Privacy Policy

Who Are We

When we refer to 'we’ (or 'our’ or 'us’), that means Roamr. Roamr is based in Ireland.

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Privacy notice overview

This Privacy Notice describes how and why we, as Data Controller, obtain, store and process personal data. 'Personal data’ means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We commit to processing your personal data fairly, lawfully, and transparently. In the spirit of data privacy principles, we will only collect and use your personal data for the following purposes, to:

• Provide our services
• Improve our services
• Make our marketing more relevant
• Meet our legal responsibilities

Please do not hesitate to contact us if you have questions in addition to the information provided in this Privacy Notice at info@roamr.org.

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The personal data we collect

Depending on the type and level of engagement you have with us, we may collect the following categories of personal data:

• Identifying and Demographic Information: such as your full name, date of birth, email address and phone number (if provided)
• Billing Information: such as payment preferences, address, bank account details (if provided)
• Communications: such as records of our interactions with you using one or multiple of the following; direct messages, emails, posts, phone conversations
• User Feedback: while using our services, occasionally you may be asked to provide feedback. Providing this feedback is entirely optional.

When you visit our website, we collect technical data such as:

• Usage data: (if permitted) we collect certain information related to your device, such as your device’s IP address, what pages your device visited, and the time that your device visited our website (for more information please see 'Our Use of Analytics' section)
• Cookies: (if permitted) your IP Address and other information provided to us by cookies (for more information please see our Cookies Policy)
• Digital Images: such as ID and photographs for verification of identity purposes

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Sensitive data

As part of providing our service to you, we will need to collect and process sensitive data (otherwise known as 'Special Categories of Personal Data'). Special Categories of Personal Data includes (but is not limited to):

• Racial or ethnic origin data
• Political opinions data
• Religious or philosophical belief data
• Trade union membership data
• Genetic or biometric data (for the purpose of uniquely identifying a natural person)
• Health data
• Sex life or sexual orientation data

We will only process or share your sensitive data with your explicit consent.

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Children

While our services are designed for a general audience, we will not knowingly collect any data from children under the age of 16 or sell products to children. If you are under the age of 16, you are not permitted to use or submit your data to the website.

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How we collect your data

We may collect your personal data in one of the following ways:

• When you create an account with us
• When you provide additional information directly into our products and services
• When you visit our website
• When you express an interest to use our services
• When you contact us for service related queries
• When you engage with us on social media
• When you review our services
• When you interact with our website (see our Cookies Policy for more details)
• When you apply for an employment vacancy with us
• When you subscribe to our newsletter or blog

We may also receive data about you from various third parties, including:

• Technical data from analytics providers. Please see further information in the section entitled 'Our Use of Analytics'
• Technical data from our website and cookies providers. Please see further information in the section entitled 'Our Use of Cookies'
• Contact and/or transactional data from our trusted third party providers. Please see further information in the section entitled 'How We Share Your Data'

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Why we process your personal data

We process your personal data in order to fulfil any of the activities below:

• Setting up an account with us
• Providing, operating, and maintaining our services
• Providing communications to existing customers or subscribed users
• Processing and completing transactions, and sending related information, including transaction confirmations and invoices
• Managing our customers’ use of our services, responding to enquiries and comments, and providing customer service and support
• Sending customers technical alerts, updates, security notifications, and administrative communications
• Investigating and preventing fraudulent activities, unauthorised access to our services, and other illegal activities

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How we use your personal data

We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it. We will only collect personal data from you when:

• We have your consent to do so, or
• We need your personal data to perform a contract with you, or
• We are pursuing our legitimate interests in a way that you might reasonably expect to be a part of running our business and that does not significantly impact your interests, rights, and freedoms. For example, communicating with you if we have a sufficient legal ground based on the e-marketing laws in your country
• We have a legal obligation to collect or disclose personal data from you (for example, in suspected instances of fraud we may need to give personal data to relevant government bodies).

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How we share your data

We sometimes share your personal data with our trusted categories of third parties we use to conduct our business. Our trusted categories of third parties include:

• Website provider
• Cloud service (SaaS) providers
• Social media providers
• Professional services providers (e.g., our lawyers, accountants, and insurance providers)
• E-marketing providers
• Advertising providers
• Recruitment partners
• Payment providers

A full list of our data sub-processors can be found in our Privacy Center on our website.

As part of fraud monitoring and prevention, we may be legally required to share your personal data with government bodies and law enforcement. Please note that these bodies may retain a record of the information that we provide to them for this purpose.

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Marketing preferences

We may send you marketing communications, product information and promotional offers:

• If you have consented to receiving such communications from us, or
• If you have recently created an account with us and not opted out of receiving such communications from us, or
• If you have bought a product or service from us and have not opted out of receiving communications from us, or
• If you are from a country where the laws permit us to send you such communications

You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us at any time:

• You can unsubscribe or 'opt-out’ by using the unsubscribe link included in the footer of any marketing message from us; or
• You can unsubscribe by managing your preferences using the Privacy Center on our website

We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers it may take a few days for any opt-out request to be implemented.

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Our use of cookies

Our website uses cookies. They help us to provide you with the very best experience when you browse our website and to make improvements to our website. You can accept or reject cookies by clicking on the cookie consent banner on our website or by navigating to the 'Cookies Preferences’ Area in our Privacy Center on our website.

For detailed information on the cookies which we use and the reasons why we use them, please refer to our Cookie Policy and Cookie Declaration in our Privacy Center on our website.

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Our use of analytics

We use analytics tools on our website and services. For example, we use tools such as Google Analytics to analyse and improve our suite of product features, website content, knowledge center content and marketing campaigns.

If you would like any further information about the data collected by these third parties or the way in which the data is used, please contact us on info@roamr.org.

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Our use of targeted advertising

We use targeted advertising tools to advertise our services, including (but not limited to):

• Google Analytics
• Facebook (including Instagram)
• TikTok
• LinkedIn
• Google Ads

We use these tools to deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the advertising provided.

If you would like any further information about the data collected by these third parties or would like to opt-out of targeted advertising, please contact us on info@roamr.org.

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Links to other websites and third parties

Our website may include links to social media platforms and other websites. If you follow a link to any of these platforms or websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their platforms or websites.

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Securing your data

The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved.

We have put in place physical, electronic and managerial security procedures in the storage and disclosure of your personal data to protect it against accidental loss, destruction or damage. Nevertheless, any data transmission over the internet or by any other means can never be fully secure, such is the character of the internet, and provision of personal data by you to us is at your own risk. We take all reasonable measures to protect your personal data by putting appropriate technical and operational security measures in place.

When we disclose your personal data to trusted third parties (for the purposes set out in this Privacy Notice and our list of Data Sub-Processors), we require all third parties to have appropriate technical and operational security measures in place to protect your personal data, and we work with them to ensure that your data privacy rights are respected. Where your personal data is shared with a third party, it must only be used for the purposes for which it was supplied.

In the unfortunate event of a personal data breach, we will notify you and any applicable data protection authority when we are legally required to do so.

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Retaining your data

We will not keep your personal data for longer than is necessary and when we no longer need to keep it, we will securely destroy, delete or anonymise it in line with our Data Retention policy.

Having obtained your consent (or other legal basis) to contact you, we will retain your personal data for marketing and analysis purposes until you withdraw your consent or unsubscribe. If you choose to withdraw your consent or unsubscribe from marketing, we will delete your personal data from our systems, unless we have another legal basis to retain it, which may include performance of our contract with you or to maintain your contact details on an 'unsubscribed list' to ensure we do not send you further communications.

We may need to retain your personal data to satisfy our legal obligations, to deal with complaints and queries, in order to resolve, litigate or defend a dispute and to prevent fraud and abuse.

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Your rights and our commitment to you

You have rights under data privacy laws and Roamr is committed to you being able to freely exercise your Rights. Where possible, we have incorporated automated tools on our website that enable you to facilitate your rights in real-time. Use the Roamr Privacy Center to access and manage your personal data that we process and manage your preferences. You are not required to pay any charge for exercising your rights. Your rights include, under certain circumstances, the right to:

• Be informed: you have the right to be informed if and how your personal data is being processed.
• Access, rectification, or erasure: you have the right of access to personal data we hold about you in our records. You are also entitled to have your personal data corrected if it is inaccurate, or to have it erased if we do not have a legitimate reason for retaining your data.
• To request data portability: for personal data which you have provided to a controller, where processing was based on your consent, or where processing is done by automated means, you have the right to obtain a digital copy of your personal data, request the transfer of your personal data to another company or request to move your data from one IT system to another in a safe and secure way.
• To request restriction of processing: you have the right to restrict the processing of your personal data where you are contesting the accuracy of that information, you have objected to processing (as described below), or where the processing is unlawful. Where processing is restricted, we may need to retain sufficient information about you to ensure that the restriction is respected in future.
• To object to automated decision-making including profiling: you have the right not to be the subject of any automated decision-making or profiling by us.
• To withdraw consent: in cases where we are relying on your consent for the processing of your personal data, you have the right to withdraw your consent at any time. In respect of the e-marketing we conduct, an unsubscribe option is included with every e-marketing communication we send.
• To object to processing: where your personal data is being processed based on the legitimate interests of a data controller or third party, you have the right to object to that processing.
• To complain to the relevant supervisory authority: should you have any concerns or complaints regarding the way in which we process your data, you also have the right to make a complaint to the relevant European Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach a Supervisory Authority, so please do contact us in the first instance info@roamr.org. The contact details of European Supervisory Authorities can be found here:
  https://edpb.europa.eu/about-edpb/about-edpb/members_en-member-lv
• Cookies Preferences: you can accept or reject cookies by navigating to the ‘Cookies Preferences’ Area in our Privacy Center on our website. You can also do so by adjusting your web browser controls. Please consult our Cookie Policy for more information about our use of cookies on the website and how to accept and reject them.

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Changes to this privacy notice

We may update this privacy notice from time to time and we will inform all our paying customers and users subscribed to receive communications from us of any changes.

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How to contact us

We welcome feedback and are happy to answer any questions you may have about your data. You can contact us at:
Email: info@roamr.org