Privacy and Data Protection Policy and Notice
Roamability LLC and its affiliates (“Roamability”, “we”, “our” or the “Company”) respect the privacy
of our customers, prospective customers, business partners, vendors, personnel, and visitors and
users of our websites and Nexuce platform.
Roamability is a US-based entity, providing global industry-leading roaming and eSIM solutions (the
“Services”).
This policy and notice (the “Privacy Policy”) explains the types of information we may collect from
you, that we may receive about you or that you may provide in the course of your interest in our
Services, business transactions, conferences or when you visit our website and platform. We are
transparent about our practices regarding the information we collect, use, maintain and process and
describe our practices in this policy and notice. Please read the following carefully to understand our
practices regarding your personal data and how we will treat it.
For the purposes of EU General Data Protection Regulation (GDPR), US State privacy laws and other
applicable privacy laws, Roamability is a data controller (business) in relation to the personal data of
its customers and prospective customers, employees, and platform and website visitors. With
respect to Personal Data processed through our Services on behalf of our customers, including
Personal Data relating to our customers' end users, Roamability generally acts as a processor or
service provider on behalf of the relevant customer. Our customers determine the purposes and
means of such processing and are responsible for their own privacy notices and for responding to
requests from their end users. This Privacy Policy primarily describes Roamability's processing of
Personal Data in its capacity as a controller.
1. WHICH INFORMATION MAY WE COLLECT?
Summary: we collect various categories of personal data in order to meet our contractual
obligations, and also to meet various legitimate interests, such as fraud prevention and marketing.
We collect data about you in connection with your transactions with us, or in processing data for our
customers. We also collect data about our employees and site visitors. One type of data collected is
non-identifiable and anonymous information (“non-personal data”). We also collect several
categories of personal data (“Personal Data”), as described below.
Personal Data includes information that identifies or relates to an identifiable individual and that is
provided to us directly, received from third parties, or collected or generated through the use of our
website, Nexuce platform or Services. This generally includes your name (first and last), email
address, phone number, postal address, position and organization name and other information you
may choose to provide to Roamability. In connection with the Services, we may also process
technical and telecommunications data, including, as applicable, IMSI, IMEI, IP address, SIM/eSIM
and device identifiers, network and connectivity information, location or country information
derived from network use, service usage information, and related transaction and billing
information. Where such information relates to a customer’s end users, Roamability generally
processes it on behalf of the relevant customer.
You do not have any legal obligation to provide any information to Roamability, however, we require
certain information in order to perform contracts, or to provide any services. If you choose not to
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provide us with certain information, then we may not be able to provide you or your organization
with some or all of the services.
By contacting us or submitting requests for information or support via the website, email etc.,
Roamability will collect details, including also your name, phone number and personal or company
email you provided, country and other information provided by you. Roamability may use this
information to offer Roamability’s services and support.
2. HOW DO WE COLLECT PERSONAL DATA?
Summary: we collect Personal Data when you or your organization send it to us, or when a vendor,
affiliate or other business partner, sends it to us so; we collect Personal Data through our website
and services, and through our interactions with you.
We collect Personal Data required to provide Services when you register interest, or when you
provide us such information by entering it manually or automatically, or through your use of our
facilities and Services, or in connection with website visits, in the course of preparing a contract, or
otherwise in engaging with us. We also may collect Personal Data when you call us for support, in
which case we collect the information you provide us.
In providing the Services to our customers, we may also receive or generate Personal Data relating
to customers’ end users through our customers and third parties involved in providing the Services.
We also collect Personal Data through your use of our website and Nexuce platform. In other words,
when you are using the website or platform, we are aware of it and may gather, collect and record
the information relating to such usage, either independently or through the help of third-party
services as detailed below. This includes technical information and behavioral information such as
the user’s Internet protocol (IP) address used to connect your device to the Internet, your uniform
resource locators (URL), operating system, type of browser, time zone setting, the user’s
‘clickstream’ on the website, the period of time the user visited the website, methods used to
browse away from a page, and information relating to your interactions with our customer support
services. We likewise may place cookies on your browsing devices (see Cookies section below).
3. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?
Summary: we process Personal Data to meet our obligations, protect our rights, and manage our
business.
We will use Personal Data to provide and improve our services to our customers and others and
meet our contractual, ethical and legal obligations. All Personal Data will remain accurate complete
and relevant for the stated purposes for which it was processed, including for example:
Processing which is necessary for the performance of a contract to which you are a party or
in order to take steps at your request prior to entering into a contract:
● carrying out our obligations arising from any contracts entered into between you and
Roamability and/or any contracts entered into with Roamability and to provide you with the
information, products, support and services that you request from Roamability;
● verifying and carrying out financial transactions in relation to payments you make in
connection with the Services.
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Processing which is necessary for the purposes of the legitimate interests pursued by
Roamability or by a third party of providing an efficient and wide-ranging service to
customers:
● notifying you about changes to our service;
● replying to your queries, troubleshooting problems, detecting and protecting against error,
fraud or other criminal activity;
● sending marketing communications regarding Roamability’s services, events and offerings,
where permitted by applicable law;
● soliciting feedback in connection with the services;
● tracking use of Roamability Services to enable us to optimize them;
● communicating with and providing Services and support to personnel and representatives of
our customers, vendors and business partners; and
● contacting you to inform you of additional services which may be of interest to you.
Processing which is necessary for compliance with a legal obligation to which Roamability is
subject:
● compliance with applicable legal, regulatory, tax, accounting and reporting obligations;
● if necessary, we will use Personal Data to enforce our terms, policies and legal agreements,
to comply with court orders and warrants and assist law enforcement agencies as required
by law, to collect debts, to prevent fraud, infringements, identity thefts and any other
service misuse, and to take any action in any legal dispute and proceeding;
● for security purposes and to identify and authenticate your access to the parts of the
facilities.
We may collect personal data of our customers’ personnel, which will be used for the purposes set
out above. Where Roamability processes Personal Data on behalf of its customers, it processes such
data to provide the Services in accordance with the relevant customer’s instructions and
Roamability’s agreement with that customer. This may include providing and managing connectivity
and roaming services, managing and improving SIM/eSIM services, monitoring service usage, billing,
troubleshooting, security, fraud prevention and customer support.
4. SHARING DATA WITH THIRD PARTIES
Summary: we share Personal Data with our service providers, partners, and group companies, and
authorities where required.
We transfer Personal Data to:
Members of our Group: We may share Personal Data with our parent company, subsidiaries and
other affiliated companies where necessary for the purposes described in this Privacy Policy.
Third Parties. We transfer Personal Data to third parties in a variety of circumstances. Where third
parties process Personal Data on our behalf, we take appropriate steps to ensure that such
processing is subject to appropriate contractual data protection obligations. These third parties
include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of
any contract we enter into with you. They assist us in providing the services we offer, processing
transactions, fulfilling requests for information, receiving and sending communications, analyzing
data, providing IT and other support services or in other tasks, from time to time. These third parties
also include analytics and search engine providers that assist us in the improvement and
optimization of our website, and our marketing.
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We periodically add and remove third party providers. At present services provided by third-party
providers to whom we may transfer Personal Data include also the following:
- Document management and sharing services;
- Client ticketing and support;
- On-site and cloud-based database services;
- CRM software;
- ERP software;
- Customer service providers for Roamability Services;
- Network operators, connectivity providers and other telecommunications partners, as
necessary to provide the Services
- Data security, data backup, and data access control systems;
- Project management systems;
- Website analytics;
- Our lawyers, accountants, and other standard business software and partners.
In addition, we will disclose your Personal Data to third parties if some or all of our companies or
assets are acquired by a third party including by way of a merger, share acquisition, asset purchase
or any similar transaction, in which case Personal Data will be one of the transferred assets.
Likewise, we transfer Personal Data to third parties if we are under a duty to disclose or share your
Personal Data in order to comply with any legal or audit or compliance obligation, in the course of
any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and
other agreements with you or with a third party; or to assert or protect the rights, property, or
safety of Roamability, our customers, or others. This includes exchanging information with other
companies and organizations for the purposes of fraud protection and credit risk reduction and to
prevent cybercrime.
For avoidance of doubt, Roamability may transfer and disclose non-Personal Data to third parties at
its own discretion.
5. DATA STORAGE
Summary: we store your Personal Data across multiple locations globally
Personal Data may be stored and processed using Roamability’s systems and those of its service
providers in the countries and regions in which Roamability, its affiliates and service providers
operate. Information regarding international transfers is provided below.
6. INTERNATIONAL DATA TRANSFERS
Summary: we transfer Personal Data within and to the EEA, USA, Israel and elsewhere, with
appropriate safeguards in place.
Personal Data may be transferred to and processed in countries outside the country in which you are
located. Where Personal Data subject to the GDPR is transferred outside the EEA to a country that
has not been recognized by the European Commission as providing an adequate level of data
protection, we use an applicable transfer mechanism, such as the European Commission’s Standard
Contractual Clauses, or rely on another lawful transfer mechanism. Transfers to Israel may rely on
the European Commission’s adequacy decision. Transfers to eligible US recipients may rely on the
EU-U.S. Data Privacy Framework, where applicable.
We may transfer your Personal Data outside your location in order to:
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- store or backup the information;
- enable us to provide you with the Services and products and fulfil our contract with you;
- fulfill any legal, audit, ethical or compliance obligations which require us to make that
transfer;
- facilitate the operation of our group businesses, where it is in our legitimate interests and
we have concluded these are not overridden by your rights;
- to serve our customers across multiple jurisdictions; and
- to operate our parent company, subsidiaries and affiliates in an efficient and optimal
manner.
7. DATA RETENTION
Summary: we retain Personal Data according to our data retention policy, as required to meet our
obligations, protect our rights, and manage our business.
Roamability retains Personal Data for as long as reasonably necessary for the purposes for which it
was collected or processed, including to provide the Services, comply with legal, regulatory, tax and
accounting obligations, resolve disputes, prevent fraud and security incidents, and establish, exercise
or defend legal claims. Retention periods may vary depending on the nature of the data, the
purposes of processing and applicable contractual and legal requirements. Where Roamability
processes Personal Data on behalf of a customer, retention is also subject to the customer’s
instructions and the applicable agreement.
8. SERVICES AND WEBSITE DATA COLLECTION AND COOKIES
Summary: we use cookies and similar technologies on our website. Where required by applicable law,
we obtain consent before using non-essential cookies. You can also control cookies through your
device and browser settings.
Roamability uses cookies, pixel tags and other forms of identification and local storage (together
referred to as “tags/files” hereunder) to distinguish you from other users of the website. This helps
us to provide you with a good user-experience when you browse the website and also allows us to
improve our website and our services.
In many cases, these tags/files lead to the use of your device’s processing or storage capabilities.
Some of these tags/files are set by Roamability itself, others by third parties; some only last as long
as your browser session, while others can stay active on your device for a longer period of time.
These tags/files can fall into several categories: (i) those that are necessary for functionality or
services that you request or for the transmission of communications (functionality tags/files); (ii)
those that we use to carry out website performance and audience metrics (analytics tags/files) and
(iii) the rest (tracking across a network of other websites, advertising, etc.) (other tags/files).
Internet browsers allow you to change your cookie settings, for example to block certain kinds of
cookies or files. You can therefore block cookies by activating the setting on your browser that
allows you to refuse the setting of all or some cookies. However, if you use your browser settings to
block all cookies, you may not be able to access all or parts of the website, due to the fact that some
may be functionality cookies. For further information about deleting or blocking cookies, please visit:
https://www.aboutcookies.org/how-to-delete-cookies/
Cookies that are strictly necessary for the operation of the website do not require your consent.
Where required by applicable law, we will obtain your consent before using non-essential cookies or
similar technologies, such as certain analytics or advertising technologies.
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9. SECURITY AND STORAGE OF INFORMATION
Summary: we take data security very seriously, invest in security systems, and train our staff. In the
event of a breach, we will notify the right people as required by law.
We take great care in implementing, enforcing and maintaining the security of the Personal Data we
process. Roamability implements, enforces and maintains security measures, technologies and
policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or
disclosure of Personal Data. We likewise take steps to monitor compliance of such policies on an
ongoing basis. We maintain technical and organizational security measures designed to protect
Personal Data, taking into account the nature of the information, the processing activities and
associated risks.
Note however, that no data security measures are perfect or impenetrable, and we cannot
guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.
Within Roamability, we endeavor to limit access to Personal Data to those of our personnel who: (i)
require access in order for Roamability to fulfil its obligations, including also under its agreements,
and as described in this Privacy Policy, and (ii) have been appropriately and periodically trained with
respect to the requirements applicable to the processing, care and handling of the Personal Data,
and (iii) are under confidentiality obligations as may be required under applicable law.
In the event of a Personal Data breach, Roamability will take appropriate remedial measures and
provide notifications to customers, competent authorities and/or affected individuals where
required by applicable law or contractual obligations.
10. DATA PROTECTION RIGHTS
Summary: depending on the law that applies to your Personal Data, you may have various data
subject rights, such as rights to access, erase, and correct Personal Data, and information rights. We
will respect any lawful request to exercise those rights.
Data subjects with respect to whose data GDPR and other laws apply, have rights under applicable
laws, including, in different circumstances, rights to data portability, rights to access data, rectify
data, object to processing, and erase data. It is clarified for the removal of doubt, that data subject
rights cannot be exercised in a manner inconsistent with the rights of Roamability employees and
staff, with Roamability proprietary rights, and third-party rights. These rights are subject to the
conditions, limitations and exemptions provided by applicable law. For example, certain information
may be withheld where disclosure would adversely affect the rights and freedoms of others or
where another legal exemption applies. If processing occurs based on consent, data subjects have a
right to withdraw their consent.
A data subject who wishes to modify, delete or retrieve their Personal Data, may do so by contacting
Roamability (privacy@roamability.com). Note that Roamability may have to undertake a process to
identify a data subject exercising their rights. Roamability may keep details of such rights exercised
for its own compliance and audit requirements. Please note that Personal Data may be either
deleted or retained in an aggregated manner without being linked to any identifiers or Personal
Data, depending on technical commercial capability. Such information may continue to be used by
Roamability.
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Data subjects in the EU have the right to lodge a complaint, with a data protection supervisory
authority in the place of their habitual residence. If the supervisory authority fails to deal with a
complaint, you may have the right to an effective judicial remedy.
11. GENERAL
Minors. Our websites and Services are not directed to children, and Roamability does not knowingly
collect Personal Data directly from children through its websites. Personal Data relating to minors
may, however, be processed through the Services on behalf of Roamability’s customers, in which
case Roamability processes such information in accordance with the relevant customer’s instructions
and applicable law. If you are under 16, do not register or attempt to register for any of the
Roamability Service or send any information about yourself to us. If we learn that we have collected
or have been sent Personal Data from a child under the age of 16, we will delete that Personal Data
as soon as reasonably practicable without any liability to Roamability. If you believe that we might
have collected or been sent information from a minor under the age of 16, please contact us at:
privacy@roamability.com, as soon as possible.
Changes to this Privacy Policy. We may update this Privacy Policy from time to time. The updated
version will be posted on our website with an updated ‘Last Revised’ date. Where required by
applicable law, we will provide additional notice of material changes.
Roamability aims to process only adequate, accurate and relevant data limited to the needs and
purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the
purpose for which the data is gathered. Roamability only collects data in connection with a specific
lawful purpose and only processes data in accordance with this Privacy Policy. Our policies and
practices are constantly evolving and improving, and we invite any suggestions for improvements,
questions, complaints or comments concerning this Privacy Policy, you are welcome to contact us
(details below) and we will make an effort to reply within a reasonable timeframe.
If you have questions regarding this Privacy Policy, Roamability’s processing of Personal Data, or
wish to exercise your privacy rights, you may contact MyEDPO, Roamability’s Data Protection
Officer, at: privacy@roamability.com
Last Revised: 10/6/2026