Privacy Policy

This Privacy Policy explains how TogetherCrew (“the Organization”, “TC”, “we”, “us”, “our”) collects, uses, and shares data in connection with the Website and App. By accessing or using our Website or App, You acknowledge that You are at least 16 years old and that You have read, understood, and agree to the collection, storage, use, and disclosure of Your personal information as described herewith. If You disagree with the provisions of this privacy policy, please do not access the Website nor App.

In its capacity as a personal data controller, the Organization carries out its activities in strict compliance with the legal requirements regarding the users’ personal data protection. Pursuant to the provisions of Art. 13 and Art. 14 of the General Data Protection Regulation (GDPR), TC hereby provides the necessary information regarding the collection and processing of Your personal data while using this website.This Privacy Policy is compliant with the EU General Data Protection Regulation (GDPR), which can be considered a general world standard for privacy compliance.

CCPA, pursuant to Article 1798.140, is not applicable to TC.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Website, and You waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by Your continued use of the Site after the date such revised Privacy Policy is posted.

1. Definitions and key terms
For the purposes of this Privacy policy:
- “Account” means a unique account created for You to access our Service or parts of our Service;- “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- “Data subject” means a natural person identified or identifiable whose personal data are processed by the controller.
- “IP address” - every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet;
- “Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- “Privacy Policy” means this privacy policy;
- “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
- “You” or “Your or “Yours” refer to a person who accesses, views and navigates in the Site;
- “Website” refers to TC website: www.TogetherCrew.com;
- “App” refers to TC website: app.TogetherCrew.com and different bots created and managed by TC and operating in other platforms (e.g. TogetherCrew’s Discord bot, Telegram Bot, Discourse Bot, etc.);

2. Identity and contact details of the controller
Controller
: TC;
E-mail: info@togethercrew.com;

3. Categories of collected and processed personal data
TC processes two types of personal data. First, TC processes the personal data that You sent us by way of email or filing a form in the website or App. Second, TC processes data that You communicate to Us when You create an account on TC Website or App.

4.1 Purposes
In case of emails and other communications, TC collects and processes Your personal data to examine and answer Your request.The purposes of processing for the creation of Your account are to provide to TC the minimum amount of information required to create an account and according to the principle of minimization. 

4.2 Legal basis
If You are an individual in the European Economic Area (EEA), we collect and process information about You only where we have a legal basis for doing so under applicable EU laws. The legal basis for the personal data that You communicate to Us in case of email and other communications is Your consent pursuant to Article 6, 1(a) GDPR. The legal basis for the personal data that You communicate to Us for the creation of the account, depending on the case, may be either Your consent pursuant to Article 6, 1(a) GDPR or for taking step prior to entering a contract.  

5. Period for which the personal data will be stored
TC stores Your personal data for a reasonable period of time and never for longer than it is absolutely necessary. In establishing contractual relations with You, TC stores Your personal data throughout the established relations. Typically, the Organization stores Your personal data for 10 (ten) years. 

6. Disclosure and transfer of personal data
In strict compliance with the legal requirements, TC may disclose or transfer Your personal data to the following recipients under particular circumstances:With service providers - We may share Your information with our service providers and vendors to assist us in providing, delivering, and improving the Services. To comply with our legal obligations - We may share Your data in the course of litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedure. With Your consent - We may share Your information any other time You provide us with Your consent to do so.We may need to send some personal information outside of the European Economic Area (EEA). For the transfer of personal data to countries or jurisdictions which are not subject to an adequacy decision granted by the European Commission, we will take measures to comply with our legal obligations and all reasonable safeguards to ensure that Your personal data is treated securely and in accordance with this Privacy Policy. For example, we will enter into standard contractual clauses that have been approved by the European Commission.We do not share Your information with any third parties for any marketing purposes whatsoever.

7. Cookie policy
This Site uses only technical cookies that do not involve the processing of Users data.

8. Your privacy rights
As a data subject, under the GDPR You have the following rights in relation to the personal data You provide:● The right to be informed – You have the right to receive appropriate transparent information about the processed personal data, the purposes and basis of the processing, the recipients or categories of recipients to whom Your personal data has been or will be disclosed, the storage period, as well as any other information about Your personal data.

●  The right of access – You have the right to access Your personal data processed by TC, as well as to request a copy of the personal data in a structured, commonly used format.

●  The right to rectification – You have the right to request rectification of Your personal data if it is incomplete, inaccurate or out of date.

●  The right to erasure (the right to be forgotten) – You have the right to request the erasure of Your personal data under particular circumstances: it is no longer necessary in relation to the purposes for which it was collected; You have withdrawn Your consent to the processing, and there is no other legal basis for processing; when Your personal data has been unlawfully processed; in the presence of other legal grounds.

●  The right to object – You have the right to object to the processing of Your personal data.

●  The right to restrict processing – You have the right to withdraw Your consent to the processing of Your personal data by the controller or the processor at any time and free of charge.

●  The right to data portability – You have the right to request the transfer of Your personal data to another personal data controller when technically feasible.

●  Right of protection – You have the right to defend Your rights by judicial or administrative means if You believe that Your rights as a data subject have been infringed in any way.

●  Rights related to automated decision-making and profiling.

9. Exercising rights related to personal data

At any time, You can withdraw Your consent or object to the processing of Your personal data and exercise Your other rights as a data subject. For this purpose, You should send us a notice using one of the contact details provided in this policy.

Upon receipt of such a notice, TC will provide information regarding the actions taken within one month of receipt. If necessary, this period may be extended by another two months, considering the complexity and number of requests made by one data subject. We will inform You of any extension within one month of receiving the notice, stating the reasons for the extension.

TC will provide the necessary information in relation to the notice only if the sender has been appropriately identified. TC is not obliged to respond to a notice in the event that it is unable to identify the data subject or his/her credentials. We may request the provision of additional information and documents necessary to confirm the identity and authority of the data subject when there are reasonable concerns.

Your questions, comments, requests or complaints regarding this Privacy Policy shall be addressed to info@togethercrew.com
If You are a resident of the European Economic Area and believe we maintain Your Personal Data within the scope of the General Data Protection Regulation (GDPR), You may direct questions or complaints to the supervisory authority of the place where You reside. If You are a resident of the United Kingdom and believe we maintain Your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, You may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office. 

10. Supplemental Notice for California residents
10.1. This Supplemental Notice for California Residents only applies to our processing of personal data that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal data TC has collected about them and whether TC disclosed that personal data for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information respectively in Art. 3 “Categories of collected and processed personal data” and Art. 6 “Disclosure and transfer of personal data” of this Privacy Policy.
10.2. “Sales” of Personal Information under the CCPA For purposes of the CCPA, TC does not “sell” personal data, nor do we have actual knowledge of any “sale” of personal data of minors under 16 years of age.10.3. Additional Privacy Rights for California ResidentsNon-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only You, or someone legally authorized to act on Your behalf, may make a verifiable consumer request related to Your personal information. To designate an authorized agent, please contact us as set forth in “Contact Us” below.Verification. When You make a request, we will ask You to provide sufficient information that allows us to reasonably verify You are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about You. If You are a California resident and would like to exercise any of Your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.If You are a California resident and would like to exercise any of Your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those parties.

11. Supplemental Notice for Nevada residents
If You are a resident of Nevada, You have the right to opt-out of the sale of certain personal data to third parties who intend to license or sell that personal data. You can exercise this right by contacting us as set forth in “Contact Us” below with the subject line “Nevada Do Not Sell Request” and providing us with Your email address associated with Your account. Please note that we do not currently sell Your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

12. Large Language Models and Usage of Data
TC uses Large Language Models (LLMs) to analyse data and provide our Service. The Large Language Models used by TC do not use your data for training purposes.We prefer to use Open Source LLMs. For non-open source LLMs and endpoints for connecting with LLMs, the privacy policy can be seen below:
OpenAI: https://platform.openai.com/docs/models/how-we-use-your-data
Cohere (TC has selected the option to opt-out of providing data for training purposes): https://cohere.com/data-usage-policy
Anyscale: https://www.anyscale.com/endpoints

13. Contact Us
If You have any questions about our privacy practices or this Privacy Policy, or to exercise Your rights as detailed in this Privacy Policy, please contact us at: info@togethercrew.com