• Support legitimate business needs

Applicable laws may require longer retention periods.

6. Your Privacy Rights

Depending on your jurisdiction, you may have rights to:

• Access your personal information

• Correct inaccurate data

• Delete or request erasure

• Restrict or object to data processing

• Request data portability

• Withdraw consent (where applicable)

• Opt out of certain types of data disclosures

You may exercise these rights by contacting us at privacy@blacklake.group. 

7. Data Security

We use administrative, technical, and physical controls designed to protect personal information against unauthorized access, disclosure, alteration, and destruction.

8. Children’s Privacy

Our CRM systems and business operations are not intended for children.
We do not knowingly collect personal information from individuals below the age permitted by applicable laws.

9. Updates to This Notice

We may update this Privacy Notice periodically.
Changes will be posted with an updated “Last Updated” date.

10. Contact Us

Questions about this Notice or our CRM privacy practices may be directed to Thousand Islands Industries, Inc. dba Blacklake via privacy@blacklake.group. 

11. GDPR (EU/EEA/UK) Compliance

If you are in the European Union, European Economic Area, or United Kingdom, the following applies.

11.1 Legal Grounds for Processing

• Contract performance

• Legitimate interests

• Compliance with legal obligations

• Consent for specific uses (e.g., optional marketing)
  
  

11.2 Your GDPR Rights

You may request:

• Access, correction, deletion

• Restriction or objection

• Data portability

• Withdrawal of consent

• Complaint to a supervisory authority
  
  

11.3 International Transfers

Transfers outside the EU/UK rely on:

• Standard Contractual Clauses

• UK Data Transfer Addendum

• Adequacy decisions

• Additional safeguards
  
  

12. California Consumer Privacy Rights Act (CPRA)

This section applies to California residents.

12.1 Categories Collected

May include:

• Identifiers

• Commercial information

• Internet activity

• Professional information

We do not sell or “share” personal information for cross-context behavioral advertising.

12.2 CPRA Rights

You may request:

• Access, correction, deletion

• Information about our data practices

• Opt-out from certain disclosures

• Limiting use of sensitive information (not applicable as we do not use it for inferring characteristics)

Authorized agents may submit requests on your behalf.

13. Virginia Consumer Data Protection Act (VCDPA)

This section applies to Virginia residents.

13.1 Virginia Rights

You may:

• Access and confirm processing

• Correct inaccuracies

• Delete personal data

• Obtain a portable copy

• Opt out of targeted advertising, sale, or significant profiling

We do not use data for automated decisions producing legal or significant effects.

13.2 Appeals

If we deny your request, you may appeal. If unresolved, you may contact the Virginia Attorney General.

14. Canada (PIPEDA) Compliance

If you reside in Canada, the following applies pursuant to the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws.

14.1 Accountability

We maintain policies, training, contractual controls, and safeguards to protect personal information under our control.

14.2 Purposes for Collection

We collect personal information only for:

• Managing customer relationships

• Fulfilling contracts and transactions

• Providing services and support

• Regulatory compliance

• Legitimate business operations

When required, we will obtain meaningful consent for collection, use, or disclosure.

14.3 Your Canadian Privacy Rights

Under PIPEDA, you may:

• Access the personal information we hold about you

• Request corrections

• Withdraw consent (subject to legal or contractual limits)

• Challenge our compliance with PIPEDA

We respond to verified requests within statutory timelines.

14.4 Cross-Border Transfers

Your information may be transferred to the United States or other jurisdictions.
Where this occurs, we implement measures consistent with PIPEDA requirements to protect your information.

14.5 Questions or Complaints

You may raise concerns with us via privacy@blacklake.group. If unresolved, you may contact the Office of the Privacy Commissioner of Canada.