隐私政策

Our Data Processors

We share your data with these trusted service providers. Each one has a data processing agreement with us.

We have Data Processing Agreements in place with all processors listed above.

Affiliate Partners

When you arrive through an affiliate link, we share a referral token with Rewardful to attribute your purchase and calculate rewards. This data is kept for 90 days.

Transfer Mechanisms by Processor

Stripe, Google, Meta, Microsoft, Sentry, VWO, and Vercel transfer data to the United States under Standard Contractual Clauses (SCCs) and the EU-US Data Privacy Framework. Supabase processes data in the US under SCCs. For UK-origin transfers, we use the UK International Data Transfer Agreement (IDTA) alongside SCCs.

如何行使您的权利

如需行使上述任何权利，请发送邮件至help@helloroam.com联系我们。查阅数据或行使权利无需缴纳费用。仅当您的请求明显无根据、重复或过度时，我们才可能收取合理费用。

管理您的Cookie偏好

我们在服务中使用Cookie及类似追踪技术来存储信息并追踪活动，包括信标、标签和脚本，用于收集数据并改善我们的平台。

投诉权利

如对本隐私政策或我们的数据处理方式有疑问，请联系我们：

我们收集的个人信息

我们从加利福尼亚州居民处收集以下类别的个人信息：

• 标识符：姓名、电子邮件地址及账户凭据
• 设备信息：设备类型、操作系统及用于eSIM激活的设备标识符
• 支付信息：由我们的支付服务商安全处理的账单详情
• 使用数据：您与我们网站和应用的互动情况
• 互联网或其他网络活动：IP地址、浏览器类型及访问的页面

如何提交CCPA请求

如需行使上述任何权利，请发邮件至help@helloroam.com联系我们。邮件中请注明您的姓名、电子邮件地址及请求说明。如您持有书面授权或授权委托书，也可代他人提交请求。

身份验证流程

在处理您的请求之前，我们需要验证您的身份。我们将要求您确认与账户关联的电子邮件地址，并可能要求提供其他信息以核实身份。我们将在45天内响应您的请求。如需更多时间，我们会提前告知。

Legal Bases Under LGPD

We process your personal data based on your consent, to perform a contract with you, to meet a legal obligation, or to serve our legitimate interests. We tell you the applicable legal basis at the time we collect your data.

Your Rights Under LGPD

• Confirmation that we process your personal data and access to a copy of it.
• Correction of incomplete, inaccurate, or outdated data.
• Anonymization, blocking, or deletion of unnecessary or excessive data.
• Portability of your personal data to another service provider.
• Deletion of personal data processed with your consent.
• Information about which public and private entities we share your data with.
• Information about your option to deny consent and the consequences of doing so.
• Withdrawal of consent at any time, free of charge.
• Review of decisions made by automated means that affect your interests.

Purpose of Data Use

We use your personal data to process eSIM orders, manage your account, provide customer support, send service notifications, and improve our platform. We will not use your data for other purposes without notifying you first.

Cross-Border Transfers

Your personal data is transferred to and stored in the United Kingdom. The UK has been recognized as providing an adequate level of personal data protection by the European Commission. We apply equivalent safeguards for transfers under APPI.

Your Rights Under APPI

• Disclosure of the personal data we hold about you.
• Correction of any inaccurate personal data.
• Cessation of use or deletion of your personal data where it is no longer needed.
• Cessation of provision of your personal data to third parties.

How We Apply PIPEDA Principles

• Accountability: We are responsible for all personal information under our control and have designated a privacy contact to oversee compliance.
• Consent: We collect, use, or disclose your personal information only with your knowledge and consent, except where the law permits otherwise.
• Limiting Collection: We collect only the information we need for the identified purposes.
• Accuracy: We keep your personal information as accurate, complete, and up to date as necessary.
• Safeguards: We protect your personal information with security appropriate to its sensitivity.

Your Rights Under PIPEDA

• Access to the personal information we hold about you.
• Challenge the accuracy and completeness of your information and request corrections.
• Withdraw consent for non-essential data collection at any time.

Your Rights Under the DPDP Act

• Access to a summary of the personal data we process and how we use it.
• Correction and updating of inaccurate or incomplete personal data.
• Erasure of personal data that is no longer necessary for the purpose it was collected.
• Grievance redressal through our dedicated grievance mechanism.
• Nomination of another individual to exercise your rights on your behalf in case of death or incapacity.

AI Crawler Access

Our public website content, including eSIM pricing, coverage information, and FAQs, is accessible to AI crawlers. Your account data, personal information, and order history are never exposed to or shared with AI crawlers. We protect all personal data from AI training pipelines.

How We Use AI Internally

We use AI tools to support content research and review customer support quality. These tools process anonymized or aggregated data only. They are not used to make automated decisions about individual users.

When you participate in the HelloRoam referral program, we collect limited technical data to attribute referrals accurately and prevent fraud.

Data Collected

• IP address (anonymized after attribution)
• Browser user-agent string
• Device fingerprint (hashed, non-reversible)

Purpose

This data is used solely to attribute referral purchases to the correct referrer, prevent duplicate or fraudulent claims, and calculate referral rewards. We do not use this data for advertising or sell it to third parties.

Data Retention

Referral attribution data is retained for 90 days after the referred purchase. After this period, the data is automatically deleted. Aggregated, non-personal statistics (total referrals, reward amounts) are kept for accounting purposes.