Privacy, terms and conduct.

Privacy Notice

1. Who we are

Black Gold Hub LLP (“Black Gold Hub”, “we”, “us”) is a limited liability partnership registered in England and Wales under number OC457760, with its registered office at 128 City Road, London EC1V 2NX, United Kingdom. We operate from Bar, Montenegro.

We are the controller of the personal data described in this notice. For any question about it, write to privacy@blackgoldhub.com.

2. Whose data we process

We work business to business. The personal data we hold is almost entirely about people acting for companies: representatives of buyers, suppliers, traders, agents and managers; the beneficial owners, directors and authorised signatories of our counterparties; and anyone who contacts us through this website or by email.

3. What we collect

• Contact data — name, company, job title, corporate email, telephone number.
• Enquiry data — what you send through the enquiry form or by email, including vessel or aircraft details, ports, grades, quantities and commercial terms, plus a reference and UTC timestamp generated when the form is sent.
• Due diligence data — identity and authority documents, ownership and control information, and the results of sanctions, politically exposed person and adverse media screening.
• Transaction records — correspondence, offers, nominations, delivery documents and commission records relating to a deal.
• Technical data — the IP address and basic request information that our hosting provider records when you visit or send a form. This website does not use advertising or analytics cookies.

4. Why we use it and our lawful basis

Where screening reveals information about alleged offences, we process it only as permitted by the Data Protection Act 2018, for the purpose of preventing or detecting unlawful acts.

5. Who we share it with

• The counterparty on the other side of a proposed transaction, to the extent needed to verify the parties and present an offer.
• Service providers who process data for us: website hosting and form handling (Netlify, Inc.), email and document storage providers, and sanctions screening tools.
• Professional advisers, auditors and insurers.
• Regulators, law enforcement or courts where the law requires it.

We do not sell personal data, and we do not use it for marketing to third parties.

6. International transfers

We operate between the United Kingdom, Montenegro and the European Union, and some of our service providers are in the United States. Where personal data leaves the UK or EEA for a country without an adequacy decision, we rely on the UK International Data Transfer Agreement or Addendum, or the EU Standard Contractual Clauses, as applicable.

7. How long we keep it

• Enquiries that do not lead to a relationship: up to 24 months from the last contact.
• Due diligence and transaction records: five years from the end of the business relationship or the transaction, whichever is later, or longer where a legal claim or investigation requires it.
• Accounting records: as long as UK company and tax law requires, currently at least six years.

8. Your rights

Subject to legal limits, you may ask us for access to your personal data, correction, erasure, restriction, data portability, and you may object to processing based on legitimate interests. Write to privacy@blackgoldhub.com. We reply within one month. Some due diligence records cannot be erased while we are legally required to keep them.

You also have the right to complain to the UK Information Commissioner’s Office (ico.org.uk), or to the supervisory authority where you live or work. We would appreciate the chance to deal with your concern first.

9. Security

Access to due diligence and transaction files is limited to the people who need it. Data is held with providers that encrypt it in transit and at rest. This website is served only over HTTPS.

10. Changes

We will update this notice when our practices change. The date at the top of this page shows when it was last revised.

Website Terms

1. About these terms

This website is operated by Black Gold Hub LLP. By using it you accept these terms. If you do not accept them, please do not use the site.

2. No offer, no advice

Everything on this website is general information about our services. Nothing on it is an offer, a quotation, an acceptance or a commitment to supply, and nothing on it is legal, technical, regulatory or investment advice. Specifications, regulations, ports and examples are described in summary and may change. Fuel selection, compliance with MARPOL, ECA, EU ETS, FuelEU Maritime and any other requirement, and the decision to buy remain with the buyer and the vessel or aircraft operator.

The stem confirmation shown on the home page is an illustrative specimen. It is not a live document and its figures are examples only.

3. Enquiries

Sending an enquiry through this website or by email does not create any contract or obligation on either side. A transaction is binding only when it is confirmed in writing in the form we describe on the home page, after verification of both parties.

4. Our role

Black Gold Hub acts as a broker and intermediary only. We do not take title to product, receive or hold transaction funds, act as paymaster, provide credit, or carry out regulated activities. Supply is made by the physical supplier named in the firm offer, on that supplier’s terms.

5. Intellectual property

The content, text, design and images on this website belong to Black Gold Hub LLP or its licensors. You may view and print pages for your own business use. You may not copy, republish or use our name or branding in a way that suggests a relationship with us that does not exist.

6. Impersonation

We are aware that names of fuel brokers are sometimes used in fraudulent offers. We only correspond from @blackgoldhub.com addresses, we never ask for advance fees, and our bank details are confirmed only in writing on a signed document. If you receive anything in our name that looks wrong, contact compliance@blackgoldhub.com before acting on it.

7. Liability

We take care to keep this website accurate but we do not guarantee that it is complete, current or free of errors, or that it will always be available. To the extent the law allows, we are not liable for any loss arising from use of, or reliance on, this website. Nothing in these terms limits liability that cannot be limited by law, including for fraud or for death or personal injury caused by negligence.

8. Links

Links to other websites are provided for convenience. We are not responsible for their content.

9. Law and jurisdiction

These terms and any dispute about this website are governed by the law of England and Wales, and the courts of England and Wales have exclusive jurisdiction.

Sanctions and Anti-Bribery Statement

The fuel trade carries real sanctions and corruption risk. This is our position, applied to every enquiry and every transaction. A signed copy is available on request from compliance@blackgoldhub.com.

Sanctions

• We comply with the sanctions regimes of the United Kingdom, the European Union and the United Nations, and we take account of United States sanctions where they may apply to a transaction or its parties.
• We screen counterparties, their beneficial owners, vessels, ports and routes before we quote, on any material change, before delivery and before any commission is released.
• We do not deal in product of Russian or Belarusian origin, and we do not take part in any transaction that is prohibited or restricted under applicable sanctions, including through ship-to-ship transfers, blending or relabelling intended to disguise origin.
• We do not deal with vessels that have disabled or manipulated AIS without a credible explanation, or whose ownership and management cannot be established.

Anti-bribery and corruption

• We do not offer, pay, request or accept bribes or facilitation payments, directly or through anyone else. This applies in every country in which we work, consistent with the UK Bribery Act 2010.
• Our commission is paid only under written terms, by bank transfer to a Black Gold Hub account, by the agreed party. We do not accept cash or cryptoassets, and we do not conceal commission from a principal.
• Gifts and hospitality are modest, recorded, and never connected to a pending decision.
• We do not split commission with anyone who is not disclosed to both principals.

Fraud and advance fees

• We decline unsolicited FCOs, soft offers and allocation claims that cannot be verified, and open broker chains where the ultimate buyer or seller cannot be identified.
• We never charge, and never ask anyone to pay, advance fees for registration, allocation, performance, inspection or documentation.

Tax evasion

We do not facilitate tax evasion by anyone. Duty and VAT status is verified for every yacht and every supply where it applies.

Speaking up

Anyone, on any side of a transaction, may raise a concern with compliance@blackgoldhub.com. Concerns raised in good faith will never lead to any penalty or loss of business.

Complaints Procedure

If you are unhappy with something we have done, or not done, we want to know. We deal with complaints quickly and in writing.

How to complain

Write to compliance@blackgoldhub.com with the subject line “Complaint”, or by post to our registered office. Please include your name and company, the deal reference if there is one, what went wrong, and what you would like us to do.

What happens next

• Within 2 business days — we acknowledge your complaint and tell you who is handling it.
• Within 15 business days — we send a full written response, or explain why we need more time and when you will hear from us.
• Escalation — if you are not satisfied, a designated member of the LLP who was not involved in the matter will review it and reply in writing.

Data protection complaints

Complaints about personal data can also go to privacy@blackgoldhub.com or to the Information Commissioner’s Office, as described in the Privacy Notice above.