Privacy Policy

1. INTRODUCTION

Roam Reality LLC and our affiliates (“Roam”, “we”, “our” or “us”) are committed to respecting and safeguarding Your privacy and to complying with applicable data protection and privacy laws. This Privacy Policy is provided to help You, the user, understand how we may collect, use, disclose, protect, and otherwise deal with Your information, whether You are a person acting on Your behalf on behalf of a business, entity, or charitable organization. This Privacy Policy applies to information collected in connection with Your access to our app and use of our Services.

By providing Your data/information to Roam, You consent to the processing of Your data in accordance with the Privacy Policy. This Policy should be read in conjunction with the Terms and Conditions, End User Agreement and Liability Waiver associated with our services.

2. KEY DEFINITIONS

This Privacy Policy uses the following defined terms:

• “Personal Data/Personal Information” means any information concerning an identified or identifiable individual (e.g. name, address, telephone number, ID number, e-mail address, date of birth, etc)
• “Process, processing or processed” means all activities involving the handling of Personal Data such as the access, collection, storage, transfer, use, disclosure, retention, amendment, erasure, deletion, and any other operative involving Personal Data.
• “Sensitive Personal Data” means Personal Data relating to the racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic or biometric data, data concerning physical or mental health or sex life, or sexual orientation of an individual, the commission or alleged commission of any offense, etc.
• “We”, “us”, “our” means Roam Reality LLC
• “You” means the User.

3. INFORMATION WE COLLECT ABOUT YOU

We use Your data to make Roam services and products work better for You and for others by creating a tailored and safe experience each time You use the app. This describes what data we collect about (which can vary depending on Your country of residence).

Roam collects and uses Your personal data with Your knowledge and consent and typically when You:

• Use Roam’s range of services that are offered, including our online, and mobile products;
• Respond to any communications from us (such as SMS, email, questionnaires, WhatsApp, surveys)
• Engage with and utilize the Roam app.
• Participate on Roam’s social media pages such as Instagram, Facebook, TikTok etc.
• Participate in any Roam’s promotional events, incentive programs or loyalty programs;
• Provide information to our customer support centre or any other affiliate or third party that Roam may from time to time engage for this purpose.

What do we collect?

The types of information collected by Roam, include but are not limited to:

• Contact information (full name, mailing address, email address and telephone number)
• Demographic information (date of birth, gender)
• Location data (while using the app)
• User Activity data (while using the app)
• Banking information (credit card number, name on credit card, security number)

4. HOW WE USE YOUR INFORMATION

We use Your data to:

• Help You log into Your account.
• Verify who You are and secure Your data.
• Ensure that the product and services are working optimally.
• Optimize safety while using the app.
• Fight fraud, follow the law, enforce our agreements.
• Figure out what improvements are required through surveys.
• Market new products, services, and updates

We may collect, use, and share information about You for the following reasons:

• Delivering the information and the support You request, including technical notices and providing assistance for problems with our Services on Your Roam account.
• Determining whether the Services are available in Your country.
• Developing new products and services.
• Displaying Your user history.
• Providing, maintaining and improving our Services.
• Doing internal research, measuring, tracking, and analyzing trends and usage.

Communicating with You about Roam:

You may receive surveys which require feedback about our Services. Providing useful information and updates about our Services to You including promotions and loyalty programmes.

5. WHEN AND WITH WHOM WE SHARE YOUR INFORMATION

We may share Your information with others in the circumstances described in this section. For example, with other people with whom You interact when You use our services; within the Roam Reality group; with service providers who help us run our services; with ad platforms that help us market and advertise our services to You; or if we need to share information to comply with the law.

With our Affiliates

With Roam Reality affiliates we may share information internally to understand how You interact with Roam app to help make our Services better for You, and to help build Services tailored to Your preferences.

With Service Providers

With Services Providers that may help us run our events, advertising campaigns, competitions, special offers and other activities.

With Emergency Personnel

With emergency personnel, in the case of an emergency, we may share limited information (including but not limited to name, image, bio data and last known location with the nearest police department, ambulance, rescue team, lifeguard or other first responder.

With Third-Party Social Media Platforms

With Third-Party social media Platforms, we may share limited information recording while You use the app and consent to share the information to the social media platform before posting.

Safety and Compliance with Law

If we believe that disclosure if reasonably necessary to (1) comply with any applicable law, regulation, legal process or governmental request; (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with our Terms and Conditions, End User Agreement or other applicable agreements or policies (iv) to protect our or our customer’s right or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

With Your Consent

We may share information with Your consent (e.g. at Your direction)

Aggregated and Anonymized Information

We also may share (with our group or affiliates) or with service providers or other third parties) aggregated and anonymized information that does not specifically identify You or any individual user of the Services.

6. YOUR CONSENT

If we do request Your consent to Process Your Personal Data or Sensitive Personal Data, You do not have to give Your consent. If You decide to give Your consent You may later withdraw Your consent at any time, by making a request to remove by emailing us at info@roamtt.com.

If You do withdraw Your consent, it will not affect: (i) processing that has already occurred or (ii) processing that is not based on Your consent.

7. QUANTITY AND QUALITY OF DATA

7.1 No excessive data

We restrict the processing of Personal Data and Sensitive Personal Data (where applicable) to the data that is reasonably adequate for and relevant to the purpose and take reasonable steps to delete all data that is not required for the applicable business purpose.

7.2 Retention Period

We will retain Your Personal Data only for the time that is necessary for the relevant purposes (in most cases the completion of Your use of the app) or to the extent reasonably necessary to apply with an applicable legal requirement. We keep Your information for a minimum of six (6) years to comply with prevailing law and guidelines. So even after You deactivate Your account, we retain copies of Your Personal Data and any quest You may have participated for a minimum of six (6) years.

7.3 Quality of Data

We take all reasonable steps to keep the Personal Data we hold about You accurate, complete, and up to date. Please notify us if Your Personal Data details change or if You become aware of any inaccuracies. You may also update Your Personal Data directly though the Roam app.

8. KEEPING YOUR PERSONAL DATA SECURE

We have appropriate technical and organizational security measures in place to protect Your Personal Data against unlawful or unauthorized Processing. This includes having secure operating systems and processes to ensure that only authorized Roam personnel and third parties with whom Roam has contracted for this purpose have access to Your Personal Data.

9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to make changes to this privacy policy from time to time in response to change in applicable data protection and privacy legislation. When the changes impact Your rights or how we use Your data in important ways, we’ll notify (30 days’) You by email (if we have Your email address) and post the revised policy on the website and app.

Updated: 22 February 2024