Privacy Policy

Last updated: March 2026

  1. Who we are
    BlackSwanAdvisory is operated by Jack Felix and Neil Martin. We publish The BSA Continuity Briefing and related advisory content for SME owners in the UK and Europe.
    For the purposes of UK GDPR and the Data Protection Act 2018, Neil Martin is the data controller for personal information collected through this website.
    Contact: blackswanadvisory@proton.me
  2. What information we collect
    When you register your interest on our website, we collect:
    • Your name
    • Your email address
    • The date and time you submitted the form
    • Your consent record (that you agreed to receive communications from us)

We do not collect payment details, sensitive personal data, or any information beyond what is listed above at this stage.

  1. Why we collect it and our legal basis
    We collect your information solely to:
    • Notify you when The BSA Continuity Briefing is published and available
    • Send you early access pricing and any related offers, and subscribe you to the BSA Substack (free subscriber status).

Our legal basis for processing your data is consent (Article 6(1)(a) UK GDPR). You provided this consent by ticking the opt-in checkbox on our registration form. We will not use your data for any other purpose without asking you again.

  1. How we store your data
    Your data is currently held securely by BlackSwanAdvisory. When we connect our email marketing platform, your data will be transferred to that provider. We will update this policy at that point to name the provider and confirm their data processing terms.
    We will retain your data only for as long as necessary to fulfil the purpose for which it was collected, or until you withdraw your consent.
  2. Who we share your data with
    We do not sell, rent, or share your personal data with any third parties for marketing purposes.
    We may share data only in the following limited circumstances:
    • With our email marketing provider (to be confirmed — see Section 4)
    • If required by law, regulation, or court order
  3. Your rights under UK GDPR
    As a data subject, you have the following rights:
    • Right to access — you can request a copy of the personal data we hold about you
    • Right to rectification — you can ask us to correct inaccurate data
    • Right to erasure — you can ask us to delete your data at any time
    • Right to withdraw consent — you can unsubscribe or withdraw consent at any time, without affecting the lawfulness of processing before withdrawal
    • Right to object — you can object to us processing your data
    • Right to data portability — you can request your data in a portable format

To exercise any of these rights, contact us at: blackswanadvisory@proton.me
We will respond within 30 days.

  1. Cookies
    This website may use basic cookies for functionality purposes (e.g. WordPress session cookies). We do not currently use tracking, analytics, or advertising cookies. If this changes, we will update this policy and seek your consent where required.
  2. How to unsubscribe
    You can unsubscribe from our communications at any time by:
    • Clicking the unsubscribe link in any email we send you
    • Emailing us at blackswanadvisory@proton.me and asking to be removed

Once you unsubscribe, we will remove your email from our active list within five working days and will not contact you again for marketing purposes.

  1. Complaints
    If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the UK’s data protection regulator:

Information Commissioner’s Office (ICO)
Website: www.ico.org.uk
Helpline: 0303 123 1113

We would, however, appreciate the opportunity to address your concern before you contact the ICO. Please email us first at blackswanadvisory@proton.me

  1. Changes to this policy
    We may update this Privacy Policy from time to time, particularly when we connect an email marketing platform or as the business develops. The ‘last updated’ date at the top of this page will always reflect when it was last changed. Continued use of this website after changes are posted constitutes your acceptance of the revised policy.
  2. Contact
    For any questions about this Privacy Policy or how we handle your data:

Neil Martin
BlackSwanAdvisory
Email: blackswanadvisory@proton.me