Privacy Policy

This Privacy Policy explains how Gemini Media Agency SRL (“we”, “us”), the operator of itssomwhere, collects, uses and protects your personal data. We are the data controller responsible for your personal data.

Registered address: Harmanului Street No. 17, 500228 Brașov, Romania. Contact: contact@itssomwhere.com.

1. Data we collect

We collect the information you give us when you apply, together with a limited amount of technical data needed to run the site.

Application data

• Members: full name, email, city, an optional LinkedIn or website link, and your written answers (what you’re building, who you hope to meet, what you can share, and why you want to join).
• Partners: organization, website, contact person, contact email, partner type, and your written answers.
• Founding Stars: name or organization, email, an optional link, and your written answers.

Other data

• Communications you send us (for example, by email).
• Technical data such as IP address and browser information, processed by our hosting provider to keep the site secure and operational.

2. How we use your data

• To review your application and decide whether to offer access.
• To contact you about your application and, if accepted, about the community and its experiences.
• To operate, secure and improve the community and the site.
• To comply with our legal obligations.

3. Legal bases (GDPR)

• Consent — when you submit an application (Art. 6(1)(a) GDPR). You can withdraw consent at any time.
• Legitimate interests — operating and securing a curated community (Art. 6(1)(f) GDPR).
• Legal obligation — where the law requires it (Art. 6(1)(c) GDPR).

4. Sharing and processors

We never sell your personal data, and we never share it with third-party advertisers or marketing companies. We use no analytics tools and we do not track visitors. There is no database: applications arrive directly in our mailbox, where a person reads them.

We share data only with the service providers who process it on our behalf, under contract:

• Zooku Solutions SRL (Romania) — website hosting.
• Resend (United States) — delivers your application to our mailbox. Retains delivery logs for roughly 30 days.
• Proton AG (Switzerland) — our mailbox provider, where the application is read and stored.
• Luma (United States) — after acceptance only: the member list, events and newsletter.

If your application is not accepted, your data never reaches Luma.

We may also disclose data where required by law or to protect our legal rights.

5. International transfers

The website is hosted in Romania, within the European Union. Resend and Luma are United States companies, and those transfers are protected by appropriate safeguards such as the European Commission’s Standard Contractual Clauses. Proton AG is in Switzerland, a country covered by a European Commission adequacy decision.

6. How long we keep it

We do not keep data longer than we need it:

• Unsuccessful applications — deleted within 6 months of the decision.
• Accepted members — we keep the application while your membership is active, and for 12 months after it ends.

You can ask us to delete your data at any time, sooner than these periods. We make an exception only where a longer period is required by law.

7. Your rights

Under the GDPR you have the right to access, correct, delete, restrict or object to the processing of your data, to data portability, and to withdraw consent. To exercise any of these, email contact@itssomwhere.com.

You also have the right to lodge a complaint with the Romanian supervisory authority, the National Supervisory Authority for Personal Data Processing (ANSPDCP) — dataprotection.ro.

8. Security

We take reasonable technical and organisational measures to protect your data. No system is perfectly secure, but we work to keep your information safe.

9. Children

itssomwhere is intended for adults. We do not knowingly collect data from anyone under 18.

10. Photography and media at experiences

Professional photographs and video may be taken at our real-world experiences, for community records and limited, restricted promotional use. When you apply you may consent to this — it is optional, and you are welcome to attend either way. You can withdraw consent, or ask us to remove media featuring you, at any time by emailing contact@itssomwhere.com.

11. Cookies

We use only essential cookies needed for the site to function. See our Cookie Policy for details.

12. Changes

We may update this policy from time to time. The “last updated” date above shows when it last changed.

13. Contact

Questions about this policy or your data? Email contact@itssomwhere.com.