1. Introduction

Roaming Intelligence Limited respects your privacy and is committed to protecting personal data. This Privacy Policy explains how we collect, use, store, share and protect personal data when you:

• visit www.roamingintelligence.com;
• contact us;
• request information or a demonstration;
• become a customer;
• use services provided or managed by us; or
• otherwise interact with Roaming Intelligence.

2. Who We Are

The organisation responsible for this Privacy Policy is:

Roaming Intelligence LimitedCompany Number: 139261CRegistered Office: Fairhaven, 118 Woodbourne Road, Douglas, IM2 3BA, Isle of ManWebsite: www.roamingintelligence.comEmail: info@roamingintelligence.com

For personal data described in this Privacy Policy, Roaming Intelligence will normally act as the data controller.

In some circumstances, particularly when providing services to enterprise customers, we may process personal data on behalf of a customer. In those circumstances Roaming Intelligence may act as a data processor, with the relevant customer or other organisation acting as controller.

3. Data Protection Law

Roaming Intelligence processes personal data in accordance with applicable Isle of Man data protection legislation, including:

• the Data Protection Act 2018;
• the Data Protection (Application of GDPR) Order 2018;
• the GDPR and LED Implementing Regulations 2018; and
• other applicable or successor Isle of Man data protection legislation.

The GDPR as applied to the Isle of Man is commonly referred to as the Applied GDPR.

4. Personal Data We May Collect

The information we collect will depend upon how you interact with us.

Identity Information

This may include:

• name;
• job title;
• employer; and
• organisation.

Contact Information

This may include:

• business email address;
• telephone number; and
• correspondence information.

Business Information

This may include:

• company name;
• industry;
• workforce information;
• connectivity requirements;
• existing roaming arrangements;
• corporate travel requirements; and
• information supplied in connection with consultancy or managed services.

Connectivity and Service Information

Where relevant to services being provided, this may include information concerning:

• mobile connectivity;
• eSIM allocation;
• eSIM activation;
• service usage;
• roaming destination or country;
• connectivity consumption;
• mobile number or service identifiers; and
• associated customer or account information.

Communications

We may retain information contained in:

• emails;
• website enquiries;
• meetings;
• telephone conversations;
• customer support enquiries; and
• other business communications.

Technical Information

When you use our website, certain information may be collected automatically, including:

• IP address;
• browser type;
• device information;
• operating system;
• website usage information; and
• cookie or similar technology identifiers where applicable.

Marketing Information

This may include information concerning:

• your marketing preferences;
• communications you have received;
• engagement with our communications; and
• your decision to subscribe or unsubscribe.

Transaction Information

Where you purchase services from us, we may process information relating to:

• services purchased;
• contracts;
• orders;
• invoices;
• payments; and
• account administration.

We seek to collect no more personal data than is reasonably required for the relevant purpose.

5. How We Collect Personal Data

We may obtain personal data:

• directly from you;
• when you contact us;
• through our website;
• when you request a consultation, demonstration or assessment;
• when you enter into a contract with us;
• through enterprise connectivity services;
• from your employer or organisation;
• through authorised technology integrations;
• from service providers and business partners;
• from referral partners; and
• from legitimate publicly available business sources.

6. How We Use Personal Data

We may process personal data to:

• respond to enquiries;
• provide quotations and proposals;
• provide requested services;
• manage customer relationships;
• conduct connectivity assessments and audits;
• analyse enterprise roaming arrangements;
• deliver consultancy services;
• provide or administer eSIM and connectivity management services;
• administer technology platforms;
• allocate connectivity services;
• provide customer support;
• manage contracts and payments;
• communicate with customers;
• improve our services and website;
• maintain the security of our systems;
• prevent misuse or fraud;
• comply with legal and regulatory requirements;
• establish, exercise or defend legal claims; and
• send relevant business communications where permitted by law.

7. Lawful Bases for Processing

Depending upon the circumstances, we may rely upon one or more lawful bases for processing under the Applied GDPR.

Contract

Where processing is necessary to:

• take steps before entering into a contract; or
• perform a contract with you.

Legitimate Interests

Where processing is necessary for legitimate business purposes and those interests are not overridden by the rights and interests of the individual.

Examples may include:

• administering our business;
• responding to business enquiries;
• improving our services;
• maintaining customer relationships;
• protecting our systems; and
• appropriate business-to-business marketing.

Legal Obligation

Where processing is necessary to comply with an applicable legal requirement.

Consent

Where you have provided valid consent for a specific purpose.

Where processing relies upon consent, you may withdraw that consent at any time.

Withdrawal will not affect the lawfulness of processing conducted before consent was withdrawn.

8. Enterprise Customer Data

When Roaming Intelligence provides enterprise connectivity, eSIM management or related services, personal data may be provided by a customer's organisation or generated through provision of the service.

Depending upon the service and contractual arrangement, Roaming Intelligence may act as either:

• controller;
• processor; or
• in different capacities for separate processing activities.

Where we act as processor, we will process personal data in accordance with:

• documented instructions from the relevant controller;
• applicable contractual requirements; and
• applicable data protection law.

Appropriate data-processing provisions will be incorporated into relevant enterprise agreements where required.

9. Sharing Personal Data

We may share personal data where reasonably necessary with organisations including:

• technology providers;
• cloud hosting providers;
• telecommunications providers;
• mobile network operators;
• eSIM providers;
• connectivity providers;
• CRM providers;
• business software providers;
• professional advisers;
• accountants;
• payment providers;
• communications platforms;
• contractors;
• suppliers; and
• regulatory, judicial, law-enforcement or public authorities where legally required.

We will take reasonable steps to ensure organisations processing personal data on our behalf protect that information appropriately.

Roaming Intelligence Limited does not sell personal data.

10. International Transfers

Telecommunications, eSIM and cloud services can operate across multiple countries.

As a result, personal data may sometimes be processed or accessed outside the Isle of Man.

Where personal data is transferred internationally, Roaming Intelligence will take appropriate steps to ensure the transfer complies with applicable Isle of Man data protection legislation.

Depending upon the circumstances, this may include:

• reliance upon an applicable adequacy arrangement;
• appropriate contractual safeguards; or
• another legally permitted transfer mechanism.

11. Data Retention

We retain personal data only for as long as reasonably necessary for:

• the purpose for which it was collected;
• providing services;
• maintaining appropriate business records;
• legal and regulatory requirements;
• accounting and tax requirements;
• contractual requirements; and
• establishing, exercising or defending legal claims.

Different categories of information may therefore have different retention periods.

Where information is no longer required, it will be securely deleted, anonymised or otherwise appropriately disposed of.

12. Data Security

We implement appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• unlawful processing;
• accidental loss;
• destruction;
• alteration;
• misuse; and
• unauthorised disclosure.

Measures may include access controls, authentication, encryption, secure cloud services, device protection and other appropriate security safeguards.

Access to personal information is limited to individuals and service providers who reasonably require access for legitimate business purposes.

13. Your Data Protection Rights

Subject to applicable law and relevant exemptions, you may have rights including:

• the right to be informed about processing;
• the right to access your personal data;
• the right to have inaccurate information corrected;
• the right to request erasure in certain circumstances;
• the right to restrict processing in certain circumstances;
• the right to data portability where applicable;
• the right to object to certain processing;
• the right to withdraw consent where processing is based upon consent; and
• rights relating to automated decision-making and profiling where applicable.

To exercise a data protection right, contact: info@roamingintelligence.com

We may need to verify your identity before responding to your request.

14. Cookies and Website Analytics

Our website may use cookies and similar technologies to:

• operate the website;
• maintain website security;
• remember preferences;
• understand how visitors use the website;
• measure website performance; and
• improve our services.

Where required by applicable law, non-essential cookies will not be used until appropriate consent has been obtained.

Further information may be provided through our cookie controls and/or Cookie Policy.

15. Marketing Communications

We may communicate with existing and prospective business customers regarding Roaming Intelligence products and services where permitted by applicable law.

You may opt out of marketing communications at any time by:

• using an unsubscribe mechanism contained in the communication; or
• contacting info@roamingintelligence.com.

Opting out of marketing communications will not prevent us from sending necessary contractual, service, security or administrative communications.

16. Third-Party Websites

Our website may link to websites, platforms and services operated by third parties.

Roaming Intelligence is not responsible for the privacy practices of independent third parties.

You should review the privacy information of the relevant organisation before providing personal data to it.

17. Complaints

If you have concerns about how Roaming Intelligence processes your personal data, please contact us first so that we can investigate.

You may contact us at: info@roamingintelligence.com

You may also have the right to lodge a complaint with the Isle of Man Information Commissioner.

18. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to:

• our services;
• our technology;
• our business practices; or
• applicable legal requirements.

The latest version will be published on www.roamingintelligence.com together with its revision date.

19. Contact Us

For questions regarding privacy or data protection, contact:

Roaming Intelligence Limited

Fairhaven

118 Woodbourne Road

Douglas

IM2 3BA

Isle of Man

Company Number: 139261C

Email: info@roamingintelligence.com

Website: www.roamingintelligence.com

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