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GDPR Notice

Last updated: March 17, 2026

1. Overview

This GDPR Notice supplements our Privacy Policy and provides additional information required under the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the UK General Data Protection Regulation for individuals located in the European Economic Area (EEA), the United Kingdom, and Switzerland.

Camp Fires LLC ("Camp Fires"), in collaboration with Capicua Digital Studio ("Capicua"), is committed to protecting your personal data and respecting your privacy in accordance with GDPR requirements.

2. Data Controller

The data controller responsible for your personal data is:

Camp Fires LLC
365 Toni Stone Crossing, 3rd Floor
San Francisco, CA, United States
hello@campfiresv.com

For GDPR-related inquiries, you may also contact our designated data protection contact at hello@campfiresv.com with the subject line "GDPR Inquiry."

3. Legal Basis for Processing

We process your personal data on the following legal bases under Article 6(1) of the GDPR:

PurposeLegal Basis
Processing your application and managing program registrationContract performance — Article 6(1)(b): Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract.
Sending program logistics, updates, and pre-event materialsContract performance — Article 6(1)(b)
Sending marketing communications, alumni updates, and future program invitationsConsent — Article 6(1)(a): You have given clear consent for us to process your personal data for this specific purpose. You may withdraw consent at any time.
Website analytics and improvementLegitimate interest — Article 6(1)(f): Processing is necessary for our legitimate interests in understanding how visitors use our website and improving user experience, balanced against your rights.
Complying with legal obligationsLegal obligation — Article 6(1)(c)

4. Categories of Personal Data

We collect and process the following categories of personal data:

  • Identity data: First name, last name
  • Contact data: Email address, phone number
  • Professional data: Company name, job title, professional background
  • Technical data: IP address, browser type, device information, cookie data
  • Usage data: Website interaction data, pages visited, time on site
  • Special categories (only if voluntarily provided): Dietary requirements, accessibility needs

We do not process special categories of personal data (Article 9) unless you voluntarily provide such information (e.g., dietary restrictions for event catering), in which case processing is based on your explicit consent under Article 9(2)(a).

5. Data Recipients and Transfers

5.1 Data Recipients

Your personal data may be shared with the following categories of recipients, only to the extent necessary:

  • Capicua Digital Studio: As co-organizer and workshop facilitator
  • Venue partners: IDEO, Studio by Tishman Speyer, and Notion, for logistics and access management
  • Technology service providers: Email delivery, payment processing, and website hosting providers
  • Professional advisors: Lawyers and accountants, where required

5.2 International Transfers

As Camp Fires is based in the United States, your personal data will be transferred to and processed in the United States. For transfers of personal data from the EEA/UK to the United States, we rely on one or more of the following safeguards:

  • The EU-U.S. Data Privacy Framework, where applicable
  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Your explicit consent for the transfer, provided after being informed of the risks

You may request a copy of the safeguards in place by contacting us at hello@campfiresv.com.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

  • Program registration data: Retained for the duration of the program and up to 24 months afterward for alumni communications and follow-up, unless you opt out earlier.
  • Marketing communications data: Retained until you withdraw your consent or unsubscribe.
  • Website analytics data: Retained for up to 26 months.
  • Financial and tax records: Retained as required by applicable tax and accounting laws (typically 7 years).

After the applicable retention period, your personal data will be securely deleted or anonymized.

7. Your Rights Under GDPR

As a data subject located in the EEA, UK, or Switzerland, you have the following rights under the GDPR. These rights are not absolute and may be subject to certain conditions and exceptions as defined by law:

7.1 Right of Access (Article 15)

You have the right to obtain confirmation of whether we process your personal data and, if so, to request access to that data along with supplementary information about how it is processed.

7.2 Right to Rectification (Article 16)

You have the right to request correction of inaccurate personal data and completion of incomplete personal data concerning you.

7.3 Right to Erasure (Article 17)

You have the right to request deletion of your personal data in certain circumstances, including when the data is no longer necessary for the purposes for which it was collected, or when you withdraw your consent.

7.4 Right to Restriction of Processing (Article 18)

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to its processing.

7.5 Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance, where processing is based on consent or contract and carried out by automated means.

7.6 Right to Object (Article 21)

You have the right to object to the processing of your personal data based on legitimate interests (Article 6(1)(f)). We will cease processing unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.

7.7 Right to Withdraw Consent (Article 7(3))

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

7.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority in the EU/EEA member state of your habitual residence, place of work, or place of an alleged infringement. A list of supervisory authorities is available on the European Data Protection Board website.

8. How to Exercise Your Rights

To exercise any of your rights under the GDPR, please send a written request to:

Camp Fires LLC — Data Protection
Email: hello@campfiresv.com
Subject line: "GDPR Data Subject Request"

We will respond to your request within 30 days. In complex cases or if we receive a large number of requests, this period may be extended by an additional 60 days, in which case we will notify you of the extension and the reasons for it. We may ask you to verify your identity before processing your request.

There is no fee for exercising your rights. However, if your request is manifestly unfounded or excessive (in particular, if it is repetitive), we may charge a reasonable fee or refuse to act on the request, in accordance with Article 12(5) of the GDPR.

9. Automated Decision-Making

We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you, as described in Article 22 of the GDPR.

10. Cookies

For information about how we use cookies and similar technologies, and how you can manage your cookie preferences, please refer to the cookies section in our Privacy Policy. Where required by law, we obtain your consent before placing non-essential cookies on your device.

11. Updates to This Notice

We may update this GDPR Notice from time to time to reflect changes in our data practices or legal obligations. The revised notice will be posted on this page with an updated effective date. We encourage you to review this notice periodically.

12. Contact

If you have any questions about this GDPR Notice or our data protection practices, please contact us:

Camp Fires LLC
365 Toni Stone Crossing, 3rd Floor
San Francisco, CA
hello@campfiresv.com

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