Privacy Policy

Last updated : November 15, 2023

Effective date : December 1, 2023

1. Introduction

This Privacy Policy (“Notice“) is designed to inform you about how Free Roaming LLC (“Free Roaming” “we” “us” or “our“) handles your Personal Data. It also outlines the information, including personal information detailed below, related to you or provided by you (“Personal Data“). This information will be collected and processed by Free Roaming and/or on its behalf by external service providers when you contact us through our channels, such as our website, after you have contracted our services. We are obligated to provide this information and inform you of your data protection rights under the General Data Protection Regulation (EU) 2016/679 (“GDPR“).

2. Free Roaming as data controller

For the purposes of this Notice, the data controller of your personal data is Free Roaming LLC, located at 1000 Brickell Ave STE 715, Miami, FL 33131, United States of America. Free Roaming is responsible for your Personal Data.

Free Roaming is committed to respecting your fundamental right to the protection of your Personal Data, and this Notice is intended to inform you about how we handle it.

3. Types of Personal Data we process about you

3.1 Website usage and Device data: When you visit our website.

  • Your visits and interactions with our website, including the pages you visit, the time and date of access, what you click on, and when you perform these actions;
  • Data from your device, including your IP address, location data, device type and language, browser type, and other related information.
  • Any associated websites you access through our website..

Most of this personal data is collected through the use of cookies on the website. Please visit our Cookie Policy for more information on how the website uses cookies.

3.2 Customer data: When you purchase an eSIM or data plan.

  • Full name; title, country of residence; current location; residential address; network provider; telephone number; payment information; e-mail address; device type (e.g. make and model); a copy of your passport, driving licence or similar documentation for identification (where necessary); and other details relating to you when you interact with us regarding the purchase of an eSIM.

4. Sources of your Personal Data

During the course of our contractual relationship or when you visit our website, we will collect your personal data in various ways: (1) directly from you, (2) indirectly from third parties (for example, through our affiliates or travel agencies once you have contracted our services).

  • When you browse our website, various cookies and tracking tools may be installed on your device, as outlined in our Cookie Policy. When we collect your personal data through the use of non-essential cookies on our website, we will request your prior consent to do so. 

5. ¿For what purpose and on what legal basis do we process Personal Data?

  1. For customers: Free Roaming may use personal data to process your service requests, handle orders, deliver products and services, process payments, communicate with you about orders, provide access to secure areas of the Free Roaming website, and enable Free Roaming to review, develop, and continually improve the products, services, and offerings it provides. Free Roaming also uses this information to prevent or detect fraud or abuse of the Free Roaming website and to allow third parties to perform technical, logistical, or other functions on its behalf. 
  2. For visitors: Free Roaming may use personal data to send information about Free Roaming to visitors and to contact them. Free Roaming also uses the information it collects to improve the content of our website, enhance user experiences, and as training material for our employees. Visitors have discretion regarding providing information to Free Roaming and may opt out of these processes as described above.
  3. For payment information: Free Roaming may request account or credit card information from account holders to process service orders. Financial information provided through our website is transferred to a third-party service provider for payment processing. Free Roaming and our third-party service provider may encrypt and store this information for record-keeping purposes related to payment processing. The third-party service provider uses credit card numbers solely for payment processing and does not use them for any other purpose. Free Roaming has entered into written agreements with our third-party service providers and will continue to do so with third parties providing payment processing services.
  4. For usage information: Free Roaming uses website usage information to gauge interest and develop its web pages and marketing plans, personalize the content you see during your visits based on your activity during previous visits, and manage the Free Roaming website. Additionally, Free Roaming uses:
    • IP addresses to help diagnose issues with its servers and manage its website;
    • cookies and other tools to help recognize users as unique when they return to the Free Roaming website. Free Roaming also uses cookies to tailor content or advertisements to your preferred interests; avoid showing visitors the same ads repeatedly; compile anonymous aggregate statistics to help Free Roaming understand how users interact with the site and improve the website’s structure; and  
    • web beacons to count the number of times your ads and web-based email content are viewed. Free Roaming combines information from web beacons with cookies to track activity on its site from ads and web-based email content.
  5. For support information: Free Roaming uses the information you provide through chat, email, web forms, and other communications to contact you about services you might be interested in purchasing. If you choose to purchase a service online via a web form, Free Roaming will use the information to set up your account. Information you submit in writing, such as chat logs, emails, and web forms, is archived and may be linked to information Free Roaming collects about your website visits.

6. ¿With whom do we share Personal Data?

Depending on the purpose for which we process your personal data, we may share it, as necessary, with some or all of the following recipients:

  • Free Roaming internal/ intra-group entities: departamentos y servicios internos (como nuestro Departamento de Ventas, Departamento de Marketing o Departamento de TI).
  • Telecommunications service providers: Service providers located in the appropriate jurisdiction for which the eSIM service was purchased.
  • Regulatory authorities and law enforcement agencies: Where we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request, such as the Revenue Commissioners, Department of Social Protection, the Data Protection Commission, Workplace Relations Commission, the Irish courts, An Garda Síochána or any other applicable authorities.  
  • Third party advisors/professionals: Professional advisors who provide professional services to us e.g. consultants, legal advisors. 
  • Third party service providers: We engage third party suppliers who may process your Personal Data on our behalf for the above Purposes. These include the following:
  • Administrative services. 
  • Advertising and communication services. 
  • Corporate social responsibility services. 
  • Maintenance services.
  • Physical security services. 
  • Archiving, custody, storage and digitalization services.
  • Document removal and destruction services.
  • Back-office services. 
  • IT services.

7. International Data Transfers

Users resident in the European Union should be aware that their personal data may be transferred to certain recipients (mainly our external service providers) located outside the European Economic Area (“EEA”), in countries with data protection laws and practices that do not provide equivalent protection for personal data (e.g., Thailand, Colombia…). In such cases, we ensure that appropriate safeguards are in place to ensure that: a) transfers are not made without our prior written authorization; and b) there is an adequate transfer mechanism, such as Module 2 of the standard contractual clauses (approved by the European Commission) or an adequacy decision by the European Commission to protect your personal data. If you would like to learn more about any transfer that may affect your personal data, please contact us at dpo@freeroaming.io.

8. Your data protection rights

8.1 Right of access: You have the right to request a copy of the personal data that Free Roaming holds about you and to access the personal data we store about you.

8.2 Right to object: You have the right to object at any time to the processing of your personal data when Free Roaming processes it based on legitimate interests.

8.3 Right to rectification: You have the right to update or correct any inaccurate personal data that Free Roaming holds about you.

8.4 Right to erasure: In certain circumstances, you can request the deletion of your personal data. For example, if you exercise your right to object and Free Roaming has no overriding reason to process your personal data, or if we no longer need your personal data for the purposes set out in this Notice.

8.5 Right to restriction of processing: You have the right to ask Free Roaming to restrict the processing of your personal data in certain cases, such as if you believe the personal data we hold about you is inaccurate or if the processing of your personal data is unlawful.

8.6 Right to data portability: You may request Free Roaming to provide the personal data you have provided in a structured, commonly used, and machine-readable format.

8.7 Right to lodge a complaint: You have the right to lodge a complaint with a supervisory authority in the EU member state of your habitual residence, place of work, or where the alleged infringement occurred.

8.8 Right to object to automated decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing of your data, including profiling, that produces legal effects concerning you or similarly significantly affects you. We may not be able to comply with this request when the processing is necessary for entering into or performing our contract with you, or when the processing is authorized by law to which we are subject.

9. How long do we retain your Personal Data

In general, we store your personal data in accordance with our obligations under applicable laws in the United States of America and the European Union and/or for the duration of our relationship with you, as well as for a reasonable period after this relationship ends. Your personal data will be retained for as long as necessary for the purpose(s) for which it was collected. The criteria used to determine retention periods include:

  • The duration of the contractual relationship plus 7.5 years from the end date;
  • If retention is prudent in light of Free Roaming’s legal position (such as with regard to statutes of limitations, litigation, or regulatory investigations);
  • If Free Roaming is subject to any legal obligations; and/or
  • 6 months for connection history and call recordings.

10. Children’s Personal Data

Free Roaming understands the importance of safeguarding personal data of minors, defined as individuals under 18 years old in Ireland or the equivalent age specified by law in their jurisdiction.

Minors under 18 are prohibited from using Free Roaming’s services. We do not knowingly collect (nor do we knowingly permit a third party to collect) personal data from individuals under 18. If we become aware that personal data from a person under 18 has been collected, we will delete this personal data and terminate that individual’s account as soon as possible.

11. ¿Who should I contact in order to exercise my data protection rights or for any questions relating to my Personal Data?

Free Roaming has a Data Protection Officer in accordance with applicable laws. If you have any questions about the information detailed in this Notice or wish to exercise your data protection rights, please contact our Data Protection Officer at dpo@freeroaming.io or our customer support team at help@freeroaming.io.

12. Updates to this Notice and other information

We will do our best to keep this Notice up to date. This Notice will be reviewed regularly and may be modified and updated periodically as necessary. Any updates to this Notice will be posted in this section of the website.

This Notice is written in English. In case of a conflict between this English version of the Notice and any translated copies, the Spanish version will prevail.