Privacy Policy

Last updated: 12 December 2025
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Purpose
Data Categories
Legal Basis
Service Provision: To create your account, track Roam Points, and provide the App functionality.
Account Data, Wallet Data
Performance of Contract (Terms of Use)
Network Mapping: To analyze signal strength and coverage quality.
Location Data, Network Identifiers, Device Data
Consent (You grant this via the App permissions)
Data Monetization: Aggregating network data to sell information and insights to Roam Customers.
Network Identifiers, Location Data
Legitimate Interest (for anonymized/aggregated data) or Consent (for raw data)
Security & Fraud Prevention: To detect GPS spoofing, bot farms, or emulation.
Device Data, IP Address, Usage Patterns
Legitimate Interest (Protecting the integrity of the Roam Network)
Marketing: To send you updates or promotional offers.
Email Address, Social Media Account Name
Consent (Opt-in)

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4. Sharing and Disclosure of Information

We do not sell your personal contact information (email, phone number) to third parties for their independent marketing purposes without your consent. However, the core nature of Roam is to crowdsource network data.

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We share data with:

  1. Roam Customers (Data Buyers): We share network measurement data with Mobile Network Operators, infrastructure companies, and analytics firms. Note: We prioritize sharing this data in an aggregated or anonymized format where the data cannot be directly linked back to you personally.
  2. Service Providers: Third-party vendors who provide infrastructure, hosting (e.g., AWS, Google Cloud), customer support, and email delivery services. These partners are bound by confidentiality agreements.
  3. Legal Requirements: We may disclose data if required by law, subpoena, or to protect the safety of any person.
  4. Business Transfers: In the event of a merger, acquisition, or sale of assets, user data may be transferred as a business asset.

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5. International Data Transfers

Roam Network AG is headquartered in Switzerland. Data we collect is processed in Switzerland and on servers which may be located in the European Union (EU) or the United States (US).

  • Switzerland/EU/UK: Switzerland has an "adequacy decision" from the EU, meaning data flows freely between these regions.
  • Transfers to the US/Other: When we transfer data to countries without adequacy decisions, we rely on safeguards such as the Standard Contractual Clauses (SCCs) approved by the European Commission and the Swiss Data Protection Commissioner.

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6. Data Retention

We retain your personal data only as long as necessary:

  • Account Data: Retained for the lifetime of your account plus a statutory period for tax/legal compliance (usually 5-10 years).
  • Measurement Data: Retained indefinitely in an anonymized/aggregated format for historical network analysis. Raw measurement data containing personal identifiers is deleted or anonymized once verified and processed.

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7. Your Rights

Regardless of your location, we grant you the following rights:

  • Access & Portability: Request a copy of the personal data we hold about you.
  • Correction: Update inaccurate data via the App settings.
  • Deletion (Right to be Forgotten): Request deletion of your account and associated personal data (Menu -> Help -> Delete Account).
  • Withdraw Consent: You may revoke location permissions or marketing consent at any time via your device settings or the 'unsubscribe' link in emails.

To exercise these rights, email: info@roam.network with the subject line "Data Subject Request."

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8. Minimum Age

Our Services are not directed to children under 13 (or 16 in the EEA/UK). We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will delete such information.

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9. Cookie Policy

We use cookies to distinguish you from other users and improve the Service.

  • Essential Cookies: Required for the App/Site to function (e.g., login sessions).
  • Analytics Cookies: Used to track usage (e.g., Google Analytics).
  • Managing Cookies: You can block cookies via your browser settings, though some features may break.

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10. Notice to United States Residents

This section applies solely to residents of California and other US states with comprehensive privacy laws.

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A. Categories of Personal Information Collected (Last 12 Months)

  • Identifiers: Name, email, IP address, device ID, IMSI.
  • Geolocation Data: Precise physical location.
  • Internet Activity: App usage logs.
  • Commercial Information: Roam Points earned.

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B. "Sale" and "Sharing" of Data

Under California law, "Sale" is defined broadly. Because Roam shares network measurement data (which may include device identifiers/location) with Roam Customers for commercial purposes, this may constitute a "Sale."

  • Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information. You can exercise this right by emailing info@roam.network with the subject "Do Not Sell My Info" or adjusting your App privacy settings.

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C. Sensitive Personal Information

We collect precise geolocation and message contents (support tickets). We use this strictly for the purpose of providing the Service (measuring network coverage) and do not use Sensitive Personal Information for inferring characteristics about you.

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D. Non-Discrimination

We will not discriminate against you (e.g., by denying services) for exercising your CPRA rights. However, please note that earning Roam Points requires data collection; if you delete your data or opt-out of collection, you may be unable to earn points.

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11. Changes to This Policy

We may update this Policy periodically. Material changes will be notified via the App or email. Your continued use of the Service after such changes constitutes acceptance.

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12. Contact Us

Data Controller:

Roam Network AG

Canton of Zug, Switzerland

Email: privacy@roam.network

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