This Privacy Notice was last updated on 31 May 2024.

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At Roosh Circle, we organize online and offline events that bring together AI/ML specialists across Europe to develop the European AI community. We respect your privacy and we would like you to understand our data processing practices, and your rights, regarding your personal data.

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This Privacy Notice describes how Roosh LTD and its affiliates (“Roosh Circle”, “we”, “our”, “us”) collect, use, and share the personal data of the users of our website at https://www.rooshcircle.com/ (the “Website”), participants of Papers Club, Roosh AI Circle and Roosh Bash events (the “Event(s)”).

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Unless we link to a different policy or state otherwise, this Privacy Notice applies when you visit the Website or attend the Events (the “Services”).

The Privacy Notice does not apply to third-party services that may collect your personal data when you register for the Event. Where third-party services collect your personal data, such processing is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

We collect the data from you directly, through third parties, and automatically.

You provide your personal data to us when you apply for participation in the Events and/or attend the Event. Such data, depending on the Event, may include:

1. full name;
2. email;
3. phone number;
4. job title;
5. company;
6. location;
7. link to LinkedIn profile;
8. previous experience in the artificial intelligence and machine learning field, as well as other areas related to our Events and about your projects and startups;
9. number of years of experience;
10. information you provide when you contact us for support, to query about the Events, or to report a problem or concern; and
11. audio or visual information, like photos and recordings taken during the Event.

We may collect the Personal Data from the following categories of third parties:

1. third-party services like event organizing platforms (the Personal Data including your name, email address, job position, or other information such as a profile picture, when you are registering for the Event through the such platforms);
2. Event partners, hosts, and sponsors (the Personal Data shared by Event partners, hosts, and sponsors with us where they have indicated that they have your consent or are otherwise legally permitted or required to disclose your personal information to us);
3. company websites (the Personal Data available on publicly accessible company websites, which may include contact details, job titles, and other business-related information);
4. social media platform (the Personal Data available on publicly accessible accounts in LinkedIn).

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We may also collect certain data through automated means such as server log files. In particular, we may collect technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types and other system data and approximate geographic location calculated based on your IP address. 

The categories of data listed in Sections 1.1, 1.2, and 1.3 are hereinafter collectively referred to as the “Personal Data”.

2.1. We do not collect any special categories of personal data as defined by Article 9 of the GDPR or other sensitive personal data (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).

We may use the Personal Data for a variety of purposes, including but not limited to the following purposes:

1. to provide access to the Events;

We use your Personal Data to send invites to our Events. We process your Personal Data so that you can participate in online Events without any technical issues and have the best experience. For you to access the premises of offline Events, we may include some of your Personal Data in participant directories to provide partners, hosts, and sponsors with your names and business contact details.

2. to provide relevant networking, speaker sessions, presentations, and exhibitor products as part of our Events;
3. to provide you with support;

We process your Personal Data to promptly address all your concerns regarding the use of the Website and provide additional information about the Events.

4. for marketing purposes;

We process your Personal Data for our marketing campaigns. We may add your email address to our marketing list, provided we receive your consent or otherwise establish the legal basis for sending you marketing communications. As a result, you will receive information about our Events. If you do not want to receive marketing emails from us, you can unsubscribe by following the instructions in the footer of the marketing emails or by contacting us at legal@roosh.tech. 

We may use Personal Data to conduct joint marketing efforts with our Event partners, hosts, and/or sponsors and connect you with them.

5. to comply with legal obligations;

We may process, use, or share your Personal Data due to legal requirements, in particular, if a law enforcement agency requests your data by available legal means. 

6. to research and analyze your use of the Services.

We process your Personal Data to better understand and analyse our operations, innovate, maintain, improve, plan, design, and develop the Events.

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4.1. Our legal basis for collecting and processing Personal Data will depend on the data concerned and the specific context in which we collect it.

4.2. In most circumstances, we collect and process your Personal Data on the following legal bases:some text

1. we rely on your consent to send you marketing communications and conduct joint marketing campaigns with Event partners, hosts, and sponsors;
2. where it is needed for the performance of a contract, 
3. we rely on a legitimate interest (1) to communicate with you regarding your use of our Website (2) to organize and provide the Event, (3) to ensure normal day-to-day operations, (4) to transfer the Personal Data to companies (e.g. partners, hosts, and sponsors) that help us conduct the Events, (5) to transfer the Personal Data to Event partners that sponsor the Event, and (6) to prevent and combat fraud;
4. we may process the Personal Data to comply with our legal obligations.

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We may disclose Personal Data with our affiliates, Event partners, hosts and sponsors, service providers, and Event participants as described in more detail below:

1. affiliates;

We may share your Personal Data with other legal entities that are part of the Roosh Investment Group to ensure our operations.

2. Event partners, hosts, and sponsors;

We may disclose your Personal Data to our Event partners, hosts, and sponsors for their recruiting and marketing purposes, as well as to carry out our business or for joint marketing efforts to reach our audience. In many cases, you consent to the disclosure of your details by filling out a registration form.

If you would no longer like to be contacted by one of our partners, hosts, or sponsors or would like to have your Personal Data corrected, updated, amended, or removed, please contact the partner, host, or sponsor that you interact with directly.

3. service providers, contractors, and agents;

We share your Personal Data with third-party companies who perform certain services on our behalf, like payment processing, data analysis, marketing, and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your Personal Data and are required to use it solely as we direct to provide our requested service.

We may disclose your Personal Data to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the services that they render to us.

4. Event participants and hosts;

When entering a virtual space, zone, or room at the Event, your registration details may be shared with other attendees including the host to facilitate the Event networking, real-time video conferencing, and online chats. Please note that chat rooms, newsgroups, or other public forums used for communication before or during the Event are open to other participants, so you should not post confidential or private information.

For offline Events, your Personal Data such as full name and contact details may be shared with a host and vendors to ensure access to the Event premises.

5. law enforcement agencies and other public authorities; and

We may use and disclose the Personal Data to ensure your access to the Events, protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

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6.1. We would like to make sure that you are fully aware of all of your data protection rights. Your principal rights under data protection law are:some text

1. the right to access. You can ask for copies of your Personal Data;
2. the right to rectification. You can ask us to rectify inaccurate Personal Data and to complete incomplete Personal Data;
3. the right to erasure. You can ask us to erase your Personal Data;
4. the right to restrict processing. You can ask us to restrict the processing of your Personal Data;
5. the right to object to processing. You can object to the processing of your Personal Data;
6. the right to data portability. You can ask that we transfer your Personal Data to another organization or to you;
7. the right to complain to a supervisory authority. You can complain about our processing.

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We encourage you to contact us directly, so we could address all your concerns. Nevertheless, you have the right to submit a complaint to a competent data protection supervisory authority, in particular in the EU Member State where you reside, work, or where the alleged infringement has taken place.

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6.2. You can exercise the above-mentioned rights and submit your requests by sending an email to us at the address indicated in clause 12. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

We take appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of the Personal Data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured. Due to this, we cannot guarantee that communications between you and the Website or any Personal Data provided to us during the use of the Services will be free from unauthorized access by third parties.

8.1. We may transfer to and store the Personal Data in countries other than the country where the data was initially collected, including the United States or other destinations outside the European Economic Area (“EEA”) or the United Kingdom. Those countries may not have the same data protection laws as the country where your Personal Data was collected. When we transfer your data to other countries, we will protect the data as described in this Privacy Notice and comply with applicable legal requirements, providing adequate protection for data transfer to countries outside the EEA and the United Kingdom.

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8.2. If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:some text

1. the country to which the personal data will be transferred has been granted a European Commission adequacy decision; or
2. we have put in place appropriate safeguards regarding the transfer.

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We may amend and modify this Privacy Notice from time to time. If the Privacy Notice or processing procedures change, we will immediately post those changes to our website. We will also notify you through email so you will have the opportunity to review and revise the Privacy Notice. By continuing to access our Website or attend the Events after those changes become effective, you agree to be bound by the revised Privacy Notice.

10.1. We will retain your Personal Data for as long as it is reasonably necessary for achieving the purposes specified in this Privacy Notice, which includes but is not limited to the period during which you are willing to attend our Events and three (3) years after your last attendance of the Event.

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10.2. We will also retain and use your Personal Data as necessary to comply with our legal obligations.

Roosh LTD, a legal entity incorporated and existing under the laws of Cyprus, registration number HE 426608, having its registered address at Kypranoros 13, EVI Building, 2nd floor, office 201, 1061, Nicosia, Cyprus, will be the controller of your Personal Data.

If you have any questions about this Privacy Notice, the data we hold about you, or you would like to exercise any of your data protection rights, please do not hesitate to:

1. email us at legal@roosh.tech; or
2. write to us at Kypranoros 13, EVI Building, 2nd floor, office 201, 1061, Nicosia, Cyprus.

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