Privacy Policy
romOrom Privacy Policy
Last updated: May 13, 2025
1. Introduction
romOrom, Inc. ("romOrom," "we," "us," or "our") is deeply committed to safeguarding the privacy and security of individuals who interact with our digital properties and related services. This Privacy Policy sets forth the principles that govern our collection, usage, disclosure, retention, and protection of personal information through our website, www.romorom.com, our mobile application (the "App"), and any services, features, content, or applications offered in connection therewith (collectively referred to as the "Services").
2. Acceptance and Scope
By accessing or using the Services, you acknowledge that you have carefully read and understood the terms of this Privacy Policy. If you do not agree with any provision of this policy, you are advised to refrain from using the Services.
This policy applies globally and outlines how personal data is processed in jurisdictions including, but not limited to, the United States, the European Union, the United Kingdom, and other territories where local data protection laws may vary. Our headquarters and primary data operations are based in the United States.
3. Categories of Personal Information Collected
We may collect personal information directly from you when you register for an account, purchase connectivity services, fill out forms, or otherwise engage with our Services. Information that we collect may include your full name, email address, country of residence, account credentials, and any preferences you choose to provide. In addition, technical data may be collected automatically through your device, including Internet Protocol (IP) addresses, operating system versions, browser types, mobile identifiers, usage activity, device settings, and crash diagnostics.
Where necessary and with your explicit consent, we may collect geolocation data to customize your access to available eSIM data plans and determine applicable pricing based on your current region. Furthermore, we retain records of data usage and financial transactions relating to the acquisition and deployment of eSIM services, including details regarding volume of data consumed, region of use, and transaction amounts.
We also maintain detailed records of any communications you have with us. This includes, but is not limited to, email correspondences, telephone conversations, live chat sessions, and other forms of engagement. In jurisdictions where it is legally permissible, such communications may be recorded for quality assurance, training, and security purposes.
4. Use of Cookies and Tracking Technologies
The information collected through cookies and similar tracking technologies plays a critical role in optimizing and personalizing the functionality of our Services. Cookies are small data files stored on your browser or device that enable the recognition of your browser during future visits and facilitate features such as seamless navigation and secure authentication.
We use both session cookies, which expire once you close your browser, and persistent cookies, which remain on your device for a longer period. These technologies allow us to remember your site preferences, language settings, and prior interactions. They also enable us to track usage trends, measure performance metrics, identify anomalies, and diagnose technical issues.
Additionally, we collaborate with a range of trusted third-party analytics and advertising partners, including but not limited to Google Analytics, Meta Pixel, and similar platforms. These partners may use cookies, SDKs, and other tools to collect anonymized or pseudonymized data on user behavior, such as time spent on pages, link clicks, screen flows, and user device characteristics. Such information is analyzed in aggregate form to help us understand which parts of the Site and App are most popular, assess the effectiveness of our marketing campaigns, and refine our user experience accordingly.
You may manage your cookie preferences through your browser’s settings, where you can choose to block or delete cookies. Some features of the Services may not function properly if cookies are disabled. Where legally required, we will request your consent before placing non-essential cookies on your device.
5. Purposes of Data Processing
Personal information may be utilized to fulfill various lawful purposes, which include, but are not limited to, the provision, maintenance, and enhancement of our Services; the administration and management of user accounts; processing payments; securing our digital infrastructure against fraudulent, unauthorized, or illegal activities; and providing tailored experiences through personalization.
We also use personal information to conduct internal analytics, user behavior research, and service development initiatives. Communication with you may occur to provide notifications, respond to inquiries, deliver updates, and issue promotional or transactional content, always in compliance with relevant consent requirements.
6. Legal Basis for Processing (EEA, UK, and Swiss Residents)
We recognize that in the context of international legal frameworks such as the European Union’s General Data Protection Regulation (GDPR), the United Kingdom’s Data Protection Act 2018, and Switzerland’s Federal Act on Data Protection (FADP), we are legally required to identify and document the appropriate legal basis for all personal data processing activities. Our processing of personal data concerning residents of the European Economic Area (EEA), the United Kingdom (UK), and Switzerland is based on one or more of the following lawful bases, as defined under these applicable data protection laws:
Performance of a Contract: We process personal information when it is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract. For instance, we require your name, contact details, and payment information to deliver purchased connectivity services, manage your account, and handle billing operations.
Compliance with Legal Obligations: Processing is undertaken when necessary to comply with a legal or regulatory obligation to which romOrom is subject. This includes our obligations in areas such as taxation, fraud prevention, telecommunications regulation, and consumer protection laws.
Legitimate Interests: In certain cases, we process personal information where it is in our legitimate interest to do so, provided that such interests are not overridden by your fundamental rights and freedoms. Examples include improving and securing our Services, analyzing usage patterns to enhance user experience, and preventing or detecting unlawful behavior.
Consent: Where required by law, we obtain your explicit, informed, and freely given consent to process certain types of personal data, such as when placing non-essential cookies on your device or sending you promotional communications. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
Vital Interests: In rare and exceptional cases, we may process personal data to protect the vital interests of the data subject or another natural person, such as in emergencies involving health or safety threats.
When we rely on legitimate interest as a legal basis, we conduct a balancing test to ensure that our interests are not overridden by your privacy rights. Our Data Protection Officer or appointed compliance advisor documents and reviews such assessments regularly.
If you require further clarification regarding the specific legal basis applicable to a particular data processing activity, you may contact us using the details provided in the Contact Information section of this Privacy Policy.
7. Disclosure of Personal Information
We may disclose personal information to third-party service providers who facilitate our operations, including web hosting services, payment processors, cloud infrastructure providers, customer support platforms, marketing partners, and analytics vendors. These service providers are contractually obligated to process data in accordance with applicable privacy regulations and solely for the purposes instructed by us.
In the event of a reorganization, merger, acquisition, or sale of assets, personal information may be shared with or transferred to the relevant parties as part of that transaction. We may also disclose information to regulatory bodies, courts, or enforcement authorities when required to comply with a legal obligation or to protect the rights, property, and safety of romOrom, our users, or the public.
8. International Data Transfers
Your information may be stored and processed in jurisdictions outside of your own, including countries that may not afford the same level of data protection. We implement robust data transfer mechanisms, such as Standard Contractual Clauses, to ensure adequate safeguards are in place for such cross-border transfers.
9. Data Retention
We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy. Retention periods are determined based on the nature of the data, the purpose of processing, relevant legal obligations, and any potential need to preserve information for dispute resolution or enforcement of our terms.
10. Your Data Protection Rights
Depending on your geographic location, you may be entitled under applicable law to request access to the personal data we hold about you, seek rectification of inaccurate data, request deletion of your data, object to certain processing activities, or request data portability. You also have the right to withdraw consent where the processing is based on consent, without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise any of your rights, you may contact us at info@romorom.com. We may ask for proof of identity or other information to verify your request before proceeding. Please note that not all rights are absolute and may be subject to legal exemptions or limitations.
11. Marketing Communications
You may opt out of receiving marketing emails at any time by following the unsubscribe instructions in the emails you receive or by adjusting your preferences within your account settings. Notwithstanding your marketing preferences, we reserve the right to send transactional or service-related communications as necessary to fulfill our contractual or legal obligations.
12. Children's Privacy
The Services are not intended for or directed to children under the age of eighteen (18). We do not knowingly collect personal data from minors. If we discover that personal information from a person under the age of 18 has been collected, we will take immediate steps to delete such information. Parents or guardians who believe that their child has submitted personal data to us are encouraged to contact us promptly.
13. Data Security Measures
We employ industry-standard administrative, technical, and organizational measures to safeguard personal information from loss, theft, unauthorized access, disclosure, alteration, or destruction. These measures include encryption, secure access controls, and regular security assessments. However, no system can guarantee complete security, and users are advised to maintain confidentiality of their account credentials and to notify us immediately of any suspected breach.
14. Third-Party Links and Services
Our Services may contain links to third-party websites or integrate with third-party platforms. We are not responsible for the content or privacy practices of these external entities. We encourage users to review the privacy policies of any third parties before providing personal information.
15. Changes to this Privacy Policy
We reserve the right to amend this Privacy Policy to reflect changes in our data practices, technological developments, legal requirements, or for any other operational reasons. When changes are made, the revised Privacy Policy will be posted with an updated effective date. Where required by law, we will provide advance notice of material changes to this Privacy Policy. If the nature of the change requires a renewed form of user agreement or acknowledgment under applicable law, your continued use of our Services after such notice may serve as your implied consent to the revised terms, unless a more explicit form of acceptance is mandated.
16. Contact Information
For any questions or concerns about this Privacy Policy or how we handle your data, please email us at info@romorom.com or write to us at: romOrom, 2187 Overlook Rd, Cleveland, Ohio, United States.
romOrom Privacy Policy
Last updated: May 13, 2025
1. Introduction
romOrom, Inc. ("romOrom," "we," "us," or "our") is deeply committed to safeguarding the privacy and security of individuals who interact with our digital properties and related services. This Privacy Policy sets forth the principles that govern our collection, usage, disclosure, retention, and protection of personal information through our website, www.romorom.com, our mobile application (the "App"), and any services, features, content, or applications offered in connection therewith (collectively referred to as the "Services").
2. Acceptance and Scope
By accessing or using the Services, you acknowledge that you have carefully read and understood the terms of this Privacy Policy. If you do not agree with any provision of this policy, you are advised to refrain from using the Services.
This policy applies globally and outlines how personal data is processed in jurisdictions including, but not limited to, the United States, the European Union, the United Kingdom, and other territories where local data protection laws may vary. Our headquarters and primary data operations are based in the United States.
3. Categories of Personal Information Collected
We may collect personal information directly from you when you register for an account, purchase connectivity services, fill out forms, or otherwise engage with our Services. Information that we collect may include your full name, email address, country of residence, account credentials, and any preferences you choose to provide. In addition, technical data may be collected automatically through your device, including Internet Protocol (IP) addresses, operating system versions, browser types, mobile identifiers, usage activity, device settings, and crash diagnostics.
Where necessary and with your explicit consent, we may collect geolocation data to customize your access to available eSIM data plans and determine applicable pricing based on your current region. Furthermore, we retain records of data usage and financial transactions relating to the acquisition and deployment of eSIM services, including details regarding volume of data consumed, region of use, and transaction amounts.
We also maintain detailed records of any communications you have with us. This includes, but is not limited to, email correspondences, telephone conversations, live chat sessions, and other forms of engagement. In jurisdictions where it is legally permissible, such communications may be recorded for quality assurance, training, and security purposes.
4. Use of Cookies and Tracking Technologies
The information collected through cookies and similar tracking technologies plays a critical role in optimizing and personalizing the functionality of our Services. Cookies are small data files stored on your browser or device that enable the recognition of your browser during future visits and facilitate features such as seamless navigation and secure authentication.
We use both session cookies, which expire once you close your browser, and persistent cookies, which remain on your device for a longer period. These technologies allow us to remember your site preferences, language settings, and prior interactions. They also enable us to track usage trends, measure performance metrics, identify anomalies, and diagnose technical issues.
Additionally, we collaborate with a range of trusted third-party analytics and advertising partners, including but not limited to Google Analytics, Meta Pixel, and similar platforms. These partners may use cookies, SDKs, and other tools to collect anonymized or pseudonymized data on user behavior, such as time spent on pages, link clicks, screen flows, and user device characteristics. Such information is analyzed in aggregate form to help us understand which parts of the Site and App are most popular, assess the effectiveness of our marketing campaigns, and refine our user experience accordingly.
You may manage your cookie preferences through your browser’s settings, where you can choose to block or delete cookies. Some features of the Services may not function properly if cookies are disabled. Where legally required, we will request your consent before placing non-essential cookies on your device.
5. Purposes of Data Processing
Personal information may be utilized to fulfill various lawful purposes, which include, but are not limited to, the provision, maintenance, and enhancement of our Services; the administration and management of user accounts; processing payments; securing our digital infrastructure against fraudulent, unauthorized, or illegal activities; and providing tailored experiences through personalization.
We also use personal information to conduct internal analytics, user behavior research, and service development initiatives. Communication with you may occur to provide notifications, respond to inquiries, deliver updates, and issue promotional or transactional content, always in compliance with relevant consent requirements.
6. Legal Basis for Processing (EEA, UK, and Swiss Residents)
We recognize that in the context of international legal frameworks such as the European Union’s General Data Protection Regulation (GDPR), the United Kingdom’s Data Protection Act 2018, and Switzerland’s Federal Act on Data Protection (FADP), we are legally required to identify and document the appropriate legal basis for all personal data processing activities. Our processing of personal data concerning residents of the European Economic Area (EEA), the United Kingdom (UK), and Switzerland is based on one or more of the following lawful bases, as defined under these applicable data protection laws:
Performance of a Contract: We process personal information when it is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract. For instance, we require your name, contact details, and payment information to deliver purchased connectivity services, manage your account, and handle billing operations.
Compliance with Legal Obligations: Processing is undertaken when necessary to comply with a legal or regulatory obligation to which romOrom is subject. This includes our obligations in areas such as taxation, fraud prevention, telecommunications regulation, and consumer protection laws.
Legitimate Interests: In certain cases, we process personal information where it is in our legitimate interest to do so, provided that such interests are not overridden by your fundamental rights and freedoms. Examples include improving and securing our Services, analyzing usage patterns to enhance user experience, and preventing or detecting unlawful behavior.
Consent: Where required by law, we obtain your explicit, informed, and freely given consent to process certain types of personal data, such as when placing non-essential cookies on your device or sending you promotional communications. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
Vital Interests: In rare and exceptional cases, we may process personal data to protect the vital interests of the data subject or another natural person, such as in emergencies involving health or safety threats.
When we rely on legitimate interest as a legal basis, we conduct a balancing test to ensure that our interests are not overridden by your privacy rights. Our Data Protection Officer or appointed compliance advisor documents and reviews such assessments regularly.
If you require further clarification regarding the specific legal basis applicable to a particular data processing activity, you may contact us using the details provided in the Contact Information section of this Privacy Policy.
7. Disclosure of Personal Information
We may disclose personal information to third-party service providers who facilitate our operations, including web hosting services, payment processors, cloud infrastructure providers, customer support platforms, marketing partners, and analytics vendors. These service providers are contractually obligated to process data in accordance with applicable privacy regulations and solely for the purposes instructed by us.
In the event of a reorganization, merger, acquisition, or sale of assets, personal information may be shared with or transferred to the relevant parties as part of that transaction. We may also disclose information to regulatory bodies, courts, or enforcement authorities when required to comply with a legal obligation or to protect the rights, property, and safety of romOrom, our users, or the public.
8. International Data Transfers
Your information may be stored and processed in jurisdictions outside of your own, including countries that may not afford the same level of data protection. We implement robust data transfer mechanisms, such as Standard Contractual Clauses, to ensure adequate safeguards are in place for such cross-border transfers.
9. Data Retention
We retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy. Retention periods are determined based on the nature of the data, the purpose of processing, relevant legal obligations, and any potential need to preserve information for dispute resolution or enforcement of our terms.
10. Your Data Protection Rights
Depending on your geographic location, you may be entitled under applicable law to request access to the personal data we hold about you, seek rectification of inaccurate data, request deletion of your data, object to certain processing activities, or request data portability. You also have the right to withdraw consent where the processing is based on consent, without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise any of your rights, you may contact us at info@romorom.com. We may ask for proof of identity or other information to verify your request before proceeding. Please note that not all rights are absolute and may be subject to legal exemptions or limitations.
11. Marketing Communications
You may opt out of receiving marketing emails at any time by following the unsubscribe instructions in the emails you receive or by adjusting your preferences within your account settings. Notwithstanding your marketing preferences, we reserve the right to send transactional or service-related communications as necessary to fulfill our contractual or legal obligations.
12. Children's Privacy
The Services are not intended for or directed to children under the age of eighteen (18). We do not knowingly collect personal data from minors. If we discover that personal information from a person under the age of 18 has been collected, we will take immediate steps to delete such information. Parents or guardians who believe that their child has submitted personal data to us are encouraged to contact us promptly.
13. Data Security Measures
We employ industry-standard administrative, technical, and organizational measures to safeguard personal information from loss, theft, unauthorized access, disclosure, alteration, or destruction. These measures include encryption, secure access controls, and regular security assessments. However, no system can guarantee complete security, and users are advised to maintain confidentiality of their account credentials and to notify us immediately of any suspected breach.
14. Third-Party Links and Services
Our Services may contain links to third-party websites or integrate with third-party platforms. We are not responsible for the content or privacy practices of these external entities. We encourage users to review the privacy policies of any third parties before providing personal information.
15. Changes to this Privacy Policy
We reserve the right to amend this Privacy Policy to reflect changes in our data practices, technological developments, legal requirements, or for any other operational reasons. When changes are made, the revised Privacy Policy will be posted with an updated effective date. Where required by law, we will provide advance notice of material changes to this Privacy Policy. If the nature of the change requires a renewed form of user agreement or acknowledgment under applicable law, your continued use of our Services after such notice may serve as your implied consent to the revised terms, unless a more explicit form of acceptance is mandated.
16. Contact Information
For any questions or concerns about this Privacy Policy or how we handle your data, please email us at info@romorom.com or write to us at: romOrom, 2187 Overlook Rd, Cleveland, Ohio, United States.