Escudo & 20

DRAFT for legal review · version 2026-10-v1

Privacy & Data Retention Policy

1. Controller

Impulso Tranquilizado, Unipessoal Lda [company number, address], operator of the Escudo & 20 club. Contact: [privacy email]. The Portuguese version prevails.

2. What we collect

  • Registration: name, email, mobile number.
  • Identity check: staff look at your ID in person; we do not keep a copy, only who checked it and when.
  • Membership and payments: membership type and validity; payment details are handled by Stripe and we do not store them.
  • Entry: entry log (date, time, result) and invitations (who invited whom).
  • Club activity: event RSVPs, suggestions and votes.
  • Cameras and sensors: fixed cameras and the robots' sensors [cameras, LiDAR, microphones: specify] capture general views of the room, in which you may appear.
  • General views of the room for training: only with consent (section 4).
  • We do not collect your gameplay (inputs, screen, game accounts) for training.

3. Purposes and legal bases

  • Managing membership, entry and payments: performance of the contract.
  • Invoicing and tax obligations: legal obligation.
  • Security, preventing account sharing, and safe robot operation: legitimate interest.
  • Model training and sharing with JuliaHub: consent.

4. Data for research and model training (optional)

With your consent, footage of general views of the room in which you appear [specify: video from fixed cameras and robot sensors; audio yes/no] is used and shared with JuliaHub, Inc. [role: controller/processor; location] for research and model training, including models for autonomous robots.

  • It is optional and not a condition of membership.
  • You can withdraw consent at any time in your account. Collection stops when you withdraw. [What happens to data already collected and to models already trained: to be decided.]
  • The cameras see the whole room, so we only record for training during events marked as recorded, where everyone present has consented: during those events only people who consented for that event are let in. Outside those events there is no recording for training. Recorded events are marked in the agenda and at the door. [Security cameras outside these events: yes/no, to be decided.]

5. Who receives data

Stripe (payments), the website host [name], the email service, the certified invoicing provider [name], the accountant and, only with consent, JuliaHub. [Transfers outside the EEA and safeguards: to be decided.]

6. How long we keep it

  • Account and membership: while you are a member and [N] months after.
  • Entry log: [N] months.
  • Invoices and accounting records: the legal period [confirm with the accountant].
  • Consent records: as long as needed to demonstrate consent.
  • Footage for training: until you withdraw consent or [period], subject to section 4.
  • Recordings without consent: [N] days, for safety only.

7. Your rights

Access, rectification, erasure, restriction, portability, objection and withdrawal of consent, via [email]. You can also complain to the Portuguese data protection authority, CNPD (cnpd.pt).

8. Changes

We announce changes to this policy; new versions must be accepted before your next entry.