The small print

Blackhorn Privacy Policy

Effective date: August 9, 2026 · applies to every Club property listed in the Terms

Blackhorn is based in Panama. This Privacy Policy explains what personal data may be collected through the Blackhorn website, how that data may be used, when it may be disclosed, and how accounts and data may be removed.

Core approach

Blackhorn’s operating principle is simple: one for all, all for one.

Blackhorn aims to retain as little personal data as reasonably possible and to protect user privacy with strong operational measures. At the same time, no website, service, or system can guarantee absolute security, uninterrupted access, or complete immunity from breach, attack, seizure, failure, or compromise. You use the site at your own peril and at your own risk.

If Blackhorn determines that a user’s privacy is under improper attack, pressure, or unlawful targeting, the service may change infrastructure, hosting, or jurisdictional arrangements in order to better protect that user and the broader user base, to the extent lawfully and operationally possible.

If a user is subject to lawful process, lawful enforcement action, or a lawful order resting on verified proof of claim, Blackhorn may review that order and, where it is required or where Blackhorn chooses, honour it. Blackhorn may suspend, disable, or permanently destroy that user’s account with fair notice each step of the way where possible, as long as the deadlines given by the governing body are both reasonable and legitimate.

If Blackhorn believes allegations, threats, or demands against a user are unlawful, abusive, political, unsupported, or not backed by valid legal process, Blackhorn declines to act on them. Blackhorn does not honour unverified or trumped-up allegations, and it does not treat a demand it cannot verify as though it were proven. This is a statement about what Blackhorn will do, not a claim about the standing of any authority or state.

If a user becomes a material risk for lawful, security, fraud, abuse, financial, reputational, or operational liability to the service, Blackhorn may terminate that account, destroy associated access, and impose a permanent ban without recourse.

Data collected

Blackhorn seeks to minimize collection of personal data as much as possible and collect only what is necessary for the operation, security, and administration of the website.

Depending on how the service is used, this may include:

Account identifiers such as username, email address, password hash, and login metadata.
Technical information such as IP addresses, browser data, device data, timestamps, session information, and security logs.
User-submitted content, communications, reports, uploads, and support requests.
Records required to investigate abuse, enforce site rules, maintain bans, or comply with applicable laws within reason.

Blackhorn does not wish to retain private data longer than needed.

The optional visitor count is cookieless, self-hosted, and off by default: it collects no cross-site ad profiling, carries no identifier, and only a soul who opts in is counted.

The IP address stored against an anonymous commons post is retained for 30 days from the post's creation, then scrubbed. The same bound is enforced in the code that stores it, not just stated here.

Use of data

Blackhorn may use data to:

Create, maintain, and secure accounts.
Authenticate users and operate the platform.
Detect spam, fraud, abuse, harassment, scraping (or distillation), evasion, and other misuse.
Communicate with users about service matters.
Enforce terms, bans, and community safety measures.
Respond to legal demands, complaints, and security incidents.
Preserve the integrity, continuity, and defensibility of the service.

Account deletion, bans, and retention

Users may request deletion of their account and personal data, subject to legal, security, and operational needs.

Data-subject requests (deletion, access, correction) are answered within 30 days of receipt; a complex request may take a further 60 days, and you will be told why.

When an account is deleted or destroyed, Blackhorn may remove, anonymize, or permanently erase associated data unless retention is reasonably necessary for national security, lawful compliance, dispute handling, abuse prevention, or ban enforcement.

If a user is permanently banned, Blackhorn may retain only the minimum data reasonably necessary to maintain and enforce that ongoing lifetime ban.

If a user is under lawful investigation or subject to lawful demands, Blackhorn may preserve, disclose, suspend, or delete data and accounts as required, permitted, or judged necessary.

If the issue involves unlawful, abusive, false, speculative, political, or unsupported allegations not backed by valid legal process, Blackhorn may choose not to act.

Children and guardian controls

This section describes the data consequences of the age model in the Terms. The Terms govern; this section does not add to them. See Section 9 of the Terms.

The Terms bind only persons who have reached the age of majority in their jurisdiction of residence. A person below that age cannot accept the Contract, and Blackhorn does not contract with minors.

The outer, all-ages surfaces of the site — including the QuantumForge and Foolee properties — are open to younger visitors without a Sanctuary Card, on the terms published for those surfaces. No membership record, payment record, or steward record is created by visiting them.

A Sanctuary Card held by a person below the age of majority requires the documented consent of a parent or legal guardian. The guardian, not the minor, is the contracting party, and the guardian is recorded as the responsible party for the minor's conduct.

Card features for consented minors operate under guardian controls that Blackhorn provides: spending limits, communication limits, and content bands. These controls shape what data the service may hold about a minor — a spending limit bounds the payment records retained, a communication limit bounds who may correspond, and a content band bounds what may be shown.

A guardian may revoke consent at any time, which ends the minor's membership immediately. On revocation the account is closed and the data held under it is handled under the deletion and retention terms above.

A minor holding a Card without documented guardian consent is a permanent violation of the Contract and is grounds for termination of every account associated with that household. The Club's parental controls are safety measures, not a promise of supervision.

Disclosure and transfers

Blackhorn does not sell personal data.

Personal data may be disclosed only when reasonably necessary to operate the service, protect users, investigate abuse, enforce platform rules, comply with law, respond to lawful process, or defend the service and its operators.

Because Blackhorn may move systems, providers, or operations to protect users or service continuity, personal data may be processed in jurisdictions other than the user’s own.

Security

Blackhorn will make reasonable efforts to keep accounts and systems secure from breaches, misuse, and unauthorized access.

However, no method of transmission, storage, hosting, encryption, or online access is completely secure. Blackhorn does not guarantee absolute security, permanent availability, or successful defense against every threat. By using the site, you accept these risks and assume responsibility for your own operational security, judgment, and disclosures.

Users should practice common sense while using the website. Do not post, store, send, or rely on any information that would create unacceptable risk if exposed, copied, leaked, seized, or misused.

User responsibility

You are responsible for the devices, networks, credentials, and information you use with Blackhorn.

You should use strong passwords, protect your devices, avoid sharing unnecessary sensitive information, and understand that online activity always carries risk.

If you use the site, you do so voluntarily, knowingly, and at your own peril.

Changes to this policy

Blackhorn may update this Privacy Policy from time to time. Continued use of the website after an update may constitute acceptance of the revised policy.

Contact

Blackhorn Members Club is organized under the laws of the Republic of Panama. Privacy requests, lawful notices, and security reports should be sent through the official contact channel designated on the website. A PO box is provided for allegations and supporting proof of claim.

You will receive a response to a privacy request within 30 days of receipt, consistent with the access-request commitment elsewhere in this policy. A complex request may take a further 60 days, and you will be told why. A lawful notice that Blackhorn determines to be invalid is not answered on that schedule, because it is not treated as a privacy request.

The registered contact address for data-protection correspondence is Carefoot Trust c/o N.K.C & Associates, nkc@tuta.io (Panama). The PO box promised above is being procured before launch; until it is published, the email route above is the official channel and receives the same legal weight.