Privacy Policy

1. Who We Are

The RoamLens App is operated by:

For privacy questions, data-access requests, deletion requests, or other privacy inquiries:

Email: roamlens@outlook.com

Geographic Availability

RoamLens is operated from Namibia and is initially intended for markets where NOVA TERRA TRADING CC can lawfully provide the App without an EU/EEA establishment or an EU representative being required.

RoamLens does not intentionally target persons in the European Union or European Economic Area as part of this initial launch.

If RoamLens later intentionally offers the App to persons in the EU/EEA in circumstances that bring additional data-protection obligations into scope, we will assess and implement the applicable requirements before doing so, including the appointment of an EU representative where required by applicable law.

Nothing in this section limits any rights or protections that may apply to a person under mandatory applicable law.

2. Information We Collect

The information we collect depends on how you use the App and which features you choose to use.

2.1 Account and Profile Information

If you create an account, we may collect information such as:

• Name or display name
• Email address
• Profile photograph, if you choose to provide one
• Account identifiers and authentication-related information
• Information associated with your account activity

You may be able to use some App functionality without providing all profile information.

2.2 Location Information

Certain RoamLens features require access to your device's location. Depending on the feature and the permissions you grant, this may include:

• Precise location
• Approximate location
• Location-derived country, city, or region
• Proximity to places or risk zones
• Location-related event information
• Location information used to support geofencing and travel-related functionality

Location may be processed by the App to provide features such as:

• Risk-zone notifications
• Places Discovery and proximity notifications
• Country or region-specific notices
• Emergency SMS functionality
• Location-based recommendations and travel information

Some location processing may occur locally on your device. Where information is transmitted to our systems, the transmitted information depends on the feature, your account status, your permissions, and the App's current implementation.

We do not state that all location information is always processed exclusively on-device or that no location information is ever transmitted.

You can control location permissions through your device's operating-system settings. Disabling location access may prevent some location-dependent features from functioning.

For background location, where supported, the App will use it only for features that require background location functionality and only where the applicable device permission has been granted.

2.3 Device and Technical Information

We may receive technical information associated with your use of the App, including, where applicable:

• Device type and model
• Operating-system version
• App version
• Device configuration
• Crash and diagnostic information
• Connectivity and network information
• General usage and interaction information
• Account or device identifiers used to operate and secure the service

We use this information to operate, maintain, troubleshoot, secure, and improve the App.

2.4 Travel, Places, and Activity Information

Depending on the features you use, the App may process information such as:

• Places you view or save
• Places you mark as visited
• Travel destinations
• Trips and itineraries
• Events you save
• Notes you create
• Reminder preferences
• Interaction with notices
• Risk-zone interactions
• Travel diary information
• Feature preferences and settings

This information is used to provide the features you request and to maintain synchronization where synchronization is available.

2.5 Regulatory Services Information

If you voluntarily use Regulatory Services, you may provide information such as:

• Country and authority selected
• Type of permit, licence, visa, or other authorization being researched
• Answers to eligibility questions
• Travel purpose and intended duration
• Application progress
• Reminder information
• Application history
• Information contained in documents you choose to use with the feature

You should not upload documents or information unless you are comfortable providing them to the relevant functionality.

Where the App allows you to select a document using your device's document picker, the document may be handled by your device's operating system and other applications involved in the action, such as your chosen email client. RoamLens does not represent that it can access or inspect every document selected through the device document picker.

You remain responsible for verifying the destination and recipients before sending documents or information through another application.

2.6 Emergency and SOS Information

The Emergency/SOS feature may process information necessary to provide emergency-related functionality, including:

• Emergency contact or service information displayed by the App
• Your interaction with emergency features
• The type of emergency action initiated
• Time and date of an action
• Location information used to prepare an emergency SMS
• Optional information you enter into an emergency message
• Feedback you voluntarily provide about an emergency feature

If you choose to send an emergency SMS, the message is sent through your device's messaging functionality. The contents of the message may be available to the recipient, your mobile carrier, your messaging application, or other providers involved in delivery.

RoamLens does not control the delivery, receipt, or response to emergency calls or messages.

2.7 Travel Wallet Information

If you use Travel Wallet, you may provide:

• Expense amounts
• Currency
• Converted amounts
• Country or city
• Expense category
• Date
• Optional notes
• Trip names
• Budget information
• Currency preferences
• Trip and expense-management information

Travel Wallet is an expense-tracking and budgeting feature. It is not a bank account, payment service, investment service, accounting service, or financial advisory service.

2.8 Notifications and Interaction Information

We may process information relating to your interaction with App notifications, including whether notifications are generated, opened, dismissed, or otherwise interacted with, where such information is available to us. You can control notification permissions through your device and, where available, through App settings.

2.9 Information You Provide to Support

If you contact us, we may receive the information you choose to provide, including your email address, account information, correspondence, attachments, and information necessary to investigate your request.

3. How We Use Information

We may use information for the following purposes:

1. To create and manage your account
2. To provide the App and its features
3. To provide location-based functionality when you grant the required permissions
4. To provide travel planning, places, events, notices, and itinerary functionality
5. To provide Regulatory Services
6. To provide emergency information and user-initiated SOS functionality
7. To provide Travel Wallet and expense-tracking functionality
8. To synchronize information across devices where synchronization is enabled
9. To maintain and improve App functionality
10. To diagnose crashes, errors, synchronization problems, and technical issues
11. To maintain security and prevent fraud, abuse, or unauthorized access
12. To communicate with you regarding your account, support requests, updates, or important service information
13. To generate statistics and analytics about use of the App
14. To provide aggregated or de-identified analytics to institutional customers where permitted
15. To comply with legal obligations
16. To enforce our Terms and protect the rights, property, and safety of RoamLens, our users, and others
17. For other purposes disclosed to you at the time information is collected or with your permission where required

4. Legal Bases for Processing Where Applicable

If a data-protection law requiring a legal basis for processing applies to you, RoamLens will rely on an appropriate legal basis for the relevant processing. Depending on the circumstances, those bases may include:

Where we rely on legitimate interests, those interests may include maintaining service security, preventing fraud and abuse, improving reliability, supporting users, and operating and improving the business, subject to applicable law and your rights.

Where we rely on legitimate interests, you may object to that processing on grounds relating to your particular situation.

Where processing requires consent, you may withdraw that consent at any time through the applicable App controls or by contacting us, without affecting the lawfulness of processing carried out before withdrawal.

5. Aggregated and De-identified Information

RoamLens may create aggregated, statistical, or de-identified information from information generated through use of the App. Examples may include:

• General place popularity
• Aggregate travel patterns
• Aggregate event-interest patterns
• Aggregate risk-zone statistics
• Aggregate notice engagement
• Aggregate emergency-feature statistics
• Aggregate spending categories or spending trends

Where we describe information as aggregated or de-identified, we intend it to be presented in a form that is not intended to identify an individual user. However, we do not make an absolute promise that data can never be re-identified under every possible circumstance.

We do not claim to use k-anonymity, differential privacy, or another specific anonymisation technology unless that technology is actually implemented for the relevant dataset.

6. Business-to-Government Analytics and Command Centre

RoamLens may offer analytics, reporting, or dashboard services to government ministries, tourism organizations, destination-management organizations, or other institutional customers.

Where such services use information derived from App activity, RoamLens may provide aggregated, statistical, or de-identified information concerning matters such as:

• Tourism activity
• Place popularity
• Travel patterns
• Event interest
• Risk-zone statistics
• Notice engagement
• Aggregate emergency-feature statistics
• Aggregate spending trends

RoamLens does not intend these products to provide government customers with an individual's name, email address, account credentials, or an individual's identifiable travel history through the Command Centre analytics products.

We will not represent an aggregated dataset as anonymous if we know that it remains identifiable.

Where applicable law requires consent or imposes restrictions on a particular type of sharing, we will comply with those requirements.

RoamLens does not sell personal information as defined by applicable law. Institutional analytics products are intended to use aggregated, statistical, or de-identified information rather than individually identifiable user information.

7. How We Share Information

We may disclose information in the following circumstances.

7.1 Service Providers

We may use third-party service providers to operate the App and related infrastructure, such as:

• Cloud hosting and database providers
• Authentication providers
• Analytics and diagnostics providers
• Push-notification providers
• Email or communication providers
• Infrastructure and security providers
• Other vendors necessary to provide the service

Our current infrastructure may include services such as Supabase, Expo push-notification infrastructure, and Sentry or comparable diagnostic services, depending on the App version and deployment configuration. Third-party providers may process information on our behalf and are expected to handle information in accordance with their contractual obligations and applicable law.

7.2 Government and Institutional Customers

As described above, we may provide aggregated, statistical, or de-identified analytics to government or institutional customers. We do not intend to provide these customers with individually identifiable user profiles through the Command Centre analytics products.

7.3 Legal and Safety Reasons

We may disclose information when reasonably necessary to:

• Comply with applicable law
• Respond to lawful requests from authorities
• Comply with court orders or legal process
• Protect the rights or property of RoamLens
• Investigate fraud or abuse
• Protect the safety of users or others
• Establish, exercise, or defend legal claims

7.4 Business Transactions

If RoamLens is involved in a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar transaction, information may be transferred as part of that transaction, subject to applicable law.

7.5 With Your Direction or Consent

We may disclose information when you specifically request or authorize us to do so. For example, when you intentionally send an email, emergency SMS, document, or other information through another application or service, that information may be processed by the service you choose.

8. Third-Party Services and Links

The App may display or link to information and services provided by third parties, including:

• Government websites
• Tourism organizations
• Event organizers
• Restaurants and other businesses
• Accommodation providers
• Transport providers
• Ticketing or booking services
• Mapping services
• Email services
• Currency-rate providers
• Other external services

RoamLens does not control the privacy practices of third parties. When you leave the App or interact directly with a third-party service, that service's privacy policy and terms apply.

9. Data Storage and Security

We use reasonable administrative, technical, and organizational measures intended to protect information against unauthorized access, alteration, disclosure, and destruction. Depending on the feature, information may be stored:

• On your device
• In RoamLens-controlled systems
• With service providers acting on our behalf
• In backups or other technical systems used to operate the service

The App is designed to support offline use for certain features. When synchronization is available and enabled, information may be transmitted to our servers when connectivity is restored.

Because the technical architecture may change over time, we do not promise a particular encryption algorithm, protocol version, database configuration, or security technology in this Privacy Policy.

No electronic system or method of transmission can be guaranteed to be completely secure.

If a personal-data breach occurs, we will notify affected individuals and relevant authorities where and when required by applicable law.

10. Data Retention

We retain information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Provide the service
• Maintain your account
• Maintain records
• Resolve disputes
• Enforce agreements
• Meet legal, accounting, or regulatory obligations
• Protect against fraud and abuse
• Maintain legitimate business records

Retention periods may vary depending on the type of information and feature. When information is no longer required, we may delete it, anonymise it, aggregate it, or otherwise securely dispose of it, subject to applicable legal or operational requirements. We do not promise a single fixed deletion period for every category of information because different systems, features, legal obligations, and backup processes may require different retention periods.

11. Account Deletion and Data Deletion

You may initiate deletion of your RoamLens account directly within the App through the account/settings area. The in-app account-deletion function is the primary method for initiating account deletion.

You may also request account or personal-data deletion by contacting: roamlens@outlook.com

When you request deletion, we will take reasonable steps to delete personal information associated with your account that we are required to delete under applicable law.

Where technically supported by the App, account deletion is intended to delete the account and associated user data maintained for the account, subject to information we are legally permitted or required to retain.

Some information may need to be retained where required or permitted by law, for example for fraud prevention, security, legal claims, accounting, or compliance.

Information that has already been irreversibly aggregated or de-identified may not be capable of being linked back to your account and therefore may not be deleted as individual user data.

Information retained for these reasons will not be used for unrelated purposes. Deletion from backups or disaster-recovery systems may occur according to the applicable backup lifecycle.

Where applicable law establishes a specific response period for a privacy request, we will respond within the timeframe required by that law.

12. Your Privacy Rights

Depending on your country or jurisdiction, you may have rights relating to your personal information, which may include:

• Access
• Correction
• Deletion
• Restriction of processing
• Objection to certain processing
• Data portability
• Withdrawal of consent where processing is based on consent
• The right to complain to a data-protection authority
• Other rights provided by applicable law

To exercise an applicable right, contact: roamlens@outlook.com

We may need to verify your identity before fulfilling a request. Your rights are subject to applicable legal limitations and exceptions.

13. California and Other U.S. State Privacy Rights

If you are a resident of a U.S. state that provides specific privacy rights, you may have additional rights under applicable state law. Depending on the applicable law, these may include rights to:

• Know or access personal information
• Correct inaccurate personal information
• Delete personal information
• Obtain or port certain personal information
• Opt out of certain sales or sharing of personal information
• Opt out of certain targeted advertising or profiling activities
• Limit certain uses or disclosures of sensitive personal information where the applicable law provides such a right

RoamLens does not sell personal information as defined by applicable law. RoamLens's institutional analytics products are intended to provide aggregated, statistical, or de-identified information rather than individually identifiable user information.

To submit a privacy request, contact: roamlens@outlook.com. We may verify your identity before processing a request. Where applicable law provides an appeal process, we will provide the applicable process when responding to your request.

14. Location Permission Controls

You can manage location permissions through your device settings. Depending on your operating system, you may be able to choose:

• No location access
• Approximate location
• Precise location
• Foreground-only access
• Background access

If you disable location permissions, features that require location may stop working or may operate with reduced functionality. RoamLens does not require you to provide location information for every feature of the App.

15. Children

RoamLens is not intended for children under 16. We do not knowingly solicit personal information from children under 16.

If you believe that a child has provided personal information to RoamLens, contact us at: roamlens@outlook.com

If we determine that we have collected personal information from a child in circumstances where deletion is required, we will take appropriate steps to delete it. Where the law in a particular jurisdiction establishes a different minimum age, the applicable legal requirement will apply.

16. International Data Processing

RoamLens and its service providers may process or store information in countries other than the country in which you live. Where required by applicable law, appropriate safeguards will be used for international transfers of personal information.

17. Regulatory Services Disclaimer

Regulatory Services provides general information intended to help users understand application processes for permits, licences, visas, and other authorisations.

RoamLens is not a government agency, immigration authority, law firm, or immigration consultancy.

Information provided by the feature may be incomplete, outdated, or changed by the relevant authority.

You should always verify current requirements with the official authority before submitting an application or relying on information provided by the App.

18. Emergency/SOS Privacy and Disclaimer

The Emergency/SOS feature is an information and communication tool. RoamLens is not an emergency service, dispatch centre, police service, medical service, or emergency responder.

The App does not guarantee that:

• Emergency information is complete or current
• An emergency call will connect
• An SMS will be delivered
• A message will be read
• A responder will act
• Location information will be accurate
• Emergency services will receive your information

If you are in immediate danger, use the official emergency services available in your location. When you use the emergency SMS functionality, you are responsible for reviewing the message and recipient before sending it.

19. Travel Wallet Disclaimer

Travel Wallet is intended for personal expense tracking, budgeting, and currency-conversion assistance. It is not financial, investment, tax, legal, accounting, or banking advice.

Exchange rates may differ from the rate ultimately provided by your bank, card issuer, exchange provider, or other financial institution.

You are responsible for verifying amounts and exchange rates before making financial decisions.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we may provide notice through the App, our website, or another appropriate method. The updated policy will include a revised Effective Date.

Your continued use of the App after an updated policy becomes effective means that you acknowledge the updated policy, to the extent permitted by applicable law.

21. Contact