Privacy Policy 2.0

Privacy Policy

RoamingAround Privacy Policy Version 2.0.0

 

Abstract
This document describes the privacy policy to be observed by RoamingAround and all partners utilizing the RoamingAround technology.
Dr. Michael Arner 

Revision History
Date: 
5/5/2015       Version: Created version 1.0     Contributors: M. Arner, M. Gambino
Date: 7/10/2015     Version: Modified to adhere with Twilio Privacy Policy 2.0.0     Contributors: M. Arner 

Philosophy

RoamingAround is committed to respecting and protecting the privacy of its partners, licensees, and their end-users. The company has established this Privacy Policy to explicitly communicate how any information shared with us will be used and how it will be secured. 

User Consent 

By accessing or otherwise using RoamingAround’s software and services, you agree to the terms and conditions of this Privacy Policy, and you expressly consent to the processing of your Personal Information and Anonymous Information according to this Privacy Policy. Your Personal Information may be processed by us in the country where it was collected as well as other countries (including the United States) where laws regarding processing of Personal Information may be less stringent than the laws in your country. 

Children’s Privacy

Policy.
RoamingAround’s websites and mobile application libraries are not structured to attract children. RoamingAround does not intend to collect personal information from anyone known to be under 13 years of age. We will delete from our databases any information associated with anyone known to be under 13 years of age.  We recommend that children between the ages of 13 and 18 obtain their parent’s permission before submitting information over the internet. By using RoamingAround’s software and Services, you are representing that you are at least 18 years old, or that you are at least 13 years old and have your parents’ permission to use RoamingAround’s software and services.

Information RoamingAround Collects

Policy.
An end-user accessing RoamingAround products and services from one of our web sites, or from a portable or mobile device running applications which use our libraries, may choose to share the following types of information. The end-user must explicitly “opt-in” to share this information:

  • Preference Information. Information about an end-user’s likes, dislikes, and interests. These may be explicitly given or made available to us if the end-user grants access to one or more of their social media accounts. 
  • Social Information linking an end-user to other end-users in RoamingAround’s database. These may be explicitly given or made available to us if the end-user grants access to one or more of their social media accounts.
  • Location Information. Information about an end-user’s geo-location. See below with respect to collection of this information.
  • Event Information. Information about other kinds of end-user-initiated events, such as application downloads, hotel or event checkins, and payment transactions.
  • Device Information. Information about an end-user’s mobile device-type and capabilities.
  • Information that an end-user submits in the process of creating or editing their account and user profile. For example, our registration and login process requires the end-user to provide RoamingAround with a name, valid email address and password of their choosing. When an end-user personalizes a profile and uses the features of RoamingAround’s software and services, we will collect any information voluntarily provided, and we may also request optional information to support use of our Software and Services, including but not limited to: year of birth, gender and other demographic information. 
  • Content that an end-user submits during their use of RoamingAround’s software and services, such as photos, comments, ratings and other information an end-user chooses to submit.
  • Information passively collected via technology and stored on RoamingAround’s service providers’ server logs, including, but not limited to: IP address, browser type, and operating system. RoamingAround may use cookies and navigational data such as Uniform Resource Locators (URLs) to gather information regarding the date and time of an end-user’s visit and the solutions and information the end-user searched and viewed, or on which of the displayed advertisements were clicked. This type of information is collected to make RoamingAround’s software and services more useful to the end-user and to tailor the experience to meet the end-user’s special interests and needs.
  • Information about the end-user from other sources with which an end-user has explicitly registered, companies RoamingAround has partnered with or other third parties may be associated with the other Information RoamingAround has collected about an end-user. 

Privacy Policies for RoamingAround’s Partners

RoamingAround’s services and databases are hosted on Microsoft’s Azure Cloud, the privacy policy for which is given here:http://azure.microsoft.com/en-us/support/trust-center/privacy/ 

RoamingAround uses as its SMS provider, Twilio Cloud Communications, whose privacy policy is given here: https://s3.amazonaws.com/com.twilio.prod.cms-assets/knowledgebase/2015/07/Short-Code-Privacy-Policy.pdf 

RoamingAround’s corporate Internet Service Provider is Xfinity, whose privacy policy is given here: http://www.xfinity.com/corporate/legal/privacyStatement.html  

Use of Collected Data

Policy.

  • RoamingAround may use information collected for the following purposes:
  • to fulfill end-user requests for our products and services;
  • to facilitate better user-experiences of our products and services
  • to communicate with end-users and to assist them with any questions they have about content or products; 
  • to offer end-users other products and services customized to their interests and preferences, including coupons;
  • to display content and advertising customized to end-users’ interests and preferences; 
  • to report to our licensees the end-user’s declared interests and preferences (but only where access to such data has been granted by both the end-user and the licensee whose application reports that data); 
  • to cooperate with government officials or parties in litigation under process of law or regulation, or as otherwise required or permitted by law;  

Geolocation Data Collection

Policy.
No geographical data will be collected by RoamingAround without the express consent of the end-user. RoamingAround will observe state, Federal, and international Laws regulating the collection of geographical data. RoamingAround will take all reasonable steps to disable such collection in areas where it is not allowed by law. Within the parameters established by law, the sampling rate at which geographical data is collected can be set by the customer and, within the licensee’s parameters, further modified by the end-user in any application collecting that data. 

Data Ownership

Policy.
Data collected by RoamingAround is jointly the property of RoamingAround and its customer, the owner of the application generating that Data.  This data may only be shared with other parties by the consent of both owners – unless it is (i) legally required, or (ii) in connection with a merger or acquisition of RoamingAround.

Securing Personal Information

Policy.
RoamingAround will take reasonable and appropriate steps to protect any personal information shared with us from unauthorized access or disclosure. RoamingAround use firewalls, encryption technologies (such as SSL) and physical security measures in order to prevent unauthorized use of personal information. Even though RoamingAround has taken significant steps to protect personal information, no company, including ours, can fully eliminate security risks associated with personal information.

Only employees of RoamingAround or our third-party agents who need the information to perform a specific task (for example, order processing and fulfillment) will be granted access to personal information for the duration of that task.

Personal information may be temporarily stored on the end-user’s device when offline. RoamingAround will take reasonable steps to ensure that any third party service providers are obligated to protect personal information in accordance with this Privacy Policy.

RoamingAround does not intend to transfer personal information without the express consent of both customers and end-users to third parties who are not bound to act on RoamingArounds’s behalf unless such transfer is (i) legally required, (ii) for the purpose indicated in this section, or (iii) in connection with a merger or acquisition of RoamingAround. It is against our policy to sell collected personal information except as aggregate data detached from specific persons.  

Email Opt Out

Policy.
RoamingAround will discontinue text, SMS, and push communication with any user upon request to optout@roamingaround.com (specifying email address and/or cell-phone number). 

RA Phone and Email Contact Information must be made available in an “About” section of the application. 

Contact and Revisions

If you have questions or concerns about our Privacy Policy, please contact us at: mailto: support@roamingaround.com.  

This Privacy Policy is subject to occasional revision at our discretion, and if we make any substantial changes in the way RoamingAround uses Personal Information, an alert will posted on the Privacy section of its website and email sent to the existing user base. An end-user who objects to any such changes, must cease using RoamingAround’s software and services. Continued use of RoamingAround’s software and services following notice of any such changes shall indicate an end-user’s acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Safe Harbor Compliance

RoamingAround complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. RoamingAround certifies that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view RoamingAround’s certification, please visit http://www.export.gov/safeharbor/ 

References

https://www.ftc.gov/tips-advice/business-center/guidance/can-spam-act-compliance-guide-business

https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule