Privacy Policy

Welcome to "Roamer" an application privacy policy. Roamer App is a mobile application ("App") that is owned and operated by Tek Travels FZCO ("TBO", "we", "our", or "us") that helps you access and manage a trip that has already been booked for you by your travel advisor. Roamer keeps your trip in one place — your itinerary, bookings, vouchers and travel documents — and lets you ask questions about your trip in a chat. Roamer does not book, sell, change or cancel travel; those remain with your travel advisor.

This Policy applies to the Roamer mobile app; Roamer does not operate a consumer website. This Policy is available inside the app at any time, and is presented to you when you first sign in, alongside the consent you provide before using Roamer.

We are committed to protecting and respecting your privacy. This Privacy Policy sets out the basis on which your personal data, as a visitor to our App, will be collected or processed by us. When you visit our App, we may use your personal data in connection with your request for or use of our services.

When you book a trip through a travel advisor who uses TBO's travel booking B2B platform, your advisor shares your booking with Roamer and invites you to access it, including inviting you to download and use the Roamer App. You then confirm your identity using your mobile number and a one-time OTP code before your trip details become available to you. This is why your trip is already set up when you first sign in: your advisor has shared it with you through Roamer.

In view of the above and in accordance with applicable data protection laws, we are both a processor and controller, for the data where we determine how and why your limited personal data is processed in the Roamer app, we act as a controller of your personal data and where all your relevant travel data is being shared with us through agencies, we are the processor of the personal data.

For all the travel bookings and related data, your travel advisor shall be the individual controller under the applicable data protection laws and we shall only act as the processor in those cases.

We are responsible for safeguarding your personal data which will, either be collected or processed in accordance with this Privacy Policy. Please read this Privacy Policy carefully to understand how we will use your personal data.

This Privacy Policy is shown to you when you first sign in to Roamer. At that point you are asked to consent to App accessing and using your filled mobile number details for generating OTP and trip information to provide the service described here, and to receiving service messages about your booking. You can withdraw consent for optional processing (such as notifications) at any time in your device or app settings, and you can ask us to delete your account and data as described in 'Your rights' below.

If you have any questions about your personal data, how we look after it or if there are any changes to your personal data, please Email us at app@roamermobileapp.com

When you access the App, we may collect the following data as a controller:

1. Your name and mobile number, for us to verify your identity and access to your booking details, and we collect such personal data as a controller in accordance with this Privacy Policy.
2. Chat data:
   • The questions you ask Roamer in chat and the answers provided, so we can respond to you and improve the quality of answers.
3. Device & technical data:
   • Technical Data: we may automatically collect data regarding general technical use of the App, such as your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We may also receive technical data about you if you visit other Apps through the App using our cookies.
   • Usage Data: we may generate information about how you navigate and engage with our App, including clickstream data, page interaction information, your preferences (including country and language), and methods used to browse away from our content or App.
   • Basic technical information needed to run the app and deliver notifications, such as device type, operating system, app version, and push-notification tokens (if you enable notifications).
   • Limited in-app usage information about how the app is performing and being used, to fix problems and improve the app. We use Segment to collect and route this usage data and Amplitude to analyse it. This is product-analytics data about how the app is used; it is not used for advertising.
   • Location: we can identify the country that you are located in based on your IP address.

Further, we also process the data related to your trip, as a processor in order to show you about your trip, answer your questions, and keep you informed about your bookings. We collect the following data as a processor:

1. Booking & trip data:
   • The details of the trip your travel advisor has shared with you — such as your itinerary, hotels, flights, transfers, tours, dates, number of travellers, vouchers and confirmations.
   • Any documents you choose to add to your Vault.

We will only use your personal data where we have a valid lawful basis to do so. We have included a table below which lists all the ways in which we use your personal data and the lawful bases we rely on to do so. Where the legal basis listed is not available under applicable law, we deem that you have provided consent for the processing set out under this privacy policy by agreeing to this privacy policy.

Where we mention "legitimate interests", this is the lawful basis we rely on when we feel that it is necessary to use your personal data for a reason which is in our and/or your interests and which does not unfairly affect your rights over your personal data.

We collect or process, as the case may, your personal data as mentioned above for the following purposes:

1. To verify your identity and give you secure access to your trip.
2. To show you your itinerary, bookings, vouchers and trip details.
3. To answer your questions about your trip in chat.
4. To send you service messages about your booking — for example, confirmation that your trip is ready to view, or an update if a booking changes.
   • Messages and notifications- Roamer keeps you informed about your trip through in-app messages, push notifications (if you allow them), and messages sent to the mobile number your travel advisor registered — including via WhatsApp. These are service messages about your booking, such as your booking confirmation and identity verification (one-time passcode). To send these WhatsApp messages we use Twilio as our messaging provider, and the messages are delivered over the WhatsApp Business Platform operated by Meta. Twilio and Meta process your mobile number and the message content for the purpose of delivering these messages to you. You can control push notifications in your device settings.
5. To keep the App secure, reliable and working properly, and to improve it.
6. To identify any problems, defects or issues with the App.
7. To optimise the performance of the App and to improve future versions of the App.
8. To monitor operations, user activity and networks for fraud prevention and crime detection.
9. Lawful basis:
   • To perform our contract with you or to take steps prior to entering into a contract with you.
   • To satisfy our legitimate interests (to run and operate the App and maintain our records).
   • Your express consent (where legally required to do so, particularly for recording the data for assistance).
   • Necessary for compliance with a legal obligation to which we are subject.

We will only use your personal data for the reasons we have set out above. If we need to use your personal data for any other reason, we will let you know and tell you the reason along with the relevant lawful basis, unless the law prevents us from doing so.

We share your personal data only where needed to operate Roamer and meet our legal obligations:

• Your travel advisor / agency: the advisor who booked your trip and invited you to Roamer, in connection with your trip and their service to you.
• Our service providers: trusted third parties who help us run, secure and improve Roamer, under contracts that require them to protect your data. These currently include: Twilio and Meta (to deliver your WhatsApp booking and verification messages); Segment and Amplitude (to collect and analyse in-app usage data so we can improve the app); and our cloud hosting provider (to store and run the app securely).
• Regulators or law enforcement: where reasonably necessary to comply with a legal obligation, court order or lawful request, or to protect the safety of any person.
• In corporate transactions: if we are involved in a merger, acquisition, reorganisation or similar transaction, in which case your data would remain protected under this Policy or an equivalent one.
• Regulators or law enforcement agencies: we may disclose your personal information if reasonably necessary with regulators, law enforcement agencies or where mandatory under a court order: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
• To enforce our legal rights: we may also share personal data: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
• With other entities related to Roamer brand or company affiliates: when it is necessary for operational reasons such as the use of a group-wide logistics and IT infrastructure and for any administrative purposes to organise, develop and deliver our services, run our organisation and decide on future strategies.

You can ask us for more information about these organisations by contacting us using the details at the top of this policy.

We will not transfer or store your personal data outside of Europe (Ireland), except to selected third parties (such as our Suppliers and service providers) that we have instructed to help us provide the services to you. Your data is transmitted using secure, encrypted connections (HTTPS/SSL).

If we do transfer or store your personal data outside of the Europe (Ireland), we will ensure we have put adequate measures in place to protect your personal data to an equivalent data protection standard as in Europe (Ireland).

You can ask us for more information about where we may transfer or store your personal data and how we will take steps to ensure your personal data is protected by using the contact details in section 3 of this policy.

We will ensure we put security measures in place to protect your personal data from being destroyed, lost or shared with somebody that should not see it. However, we cannot guarantee your personal data will be free from every security risk that may be possible when your information is sent to and from the App.

Where we have given you (or where you have chosen) a OTP which enables you to access your account, you are responsible for keeping this confidential. We ask you not to share a OTP with anyone.

The App may include links to third-party Apps. We have no control over what these Apps do with your personal data. Please check the policies on these Apps which will tell you what they do with your personal data.

We will only keep your personal data for as long as is necessary for us to do so for the reasons we collected it for in the first place as set out in this Privacy Policy or as otherwise required by applicable laws. We store your personal data in line with legal, regulatory, financial and good-practice requirements.

If you want further information on how long we keep your personal data, please contact us using the details set out in section 3 of this policy.

As a result of us collecting and processing your personal data, you may have the following legal rights:

1. To access the personal data we hold about you and request a copy of it;
2. To ask us to correct your personal data if inaccurate or incomplete;
3. To ask us to delete your personal data where we do not have a compelling reason to continue to process your personal data in such circumstances;
4. To ask us to stop using your personal data in certain circumstances where there is no need for us to continue processing it;
5. To ask us to only use your personal data for certain things if: it is not accurate; it has been used unlawfully; or it is not relevant for the purposes it was initially collected for; and/or
6. To withdraw your consent at any time where we rely on consent to process your personal data (and where the law allows, without affecting the lawfulness of processing carried out before you withdrew your consent).
7. To object to our processing of your personal data in certain situations beyond direct marketing, for example where we rely on legitimate interests, subject to applicable legal conditions.
8. To nominate another person to exercise your data protection rights on your behalf where this is permitted under applicable law.
9. To lodge a complaint with a data protection regulator or other competent authority if you consider that our processing of your personal data infringes applicable data protection laws.

If you want to exercise any of the rights listed above at any time, please contact us using the details in section 3 of this policy. We will respond to all requests that we receive from users in accordance with applicable data protection laws. We may ask you to provide proof of identity before we can answer the above requests. In some cases, we may reject requests for certain reasons (for example, if the request is unlawful).

You also have the right to make a complaint about how we have used your personal data to:

1. Us - by contacting us by email app@roamermobileapp.com and we will always try to help you with your problem in the first instance.
2. If you're still not happy with how we have dealt with your complaint, you can contact: roamermobileapp@tbo.com
3. A data protection regulator; or
4. The national courts to seek a remedy if you think that your rights in relation to your personal data have been breached.

Roamer is intended for adult travellers and is not directed at children. We do not knowingly collect personal data from children. Where a trip includes travellers who are minors, their details are provided by the adult who manages the booking.

We may need to change this Privacy Policy as our Service develops or if the law changes. We will let you know if any important changes are made, otherwise, we will always display the latest version of our policy on our App.