Roamless | Privacy Policy

Privacy Policy

Last Updated/Effective Date: March1, 2024

Myne Technologies, Inc. d/b/a Roamless (“Roamless,” “we,” “us,” or “our”) respects your privacy. ThisPrivacy Notice describes the processing of Personal Information (defined below)that is provided, collected, or disclosed in the course of providing our mobileapplication (“App”) and on ourwebsite that links to this Privacy Notice (“Site”).

1. Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means informationthat uniquely identifies, relates to, describes, or is reasonably capable ofbeing associated with or linked to you. The types of Personal Information we collect may include:‍

Account Information – When you create an account on our Site or App, we collect your first and last name, email address, and a password. At your option, you may also provide us with your home country in your account profile.

Website Usage Information – When you use our Site, we may automatically collect information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Site), domain names associated with your internet service provider, and any other information regarding your interaction with our Site (“Usage Information”)

Location Information – When you use our App, we will ask you to collect your location information so we can show you how much cellular data you can get for your account balance based on where you are located.

Connectivity Information – When you use our App and activate your eSIM, we will collect information about the amount of cellular data you use, what geographic location you use your cellular data in, and amounts paid by you for purchased cellular data (“Connectivity Data”).

Communication Information – We may collect Personal Information contained within your communications with us via email, online chat, and phone. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.

2. HowWe Collect Personal Information

Directly From You – We collect Personal Information that you directlyprovide to us, for example, if you choose to contact us or sign up foran account.

Through Cookies and Other Online TrackingTechnologies – We usecookies and similar technologies to collect (i) Usage Information related toactivity on our Site and (ii) Connectivity Data related to activity on our App.For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.

3. How We Use Personal Information

To the extent permitted by applicable law, we use Personal Information:

To provide and personalize our App, such as providing support, maintaining registered accounts, managing your account balance, creating and maintaining our business records, and undertaking similar activities.

For internal research and development, such as testing and verifying the quality of our Site and App, improving the quality of our Site and App, and compiling aggregated statistics about use of our Site and App.

For marketing, such as sending information about our App, including using your information to send you messages, notices, newsletters, surveys, or promotions.

For communicating with you, such as responding to your questions and comments.

For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.

As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.

4. How We Disclose Personal Information

We may disclose your Personal Information in the following circumstances:

‍Service Providers – We disclose your Personal Information with third party service providers as necessary to enable them to support our Site, App, or other aspects of our business.

‍Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Roamless, its employees and users, or the public against harm.

Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.

5. Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Site and App (“Usage Information”). We process Usage Information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Site and App, to enhance your experience through personalization, and to help us better understand the features of our Site and App that you and other users are most interested in.

We use analytics services, including Google Analytics, to assist us with analyzing Usage Information collected on our Site. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ websites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

We also allow third parties such as Google and Meta to collect certain Usage Information collected on our App to help us track conversions, measure the success of our advertising campaigns, and compile aggregated statistics about the use of our App. For more information about how Meta uses data, visit Meta’s Privacy Policy.

Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of our Site or App may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time.

6. How Long We Keep Your Personal Information

We will retain Personal Information for as long as necessary to fulfill the purposes described in this Privacy Notice, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether we need your Personal Information to provide you with the services in our App; we continue to have a relationship with you; you have requested information from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or record keeping policies and obligations dictate that we retain your Personal Information; or we have another business purpose for retaining your Personal Information.

7. How We Protect Personal Information

We use commercially reasonable efforts to protect the confidentiality and security of Personal Information. However, despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.

8. Children’s Privacy

Our App and Website are intended for individuals that are 18 years old and older, and we do not knowingly collect or solicit any Personal Information from individuals under the age of 18. In the event that we learn that we have collected PersonalInformation from someone under 18, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at support@roamless.com.

9. Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from our Site or App, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any PersonalInformation disclosed will handled in accordance with the applicable third party’s privacy notice.

10. California Residents

Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please email us at support@roamless.com. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

11. Individuals in the UnitedKingdom, European Union, European Economic Area, and Switzerland

This section provides additional information regarding Roamless’ processing of Personal Information of people located in the United Kingdom (“UK”), European Union (“EU”), European Economic Area (“EEA”), and Switzerland in accordance with the UK General Data Protection Regulation, EU Data Protection Regulation, and Swiss Federal Data Protection Act.

Legal Basis for Processing: Our legal basis for processing Personal Information depends on the Personal Information concerned and the context in which we process it. We process Personal Information from you where we need it to perform a contract with you, where the processing is in our legitimate interests (including the purposes described in this Privacy Notice), where the processing is necessary for us to meet our applicable legal obligations, or if we otherwise have your consent.

Special Category Data: Roamless does not intend to collect any Special Category Data, which is any data that reveals your racial or ethnic origin, political opinions, religious, moral or philosophical beliefs, trade union membership, political views, the processing of genetic data, biometric data for the purpose of identifying a person, and data concerning health or a person’s sex life and/or sexual orientation. Please refrain from sending us any Special Category Data.

Automated Decision Making: Roamless does not make any automated decisions on your behalf or about you without first obtaining your express, opt-in consent. In the event we secure your consent to do so, you have the right to object to the processing of Personal Information via automated decision making at any time by contacting us at support@roamless.com.

Cross-Border Data Transfers: Personal Information that we collect or receive may be transferred to and/or processed by third parties that are located outside of the EU, EEA, Switzerland or the UK, some of which applicable authorities may not consider to have an adequate level of protection for Personal Information. Roamless will only transfer Personal Information to third parties located outside of the EU, EEA, Switzerland, and the UK when it has ensured appropriate safeguards for such Personal Information through use of the standard contractual clauses or other lawful and approved methods.

12. Your Privacy Rights and How to Exercise Them

Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:

‍Access – The right to know what Personal Information we have collected about you and to access such Personal Information. Data portability – The right to receive a copy of your Personal Information in a portable and readily usable format.

‍Deletion – The right to delete your Personal Information that we have obtained, subject to certain exceptions.

‍Correction – The right to correct inaccuracies in your Personal Information. Objection/Restriction of

Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.

‍Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.

‍Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to reach out to us so we have an opportunity to address your concerns directly before you do so.

To exercise any of the privacy rights afforded to you under applicable data protection laws, please submit a request to us by calling us at (415) 481-4900 or emailing us at support@roamless.com. To opt out of marketing emails, please follow the instructions included in the applicable email. Please note that, even if you unsubscribe from certain marketed-relating correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our services to you.

13. Changes to this Privacy Notice

Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We will provide you notice if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to our Site and App.

14. Contact Us

If you have any questions about our practices or this Privacy Notice, please contact us by phone at +1 (415) 481-4900 or by email at support@roamless.com.