Privacy Policy was last updated on December 12, 2023.

1: Introduction

Roam Network AG is a company incorporated in the Canton of Zug, Switzerland (registration number CH-170.3.048.014-0) (hereafter referred to as "Roam," "we," or "us," as the context may require). Roam is committed to protecting the privacy of its users. This Privacy Policy outlines our practices regarding the collection, use, and disclosure of information through the Roam App and Roam Analytics Console. Our objective is to maintain transparency with users and comply with relevant data protection legislation in Switzerland, the European Union, and the United States. This policy applies to all services and products offered by Roam Network. We are dedicated to respecting user privacy and ensuring that personal data is handled responsibly and in accordance with applicable laws. This Privacy Policy applies to your use of the Roam mobile application (the "Roam App") and use of the Roam reward point ("Roam Point(s)"), any website operated by Roam Network (including http://roamnetwork.xyz) (the "Roam Network Website(s)") and the services we provide that are accessible via any of them (the "Services"). This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be stored and processed by us.

2: Information Collection
Categories of Personal Information and Usage
1. Account Information: This includes your username, password, subscription details, and associated account information. It is used for service provision under the Terms of Use and retained for the life of the account and a legally compliant time thereafter.
2. Measurements Data: This encompasses mobile network signal strength, quality, and performance data. It is used to maintain and improve service standards and is retained for the account's duration and a legally compliant period thereafter.
3. Automatically Collected Data: This covers device information, location data (both general and precise), IMSI, and IMEI numbers. It is used for service improvement and marketing and is retained as per the account duration and legal compliance.
4. Roam Points Data: This includes information regarding user participation in the Roam Points program. It is used for user engagement and rewards and is retained in line with account activity and legal requirements.
Legal Basis for Processing.
The processing of all categories of personal information is based on Roam Network's legitimate interest in providing, maintaining, and improving its services and engaging users through the Roam Points program.

3: Sharing and Disclosure
Recipients of Data
Primary Recipients: Data collected by Roam Network, as detailed in Chapter 2, is primarily shared with Roam Customers.
Circumstances of Sharing
Explicit Permission: Users give explicit permission for their data to be shared with Roam and Roam Customers. This sharing is essential for users to receive Roam Points.
Data Protection in Sharing: Compliance with Laws: Roam Network adheres to applicable data protection laws in sharing data with third parties. This ensures that user data is handled responsibly and securely.

4: User Rights and Choices
Depending on your location, you may have, among others, the following rights under applicable data protection law:
1. Opt-Out of Marketing: You can opt out of marketing by clicking 'unsubscribe' in our emails or by emailing privacy@roamnetwork.xyz with 'unsubscribe' as the subject.
2. Change Personal Information: Access and modify your account information through the app.
3, Access to Personal Information: Request a copy by emailing privacy@roamnetwork.xyz with 'data access request' as the subject.
4. Account Deletion: Delete your account and personal information via the Roam app (Help section -> Contact us -> Delete Account).
5. Object to Data Use: Object to data processing based on legitimate interests.
5. Data Portability: Receive or transfer your personal data in a machine-readable format.* Withdraw Consent: Withdraw your consent for data processing.
6. Limit Data Processing: Request limitation on data processing, especially when data accuracy is contested.
Please note that these rights are not absolute, and exceptions under applicable law may apply. To exercise any of these rights, follow the steps outlined or contact us as specified.

5: Data Security and Breach Handling
Data Security Measures
Roam Network implements appropriate technical and organizational measures to protect personal information against unauthorized access, destruction, loss, alteration, or misuse. This commitment extends to requiring contracted parties to adhere to reasonable data security measures, in compliance with applicable laws and regulations.
Breach Response
In case of a security breach affecting users, Roam Network may communicate directly via email or other means, or post a notification on the Help and Support Security Center. Users are advised to contact Roam Network at privacy@roamnetwork.xyz if they suspect any compromise of their data.

6: International Transfers of Information
Roam Network may transfer personal information to countries other than the user's country of residence. These international transfers are conducted on the basis of legally compliant mechanisms, including standard contractual clauses and the APEC Cross-Border Privacy Rules. Users can request a copy of the relevant contractual clauses by emailing privacy@roamnetwork.xyz with the subject "international transfers."
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7: Minimum Age Requirement
Roam Network's services are intended for users who are 13 years of age or older. Individuals under 13 years of age are not permitted to use the Services or provide any personal information to Roam Network. This policy is in place to ensure compliance with laws pertaining to the protection of children's privacy.

8: Changes to This Policy
Roam Network reserves the right to update or modify this Privacy Policy at any time. Changes to the policy will be communicated to users through the Roam Network services or via email. Users are encouraged to periodically review this policy for any updates. Continued use of the services after any modifications indicates acceptance of the new terms.

9: Contact
If you have any questions, comments, or requests related to this Privacy Policy, please feel free to contact us at privacy@roamnetwork.xyz with the subject line "enquiry." We welcome your inquiries and will address them promptly.

ANNEX 1 – COOKIES

We use cookies to distinguish you from other users of the Roam App and Roam Network Website(s) and to obtain certain information about your usage and behavior. A cookie is a small file of letters and numbers that we place on your computer when you use the Roam App or Roam Network Website(s). This helps us provide you with a better experience when you use the Roam App or browse the Roam Network Website(s) and also allows us to improve the Services. We use both persistent cookies, which can remain on your device until their expiration (which, in some cases, is up to 10 years), and session cookies, which are temporary files removed from your device once your browser is closed.
Cookies we use
The types of cookies we may use include:
1. Strictly Necessary Cookies: These are required for the operation of the Roam App and Roam Network Websites. They include, for example, cookies that enable you to log into secure areas of our websites.
2. Analytical/Tracking Cookies: These allow us to recognize and count the number of visitors and analyze the use of the Services, as well as verify transactions.
3. Advertising and Retargeting Cookies: These allow us to generate appropriate advertising directed to you on the Roam Network Website(s) as well as on the Roam App and other third-party websites.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You may block cookies by activating the appropriate setting on your browser, but if you do so, you may not be able to use all functionalities of the Services.
We use several industry-standard data analytics tools, such as Google Analytics and Facebook Analytics. These collect certain information about you, such as your device’s IP address and browsing and usage behavior, and are used to allow us to track and monitor the traffic visiting the Roam App and Roam Network Website(s).

Consent to use cookies
We will ask for your permission (consent) to place cookies on your device when using the Roam Network Websites, except where these are essential for us to provide you with the service that you have requested.
There is a notice on our home page that describes how we use cookies and requests your consent before we place any non-essential cookies on your device.How to turn off cookies. If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our websites.

ANNEX 2 – NOTICE TO UNITED STATES RESIDENTS
This Annex 2 is incorporated into the Privacy Policy and includes additional information for residents of the United States regarding the collection and use of their Personal Data. The term “Personal Data,” as used in Annex 2, includes “personal information” as defined in the California Privacy Rights Act (“CPRA”).

PERSONAL DATA
The following subsections detail the categories of Personal Data that we collect and have collected over the past twelve (12) months. For each category of Personal Data, these subsections also set out the source of that Personal Data, our commercial or business purpose for collecting that Personal Data, and more information regarding those sources and categories are set forth below

Categories of Personal Data We Collect
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Profile or Contact Data
Examples of Personal Data Collected:
* First and last name
* Email* Phone number
* Unique identifiers such as username and password
Profile photo
* Source: You
Categories of Third Parties with Whom We Share this Personal Data:
* Service Providers
* Advertising Partners
* Analytics Partners
* Business Partners/Marketplace Providers
* Parties You Authorize, Access, or Authenticate, including Other Users Device/IP Data

Device  /IP Data
Examples of Personal Data Collected:
* IP address
* Device ID
* MSISDN
* IMSI
* Domain server
* Type of device/operating system/browser used to access the Services
* Internet service provider
Mobile Network Operator
* Source: * You
Third parties, including Analytics Partners
* Categories of Third Parties with Whom We Share this Personal Data:
* Service Providers
* Advertising Partners
* Analytics Partners

Consumer Demographic Data
Examples of Personal Data Collected:
* Age/date of birth
* Zip code
Gender
* Source:You
Categories of Third Parties with Whom We Share this Personal Data:
* Service Providers
* Advertising Partners
* Analytics Partners
* Business Partners/Marketplace Providers
* Parties You Authorize, Access, or Authenticate, including Other Users

Geolocation Data
Examples of Personal Data Collected:
* IP-address-based location information
* GPS dataTime zone setting
* Source:You
Categories of Third Parties with Whom We Share this Personal Data:
* Service Providers
* Advertising Partners
* Analytics Partners
* Business Partners/Marketplace Providers
* Parties You Authorized, Access, or Authenticate, including Other Users

Categories of Data Considered “Sensitive” Under the CPRA
Other Identifying Information that You Voluntarily Choose to Provide
Examples of Personal Data Collected:Identifying information in emails, letters, or texts you send us or in your survey responses
* Source:You
Categories of Third Parties with Whom We Share this Personal Data:
* Service Providers
* Parties You Authorize, Access, or Authenticate, including Other Users

Other Examples of Personal Data Collected:
* Your contacts
Any Personal Data or other identifying information that you include in your user bio
* Source:You, Third parties, including Social Networks
Categories of Third Parties with Whom We Share this Personal Data:
* Service Providers
* Advertising Partners
* Analytics Partners
* Business Partners/Marketplace Providers
* Parties You Authorized, Access, or Authenticate, including Other Users

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
Providing, Customizing and Improving the Services
* Creating and managing your account or other user profiles
* Processing orders or other transactions; billing.
* Providing you with the products, services or information you request.
* Meeting or fulfilling the reason you provided the information to us.
* Providing support and assistance for the Services.
* Improving the Services, including testing, research, internal analytics and product development.
* Personalizing the Services, website content and communications based on your preferences.
* Doing fraud protection, security and debugging.
* Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the CPRA

Marketing the Services
* Marketing and selling the Services.
*Showing you advertisements, including interest-based or online behavioural advertising.
Corresponding with You
* Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Roam or the Services.
* Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
* Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
* Protecting the rights, property or safety of you, SweatCo or another party.
*Enforcing any agreements with you.
*Responding to claims that any posting or other content violates third-party rights.
*Resolving disputes.


Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
Providing, Customizing and Improving the Services
* Creating and managing your account or other user profiles
* Processing orders or other transactions; billing.
* Providing you with the products, services, or information you request.
* Meeting or fulfilling the reason you provided the information to us.
* Providing support and assistance for the Services.
* Improving the Services, including testing, research, internal analytics, and product development.
* Personalizing the Services, website content, and communications based on your preferences.
* Doing fraud protection, security, and debugging.
* Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the CPRA.

Marketing the Services
* Marketing and selling the Services.
* Showing you advertisements, including interest-based or online behavioral advertising.

Personal Data Sales
In this section, we use the term ‘sell’ as it is defined in the CPRA. We sell your Personal Data, subject to your right to opt-out of these sales.

As described in Annex 2, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CPRA, sharing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section. Otherwise, we do not sell your Personal Data to third parties.

Personal Data Sharing
Under the CPRA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We have shared the following categories of Personal Data for the purposes of cross-contextual behavioral advertising:
* Profile or Contact Data
* Device/IP Data/MSIDSN/IMSI
* Web Analytics
*Social Network
* Data Consumer
* Demographic
* Data
* Geolocation Data
* Categories of Data Considered “Sensitive” Under the CPRA
* Other

As described in Annex 1, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CPRA, sharing your data through third party Cookies for online advertising may be considered a “sale” of information. You can opt-out of data selling and/or sharing by following the instructions in this section.
We share Personal Data with the following categories of third parties:
* Marketing providers (including for cross-contextual behavioral advertising purposes)
* Service providers
* Other users (where certain information, such as profile data, is visible to all users)
* Business partners
* Third parties in connection with a business transaction, such as merger or sale
* Law enforcement, regulators, governmental authorities and other parties for legal reasons



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