Privacy Policy

Black Swan (PNG) Ltd



This privacy policy (Policy) describes how Black Swan (PNG) Ltd and any of its related parties (Black Swan) may collect, use and disclose Personal Information (as defined in paragraph 2).

A copy of this Policy is available upon request by contacting Black Swan at the details set out below.

  1. General scope of Privacy Policy

This Policy applies to any customer, user, or other person (the User, Users, You, or Your) who:

a. accesses any Black Swan website or application; and

b. accesses or utilises any Black Swan service (Service).

This Policy applies only to Personal Information (as defined in paragraph 2) and location information that a User discloses or transmits to Black Swan via the Application / Site or that is collected by Black Swan in the course of the provision of the Service.

Black Swan is not responsible for the privacy policies or content of any third-party websites (including advertisers) that You may access through links on Black Swan’s Site, and You must rely on that third-party Site for information about their privacy practices.

  1. What is Personal Information?

Personal information means information about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether recorded in a material form or not (Personal Information).

  1. Your consent to the terms of this Privacy Policy

By providing Black Swan with Personal Information, or through Your use of Black Swan’s Application / Site, or by retaining Black Swan to provide the Service, You agree with the terms of this Policy. Whenever You submit Personal Information to Black Swan, You consent to the collection, handling, use, disclosure and storage of that Personal Information by Black Swan in accordance with this Policy, any other applicable data protection legislation including the European Data Protection Regulation (GDPR) and any other contractual relationship that You have with Black Swan. If You do not consent to the collection, use and disclosure of Your Personal Information or location as described in this Policy, You are not permitted to use the Application / Site and Black Swan will not be able to provide the Service to You.


Black Swan generally processes and stores Personal Information on its servers in In some cases, Black Swan may also rely on data processors, service providers, data hosting and servers located overseas. Consequently, You should be aware that Your Personal Information may be disclosed to overseas recipients. In addition, Black Swan processes some Personal Information to provide the Service.

  1. Incorporation into Terms and Conditions of Use

This Policy is incorporated into and is subject to the Black Swan Terms and Conditions. Your use of the Application / Site and Services and Your provision of any Personal Information or location information to Black Swan is subject to the terms of this Policy, Black Swan’s Terms and Conditions and any other terms under which You have engaged with Black Swan.

  1. What kinds of Personal Information does Black Swan collect about you and how is it collected and held?

Black Swan collects Personal Information that is reasonably necessary for it to perform its functions. This may include:

a. information You give Black Swan when You request a Service from Black Swan on the Application / Site (including, without limitation, Your personal contact details and location);

b. transactional information about the use of a Service if You have or have had engaged a Service on the Application / Site;

c. technical information, including the Internet Protocol (IP) address that You use to connect to the Internet.

The types of Personal Information Black Swan may collect may include Your name, address, telephone numbers, e-mail address, the type and frequency of Service You use, and when You use them, location information, information on how You use Black Swan’s Service and how much You spend, and personal preferences regarding the use of Black Swan’s Service.

Black Swan will collect the Personal Information directly from You at the time You ask Black Swan to provide You with the Service, or if You access the Application / Site.

Your use of the Application / Site will determine the amount and type of information that Black Swan will collect about You.

If You browse Black Swan’s Application / Site, Black Swan’s internet service provider logs the following information:

a. Your server (IP) address and top level domain name;

b. the date and time of Your visit;

c. the country that Your server is located;

d. the pages that You looked at;

e. the type of browser You used;

f. the previous Site You visited; and

g. the Site You visited next.

Some of this information (such as browser type and version, operating system, sites visited) will not be Personal Information because it will not reveal Your identity. This information allows Black Swan to analyse User behaviour in an anonymous form, and is typically used to improve the quality and Services of Black Swan’s website and to prevent fraud, maintain the integrity of Black Swan’s IT systems, and to enhance the security of Black Swan’s network and IT systems.

Black Swan’s Service features or includes various location-based components. Your location information includes, but is not limited to, any information Black Swan derives in order to identify a User’s geographic position. This information may be collected directly from a User, or from a User’s wireless carrier or from certain third party service providers. A User’s location information, however, is only displayed and shared to a Black Swan Service contractor for the purposes of providing the Service to the User.

Black Swan will not use information obtained from Your browsing activities to send You any unsolicited information. 

The only Personal Information which Black Swan collects about You when You use the Site is what You tell Black Swan about yourself, for example, by sending Black Swan an email.

Black Swan will take reasonable steps to ensure that the Personal Information Black Swan collects, uses or discloses is accurate, complete, up-to-date and stored in a secure environment protected from unauthorised access, modification or disclosure.

Black Swan will only retain Your Personal Information for as long as it is reasonably necessary to fulfil the purpose/s for which it was collected or as required for a reporting, legal or accounting purpose.

  1. Why is Personal Information collected by Black Swan?

The Personal Information You provide to Black Swan will enable Black Swan to provide Black Swan’s Service to You. This information may also be used to help Black Swan develop and make available Service to suit Your needs. In particular, the Personal Information You provide Black Swan may be collected, used and disclosed for a number of purposes connected with Black Swan’s business operations, which may include:

a. verifying Your identity or transactions which You may enter into with Black Swan;

b. administering and managing the provision of Black Swan’s Service;

c. providing You with information and/or Service requested;

d. responding to queries or complaints;

e. complying with Black Swan’s risk management policies and procedures;

f. training Black Swan’s staff;

g. billing You and/or administering or otherwise managing Your Account;

h. dealing with requests, enquiries or complaints and other customer Service activities;

i. carrying out market and product analysis;

j. purposes relating to any third party acquisition or potential acquisition of an interest in Black Swan or its assets; and

k. carrying out any activity in connection with a legal, governmental or regulatory requirement that Black Swan have to comply with or in connection with legal proceedings, crime or fraud prevention, detection or prosecution, including investigating any fraud, unlawful activity or misconduct.

Black Swan may also use Your Personal Information for purposes related to those described above which would be reasonably expected by You. For example, Black Swan may use Your Personal Information to keep You informed about features of its Service or to conduct analysis in order to provide better customer Service.

If You do not provide some or all of the information requested, Your experience of Black Swan’s Service may be impaired. Black Swan may have to discontinue its business relationship with You, or Black Swan may not be able to provide You with particular Service or access to certain features on Black Swan’s Application / Site.


Black Swan uses cookies and other tracking software to provide You with an enhanced Service. Cookies may also be used to analyse trends, diagnose problems, track Your engagement with the Application / Site and Services, gather data on search patterns, administer its website, and gather broad information. The information Black Swan collects through cookies may be Personal Information. Where it is not by itself Personal Information, it may become Personal Information if it is linked to Personal Information about an individual. If the information collected is Personal Information, Black Swan will use and manage that information in accordance with this Policy, the Privacy Act and other relevant legislation.

You can choose not to accept cookies, or You can set Your browser to block cookies, in which case Your experience of Black Swan’s Site may be impaired. You can also clear stored cookies from Your browser.

  1. Who will Black Swan share my Personal Information with?

Black Swan may disclose or receive Personal Information or documents about You to/from:

a. Black Swan’s employees and related bodies corporate, in the course of their role as employees and as related bodies corporate, respectively;

b. any organisation that is in an arrangement with Black Swan to jointly offer products or services and or has an alliance with Black Swan to share information for marketing purposes to enable that organisation or Black Swan to provide You with products or Services or promote a product or Service;

c. parties involved in any third-party acquisition or potential acquisition of an interest in Black Swan or its assets;

d. Service providers or agents (some of whom may be overseas) who assist Black Swan in providing its Services, including organisations that assist Black Swan with archival, research, mail and delivery, auditing, consulting, financial and legal advisory, banking, security, storage or technology Services;

e. regulatory bodies, government agencies, law enforcement agencies and courts and any organisation that assist Black Swan to identify, prevent or investigate fraud, unlawful activity or misconduct;

f. Your authorised agents, executor, administrator or trustee in bankruptcy, Your legal representative, attorney or anyone acting for You in connection with Your account;

g. overseas recipients, in certain circumstances; and

h. any other party as otherwise permitted by law.

Where information is disclosed to overseas recipients, Black Swan will take reasonable steps to ensure that any overseas recipient does not breach this Privacy Policy. You should be aware, however, that Your rights to make a claim against Black Swan in relation to any misuse of Your Personal Information by an overseas recipient will be limited.

You may nominate third parties to view or access the Account details maintained by Black Swan in respect of You for any purpose. If You nominate a third party, that third party may be able to view and/or access Your information. By nominating a third party, You explicitly consent to the sharing of Your information with that third party by Black Swan.

  1. GDPR

The General Data Protection Regulation (GDPR) is a comprehensive European data protection law that provides greater data rights for individuals and increases compliance responsibilities for organizations. The GDPR grants EU residents greater control over their Personal Data (as defined in Article 4 GDPR and in general terms meaning data which, in isolation or in combination with other information, enables You to be identified directly or indirectly) and gives national regulators new powers to impose significant fines on organizations that breach this law.

Where the GDPR applies with regard to any Personal Data Black Swan collects, then this section applies to that Personal Data. For the purpose of GDPR, Black Swan is the ‘controller’.

If You are a resident in the European Economic Area (EEA), You have these rights with respect to Your Personal Data:

a. Access Your Personal Data

b. Correct errors in Your Personal Data

c. Erase Your Personal Data

d. Object to the processing of Your Personal Data

e. Export Your Personal Data

You can request to exercise any of these rights in relation to Your Personal Data by sending the request to the Privacy Officer at the contact details provided at the end of this Policy.

If You have a complaint with respect to Your Personal Data and You are based in the EEA, or the issue You would like to complain about took place in the EEA, please refer to Your local data protection authority.

  1. Information you provide to pay for Service acquired from Black Swan

When You order Service from Black Swan, any credit card information or other information (if any) You give Black Swan to purchase the goods or Services is used to process the payment. Black Swan’s database only records that You attended an activity or purchased a Service and how much You paid for it. Black Swan does not store Your credit card details on Black Swan’s database.

  1. Information Security

Black Swan takes appropriate measures to protect unauthorised access to, or unauthorised alteration, disclosure or destruction of, the Personal Information and location information transmitted or disclosed to Black Swan. These include internal reviews of Black Swan’s data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorised access to systems where User data is collected, stored, and/or maintained.

Black Swan requires that when You log in to the Application / Site or utilise Services that require a log in, a secure connection between Your computer and Black Swan’s server be established. Black Swan cannot warrant or ensure the security of any Personal Information and location information that it receives on behalf of Users or any other information that a User transmits, shares or discloses to Black Swan. You should be aware that no Internet or e-mail transmission is ever fully secure or error free.

Black Swan cannot guarantee that information will not be accessed, shared, disclosed, altered, or destroyed by a breach of any of Black Swan’s physical, technical, or other safeguards. Black Swan recommends that You take special care in deciding what information is shared, transmitted or disclosed to Black Swan.

  1. Data integrity

Black Swan processes Your Personal Information only for the purposes for which it was collected and in accordance with this Policy or any applicable terms that You agree with Black Swan. Black Swan review data collection, storage, and processing practices to ensure that Black Swan only collects, stores and processes the Personal Information needed to provide or improve the Service. Black Swan will take reasonable steps to ensure that the Personal Information Black Swan processes is accurate, complete, and current, but Black Swan depends on You to update or correct Your Personal Information wherever necessary.

  1. When can Black Swan vary this Policy?

From time to time it may be necessary for Black Swan to review and amend this Policy. Black Swan reserves the right to amend this Policy at any time. You should check Black Swan’s website from time to time for Black Swan’s latest Policy. Your continued use of the Services constitutes Your agreement to this Policy and any future revisions.


Once Black Swan have collected Your Personal Information, You may request the details of the information Black Swan is holding about You. In order to request such information, You need to contact Black Swan by letter, email or telephone and outline the nature of Your enquiry. Black Swan will take reasonable steps to let You know, generally, what sort of Personal Information Black Swan holds, for what purposes and how Black Swan collects, uses and discloses that information.

Upon Your request and verification of Black Swan’s identity, Black Swan will provide access to Your Personal Information Black Swan hold, except in certain circumstances, including emergency situations, specified business imperatives, law enforcement, public interests reasons, where it would interfere with the privacy of others or where it would result in a breach of confidentiality. Black Swan will endeavour to keep and maintain the data held by Black Swan as accurate, complete, relevant and up to date as possible. 

If You would like to access Your Personal Information, please contact:

The Privacy Officer: Brent Thomson


To opt-out of receiving certain Black Swan marketing materials via email, You will need to tell Black Swan.

To do this please send Black Swan an email with "unsubscribe" in the Subject Field to

Please note that if You have an account with Black Swan, Black Swan will still need to send You essential information about Your account.

  1. How can I complain if Black Swan breaches this Policy?

If You have a question, concern or complaint regarding the way in which Black Swan handle Your Personal Information please contact Black Swan on the details listed below. If You wish to lodge a complaint with Black Swan, You need to write to Black Swan setting out the details of Your complaint as addressed to:

The Privacy Officer: Brent Thomson


Black Swan will issue You with a response to any complaint within a reasonable time that, if appropriate, will outline the measures that Black Swan will take to resolve the complaint.

If You have any additional questions or concerns about this Policy, please feel free to contact Black Swan any time by emailing

This Policy was last updated on 10 March 2020.



 Your preferred language and country site (if applicable)
- The manufacturer and model of your mobile device
- Your mobile operating system
- Your geolocation
- The type of mobile internet browsers you are using
- Driver location data, which we use to track trips and assist with navigation

- Our primary goal in collecting your information is to provide you with an enhanced experience when using the Services. We use your information to closely monitor which features of the Services are used most, to allow you to view your trip history, rate trips, and to determine which features we need to focus on improving, including usage patterns and geographic locations to determine where we should offer or focus services, features and/or resources.

- Location data helps improve our services, including pickups, navigation, and customer support.

- Riders who have enabled “blackswanssvip” to collect location data from their mobile device may also enable the Emergency Data Sharing feature that shares data with emergency police, fire, and ambulance services. Such data includes approximate location at the time the emergency call was placed; the car’s make, model, color, and license plate information; the rider’s name and phone number; pickup and dropoff locations; and the driver’s name.

- Riders who have enabled “blackswanssvip” to collect location data from their mobile device may also enable “blackswanssvip” to share their location with their driver from the time the ride is requested to the start of the trip. This can help improve pickups for both drivers and riders, particularly in crowded areas.