Privacy Policy

This Privacy Policy was last updated on 10 April 2024.

We at Gathers LLC, a company incorporated and existing under the laws of Ukraine, registration number 44470839 (“Gathers”, “we”, “us”), registered address at Ukraine, 01001, Kyiv, 10-a Sofiivska Street, respect your privacy and want you to understand how we collect, use, and share your personal data. This Privacy Policy covers our data collection practices and describes your rights regarding your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you access and use our website and all related services (“Services”).

By using the Services, you agree to the terms of this Privacy Policy. You should not use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

Any translation from the Ukrainian version is provided for your convenience only. If there is any difference in meaning or interpretation between the Ukrainian version of this Privacy Policy and any translation, the Ukrainian version will prevail. The original Ukrainian text shall be the sole legally binding version.

This Privacy Policy is developed in accordance with the Law of Ukraine “On the Protection of Personal Data” No. 2297-VI, dated 1 June 2010, and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”). 

  1.                     Personal data we collect
    1.               We collect the personal data that you give us personally when you visit the website and appoint a call with our team, including your email address, name, and content of your request at your discretion.
    2.               We may also collect additional information about you during our communication to get to know you better and the needs of your company. In particular, we may collect the following data:
      1.                   company name;
      2.                 job title;
      3.               link to your LinkedIn profile; and
      4.                content of communication with us.
    3.               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 abovementioned categories of data listed in Sections 1.1 to 1.3 are hereinafter collectively referred to as the “Personal Data”.

  1.                     How do we collect Personal Data? 
    1.               We collect the Personal Data from you directly. 
    2.               If you provide us with your name, we may also collect data available on publicly accessible accounts in social media platforms). 
  2.                     Sensitive personal data
    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. social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).
    2.               We ask that you not send us, and you do not disclose, any sensitive personal data through the Services or otherwise to us.
    3.               If you send or disclose any sensitive personal data to us when you use the Services, you must consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such sensitive personal data through the Services.
  3.                     What we use Personal Data for
    1.               We process your Personal Dara to provide you with detailed information about our Services, and communicate regarding our further cooperation and agreements. 
    2.               We may add your email address to our marketing list, provided we receive consent or otherwise establish the legal basis for sending you marketing communications. As a result, you will receive information about our Services, such as for example, special offers. 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. 
    3.               We may process, use, or share your data due to legal requirements, in particular, if a law enforcement agency requests your data by available legal means.
  4.                     Legal bases for collecting your Personal Data (applies only to EEA-based users)

We process your Personal Data under the following legal bases: 

  1.                   on the basis of your consent to send you marketing communications;
  2.                 on the basis of our legitimate interests in communicating with you regarding your use of our Services and their analysis;
  3.               to perform our contract with you in case we decide to cooperate.
  1.                     Whom we share your data with
    1.               We share certain Personal Data with companies performing services for us, such as data analysis, 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. 
    2.               We may disclose your Personal Data to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
    3.               We may share your Personal Data within our corporate group  to ensure the provision of the Services. 
    4.               We may use and disclose Personal Data to 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.
  2.                     Security

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, so we cannot guarantee that communications between you and the Services or any information provided to us in connection with the data we collect through the Website and Services will be free from unauthorized access by third parties. 

  1.                     How you can exercise your Personal Data rights
    1.               You have the following rights regarding your Personal Data:
      1.                   accessing / reviewing / updating / correcting your Personal Data. 

You have the right to review, edit, or change the Personal Data that you had previously provided to us. If you would like to receive a copy of the data we process, please send us a data access request. 

  1.                 delete; 

You may also ask us to delete your Personal Data, and we will honour your request to the extent possible. In some instances, we may be legally required to keep your Personal Data. 

  1.               restrict; 

You may ask to stop or limit the processing of all or part of your Personal Data.  

Additional information for EEA-based users. If you are based in the EEA, you have the following rights in addition to the above: 

  1.                  the right to submit a complaint to supervisory authority. 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.
  2.                  the right to data portability. If you wish to receive your personal data in a machine-readable format, you can do so by requesting a copy of your personal data as described above. The data will be made available to you in the .json file or other file formats.
  1.                opt-out; 

You may ask us to stop sending you direct marketing communications. We may continue to send emails that relate to the Services provision and are not marketing-related. 

  1.                  object. 

Object to our reliance on our legitimate interests as the basis of our processing of your Personal Data. 

  1.               If you are a citizen of Ukraine, you have the following rights:
    1.                   know about sources of collection, the location of your Personal Data, the purpose of its processing, location or place of residence (staying) of the controller or the processor of the Personal Data or to authorize other persons to obtain such information, except for cases established by law;
    2.                 obtain the information concerning the conditions of access to the Personal Data, in particular, information about third parties receiving your Personal Data;
    3.               access your Personal Data;
    4.                receive a response with regard to whether your Personal Data is being processed as well as to receive the content of such Personal Data no later than within thirty (30) days from the moment of the request receipt, except for cases established by law;
    5.                  submit a motivated demand on objecting against your Personal Data processing;
    6.                submit a motivated request regarding change or destruction of your Personal Data by us and any third party processing your Personal Data on our behalf if such personal data is processed illegally or is inaccurate;
    7.              protection of your Personal Data from illegal processing and accidental loss, destruction, or damage due to a deliberate concealing, failure to provide or provision with delay, as well as to protection from provision of information which is inaccurate or disgraces your honor, dignity, and business reputation;
    8.            file complaints regarding the processing of your Personal Data to the Ukrainian Parliament Commissioner for Human Rights or directly to a court;
    9.                apply remedies in case of violation of the legislation on personal data protection;
    10.                  when granting his/her consent, make reservations to restrict the right to process your Personal Data;
    11.                withdraw your consent to processing your Personal Data;
    12.              know the procedure for the automatic processing of your Personal Data; and
    13.            be protected against an automated decision having legal implications for you.
  2.               You can exercise the above-mentioned rights and submit your requests by sending an email to us at the address indicated in clause 13. 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.
  1.                     International data transfers

We may transfer the Personal Data to countries other than the country in which the data was originally collected in order to provide the Services and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards. 

  1.                 Changes to this Privacy Policy

We may amend and modify our Privacy Policy from time to time. If our Privacy Policy or 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 Policy. By continuing to access the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

  1.                 Data retention

We will retain the Personal Data for as long as it is reasonably necessary for achieving the purposes specified in this Privacy Policy, which includes but is not limited to the period during which you access the Services. We will also retain and use the Personal Data as necessary to comply with our legal obligations.

  1.                 Data controller

Gathers LLC, a company incorporated and existing under the laws of Ukraine, registration number 44470839, registered address at Ukraine, 01001, Kyiv, 10-a Sofiivska Street, will be the controller of your Personal Data.

  1.                 Contact details

You may contact us at any time for details regarding this Privacy Policy. For any questions concerning your personal data or the exercise of your privacy rights, please contact us at legal@roosh.tech.

This Privacy Policy is effective as of 10 April 2024.