Last Updated: March 1, 2015
“Contract Data” means Personal Information about our customers’ customers or our customers’ personnel that ROAMWORKS Processes in connection with providing products and services to a customer under a customer contract. Contract Data is a subset of “Personal Information.”
“Personal Information” means information relating to an identified or identifiable natural person to the extent such information is afforded the protection of law. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural, or social identity.
“Process” means any operation or set of operations which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure, or destruction.
ROAMWORKS’ Customer Obligations with Respect to Contract Data
Collection of Personal Information
The Personal Information ROAMWORKS may collect about you includes, but is not limited to, user IDs and passwords; demographic information; contact details, such as your name, address, email address, or telephone number; geo-location data; or education or employment data.
You may provide Personal Information to ROAMWORKS in a variety of ways, such as by registering for an on-line account or event, joining a mailing list, purchasing a product or service, applying for employment, filling out an information form, or otherwise contacting us with a question, comment, or request. Additionally, ROAMWORKS may collect information about you or obtain Personal Information from third parties. ROAMWORKS may also use certain technologies to collect information about you while you are visiting the Websites, as described below. ROAMWORKS will obtain Personal Information about you only by fair and lawful means.
With respect to Contract Data, it is our customers’ responsibility to ensure that ROAMWORKS‘ collection and processing of their customers’ Personal Information is consistent with the terms of such customers’ own privacy policies.
Use of Personal Information
ROAMWORKS will use Contract Data consistent with applicable contractual obligations and applicable law. ROAMWORKS also may use Contract Data to facilitate compliance with regulatory and legal requirements.
Fulfilling Business Transactions. ROAMWORKS may use your Personal Information to fulfill business transaction requests with you or your organization. With respect to our customers, such requests may include, but are not limited to, providing products or services, such as delivering notifications of product fixes and updates, or contacting you in response to your questions, comments, or requests. With respect to our suppliers, such requests may include, but not be limited to, issuing purchase orders, receiving invoices, or providing other information such as forecasts. If, in providing support (including support to assist you with the use of our Websites), we engage you telephonically through tools such as online chat, we may monitor or record our interaction for purposes of quality assurance, training, or to document the details of a transaction.
Recruitment. If you seek employment with ROAMWORKS, you may provide us with information about yourself, such as a resume. We may use this information throughout ROAMWORKS in order to consider you for employment purposes, and may keep your information on file for future consideration and to support ROAMWORKS’ compliance with applicable legal requirements.
Disclosure of Personal Information
We may share Personal Information with third-party suppliers and service providers that help us Process Personal Information. It is ROAMWORKS’ practice to enter into contracts with our suppliers and service providers that require them to handle your information in a manner consistent with ROAMWORKS policy and applicable law.
ROAMWORKS also may provide information that identifies you at an individual level to third-party business partners, such as resellers. ROAMWORKS does not, however, sell or rent such information to these third parties.
From time to time, ROAMWORKS may contemplate entering into various business development activities which may include the sale, purchase, merger, or reorganization of one or more of its businesses. These business development activities may require the disclosure of Personal Information to the prospective or actual purchaser(s). When such disclosures are required, ROAMWORKS will seek appropriate protections of your Personal Information.
In certain circumstances, ROAMWORKS may use or release Personal Information to third parties when disclosure is required by law (e.g. statute, judicial proceeding, court order, or subpoena). We also reserve our right to use or provide your Personal Information to third parties, including law enforcement, auditors, consultants, and government officials, to protect ROAMWORKS’ rights or property, and/or the rights or property of our customers, business partners, suppliers, or other third parties.
Setting Your Privacy Preferences and Opting Out
Accessing and Maintaining the Accuracy of Your Personal Information
ROAMWORKS strives to maintain the accuracy of any Personal Information we collect, and we provide several mechanisms to allow you to review and request correction or deletion of Personal Information related to you where it is inaccurate (except where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated). We may, however, take reasonable steps to verify your identity before granting you access to your Personal Information. With respect to Contract Data, the ROAMWORKS customer is responsible for maintaining the accuracy of the Personal Information it collects about you.
You may use the contact mechanisms specified below to request that we update, correct, or delete your Personal Information on file with us (subject to the limitations set forth in the preceding paragraph). Requests to access, correct, or delete Personal Information controlled by third parties (such as Contract Data) must be made through that third party.
As described in more detail below, the Websites may employ a variety of tools to help us improve your experience on our Websites and determine the effectiveness of certain of our marketing initiatives.
Internet browsers typically have a default setting to “automatically accept cookies.” Most browsers, however, permit users to change their settings either to refuse all cookies or to selectively accept them. If you would like to change your browser’s cookies settings, please refer to the online help offered with your browser or to the manufacturer’s website. Please note, however, if you decide to turn off cookies, there may be some features of our Websites that may not be available to you and some pages may not display properly.
Other Technology ROAMWORKS May Use to Improve Your Experience. ROAMWORKS may also use other technology to improve your experience.
Analysis tools.ROAMWORKS may use Google Analytics to help us analyze the data we obtain from cookies and other technologies. If you wish to turn off Google Analytics, Google has provided a browser add-on for many commonly-used browsers. Please visit Google’s website to obtain this add-on: https://tools.google.com/dlpage/gaoptout/.
Log File Information. ROAMWORKS records log file information whenever you access our Websites. Examples of log file information include your IP address, your browser type, the page from which you accessed our Websites, the pages you viewed while visiting our Websites, the last page you viewed before you exited our Websites, and the page you accessed after leaving our Websites. We use this data in the aggregate and do not use it to identify you individually.
Web Links. Emails from ROAMWORKS may contain links that are designed to take you to a Web page after redirection through ROAMWORKS’ servers (or those of its suppliers). We use the information we obtain during the redirection process to determine whether a particular marketing initiative is effective, and may collect information connected to your identity. If you do not want ROAMWORKS to collect information about the links that you click, you can choose a text-based version of the message (if the option is available). You may also choose not to click the links we provide in the emails we send to you.
Local Shared Objects (“Flash Cookies”). ROAMWORKS may use Adobe Flash Player® to deliver multimedia content, such as a video, to you. To improve your user experience, ROAMWORKS may use Flash local shared objects (LSOs) – sometimes called “flash cookies” – to store your flash content information and preferences, similar to other types of cookies ROAMWORKS employs. You can manage flash cookies by accessing the following link on Adobe’s website:
In addition, users of the Mozilla Firefox browser can install an extension that detects and deletes flash cookies. You may obtain this add-on by accessing the following link:
Some browsers permit users to adjust browser settings or may contain add-ons to help you manage your ad choices. Please refer to the online help offered with your browser or to the manufacturer’s website.
You may opt out of the third party’s advertising network. We have provided the following information to help you with this choice:
The Network Alliance Initiative and the Digital Advertising Alliance websites offer opt-out tools to assist you in managing your choices for participating companies. For more information about these tools please visit NAI Opt-Out Page and DAA Opt-Out Page.
Please note that, even if you exercise your choices, you may still receive generic, non-targeted ads from ROAMWORKS.
Protection of Your Personal Information
Our Websites offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, please contact us . In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
ROAMWORKS’ applications and Websites are not directed to, nor do we knowingly collect Personal Information from, children under the age of 13. By your use of our Websites you affirm that you are at least 13 years of age. ROAMWORKS does not knowingly solicit data from or market to children under the age of 13. If you are a parent or a guardian, and you believe your child has provided ROAMWORKS with Personal Information without your consent, please contact us .
ROAMWORKS FZ, L.L.C.
Attn: Global Privacy Office
Office 110-114, Building 14
Dubai Internet City
P.O. Box 500229, Dubai, UAE