RCCEB Privacy Notice

Introduction

The Robert College Entrepreneurs Bond (“RCCEB”) is a non-stock corporation incorporated under the laws of the State of Delaware, USA, operating within the Robert College (“RC”) alumni ecosystem. RCCEB fosters collaboration, networking and knowledge sharing among entrepreneurs, investors and professionals affiliated with RC, including RC Alumni and RC Friends. Further details regarding membership, governance and election processes are set out in the RCCEB Charter.

This Privacy Notice explains how RCCEB collects, uses, stores and protects personal data of individuals who participate in the RCCEB community or interact with RCCEB through its communication platforms or website.

RCCEB is committed to handling personal data responsibly and in accordance with applicable data protection laws.

RCCEB operates independently as a community-led organization. RCCEB is not owned, operated or controlled by RC and RC does not assume any responsibility or liability for RCCEB activities or any data processing operations.

For the purposes of the applicable data protection laws, personal data processed in connection with RCCEB activities is administered by RCCEB, as represented by the RCCEB Founders Council, which coordinates the RCCEB community's activities.

Questions regarding this Privacy Notice or the processing of personal data may be directed to the RCCEB Founders Council using the contact information provided in Article 13.

Personal Data We Collect

RCCEB may collect and process the following categories of personal data:

Personal Identification Information, such as:

• Name
• E-Mail Address
• RC Graduation Year (for alumni) or Affiliation/Recommendation details (for RC Friends)
• Professional information shared by the participants (such as company, role, entrepreneurial interest)
• Community Participation Data, such as any type of information shared during any community interactions, events or communications
• Messages or discussions within RCCEB communication platforms.
• Website Usage Data, such as IP address, browser type and device information, pages visited and interaction data and cookies or similar tracking technologies

Special Categories of Personal Data

RCCEB does not intentionally request or collect special categories of personal data (such as health data, political opinions or religious beliefs). Participants are encouraged not to share such information within community platforms.

How Do We Collect Personal Data?

Personal data may be collected through several channels, including:

• when individuals join the RCCEB community
• when participants provide contact information for community membership
• through participation in RCCEB events or initiatives
• through communication platforms used by the community (such as mailing lists, messaging platforms (e.g. WhatsApp) or other digital platforms)
• through forms or subscriptions on the RCCEB website
• through standard website technologies such as cookies or server logs

Recommendations and Invitations

In some cases, RCCEB may receive limited personal information from Robert College, other RC alumni or community participants when recommending or inviting RC Friends to the initiative.

Purposes of Data Processing and Legal Basis

RCCEB processes personal data for the following purposes:

Community Administration: Managing membership, maintaining communication channels and facilitating participation in RCCEB activities.

Networking and Collaboration: Enabling participants to connect, share information and collaborate within the RCCEB ecosystem.

Community Communications: Providing updates regarding RCCEB initiatives, events, opportunities and activities.

Website Management: Maintaining and improving the RCCEB services and understanding how visitors interact with our website.

Community Messaging Platforms

As part of the RCCEB community infrastructure, RCCEB may operate communication channels on third-party messaging platforms (such as WhatsApp), including an “Announcement” group intended to provide members with updates regarding RCCEB activities, events and initiatives.

When participants apply to join RCCEB via the private RCCEB website, they may be asked to consent to be added to communication channels, including the RCCEB WhatsApp Announcements group. Where such consent is provided, participants can be added to the Announcements group.

Participants will have the option to join additional groups within such platforms at their discretion. Participation in such messaging platforms is voluntary and participants may leave these groups at any time.

Personal data, such as phone number and profile information, may be processed by the relevant platform provider in accordance with their own privacy policies.

Legal Basis under GDPR

Where the GDPR applies, personal data is processed on one or more of the following legal bases:

• Consent of the participant (e.g., joining RCCEB communications, including messaging platforms such as WhatsApp)
• Legitimate interest, including operating and maintaining the RCCEB services and community
• Compliance with legal obligations, where applicable
• Participants may withdraw consent at any time where processing is based on consent.

Sharing of Personal Data

Personal data may be shared in the following circumstances:

Within RCCEB Community: Personal data may be visible to other members in order to facilitate networking and collaboration.

Service Providers: Personal data may be processed by technical service providers and vendors who assist us with providing our services, including website hosting, communication platforms, messaging services (such as WhatsApp) and email services.

Legal Requirements: Personal data may be disclosed if required by applicable law, court order or regulatory obligation.

RCCEB does not sell personal data for monetary or other valuable consideration and does not share personal data for cross-context behavioral advertising or for the marketing or promotional purposes of unaffiliated third parties.

Data Security and Personal Data Breaches

RCCEB implements appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse and alteration. RCCEB maintains internal procedures to identify, assess and respond to potential data breaches.

In the event of a personal data breach, RCCEB will assess the incident and take appropriate measures in accordance with applicable data protection laws. Where the GDPR applies, RCCEB will notify the competent supervisory authority of a personal data breach without undue delay and, where feasible, not later than 72 hours after having become aware of it, unless the breach is unlikely to result in a risk to the rights and freedoms of individuals. Where the breach is likely to result in a high risk to the rights and freedoms of the individuals, affected participants will be informed without undue delay.

International Data Transfers

RCCEB is an international community with participants located in multiple jurisdictions.

As a result, personal data shared within RCCEB may be accessed or processed by participants located outside a participant’s country of residence, including outside the European Union (“EU”) or European Economic Area (“EEA”).

RCCEB seeks to handle such international transfers of personal data in accordance with generally accepted data protection principles, including those reflected in the GDPR and ensures that appropriate transfer mechanisms are in place where required. By participating in the RCCEB community, participants acknowledge that their data may be accessed by other members globally.

Data Retention

Personal data will generally be retained for as long as an individual remains a participant in the RCCEB community or until a participant requests removal of their information, unless longer retention is required to support RCCEB activities or comply with legal obligations. To determine the appropriate retention period for each category of personal data, RCCEB considers the nature and sensitivity of the data, the duration of the participant’s relationship with RCCEB, the purposes for which the data was collected and any legal, contractual or operational requirements. Personal data collected through cookies and website logs is generally retained for shorter periods consistent with industry practice.

RCCEB may retain limited records where necessary to comply with legal obligations or to resolve disputes.

Children’s Privacy

RCCEB does not knowingly collect personal data from individuals under 16 years of age and RCCEB does not sell the personal data of any individual under 16. If a parent or guardian believes that RCCEB has collected personal data from a minor without appropriate consent, the parent or guardian may contact RCCEB Founders Council using the contact information provided in Article 13.

Data Protection Rights

Where applicable under the GDPR or U.S. State Privacy Laws individuals may have the following rights regarding their personal data:

• Right of access: to request copies of personal data held about them
• Right to rectification: to request correction of inaccurate or incomplete data
• Right to erasure: to request deletion of personal data under certain conditions
• Right to restrict processing: to request limitation of processing under certain circumstances
• Right to object: to object to processing based on legitimate interests
• Right to data portability: to receive personal data in a portable format where applicable
• Right to limit use of sensitive personal data: to limit the use of sensitive personal data to purposes permitted under applicable law
• Right to non-discrimination: RCCEB will not discriminate or retaliate against participants for exercising any of these rights
• Right to appeal: to appeal RCCEB’s denial of any of the foregoing requests in accordance with applicable law

Requests

Requests related to these rights may be submitted to RCCEB Founders Council using the contact information provided in Article 13.

Under GDPR requirements, RCCEB Founders Council will respond to such requests within one month where applicable.

Under U.S. State Privacy Laws, RCCEB will respond to such requests within the timeframe required by applicable law.

Cookies and Website Technologies

The RCCEB website may use cookies or similar technologies to collect standard internet log information and visitor behavior data. Cookies help improve the functionality of the website and provide information about how visitors interact with the site. Users may control or disable cookies through their browser settings.

Links to Other Websites

The RCCEB website may contain links to external websites operated by third parties.

This Privacy Notice applies only to the RCCEB website and community.

RCCEB is not responsible for the privacy practices of external websites. Users are encouraged to review the privacy policies and/or privacy notices of any third-party websites they visit.

Changes to this Privacy Notice

RCCEB may update this Privacy Notice from time to time as the initiative evolves.

Updated versions may be published on the RCCEB website or communicated to participants through RCCEB communication channels.

Contact Details

For questions regarding this Privacy Notice or requests related to personal data, participants may contact RCCEB Founders Council through this email address: admin [at] rcceb [dot] org.

If necessary, further contact details may be provided on the RCCEB website or through RCCEB communication platforms.