Privacy Policy

1. Who we are, and who is responsible for your data

1.1 This policy explains what Roamlu does with personal data when you use the Roamlu website at roamlu.com, the Roamlu mobile app, or any of the services we sell: travel eSIM data plans, a Roamlu phone number with calls and texts, a VPN subscription, an AI travel advisor, in-app chat with friends, a stored-value wallet, loyalty points, referrals and gift codes.

1.2 Roamlu is responsible for your personal data as described in this policy. Roamlu is in the process of incorporating its operating company. Before we accept live payments, we will publish the company's full legal name, registered address, licence details and any tax registration on this page, and let account holders know.

1.3 How to reach us about privacy:

• For every privacy question and data-rights request, email hello@roamlu.com.
• We answer data-protection requests within one month. We reply to general support messages within 5 working days.

2. The short version

This is a summary. It is not a substitute for the rest of the policy.

• We hold your account details, your purchases and payments, your eSIM records, your Roamlu phone number, and the history of what you did with them.
• We store the content of your text messages. Both the ones you send and the ones you receive on your Roamlu number are kept in our database, in readable form, for as long as your account exists.
• We store details of every call. That means who called whom, when, how long, and the raw technical record from our telecoms supplier. We do not record calls and we do not transcribe them.
• If you use the optional "find friends" feature, your phone's address book is uploaded to us. That means names and phone numbers, and we keep them, including the numbers of people who are not Roamlu users.
• Chat messages with other Roamlu users are stored on our servers and are not end-to-end encrypted.
• What you type into the AI travel advisor is stored on your account and sent to an outside AI company (Anthropic, or Mistral if Anthropic is unavailable) to produce the answer.
• If you use the free VPN, you will see ads from Google AdMob, which receives your device's advertising identifier. You can reset or limit that identifier in your device settings.
• One-time sign-in codes may be sent to you by WhatsApp or by SMS.
• We do not ask for your location. There is no GPS or location permission in the app on either platform.
• We never ask for identity documents, passports, selfies or face scans. Our identity check is a phone-number check only.
• We never see your card number. Card payments are handled by Stripe.
• When you delete your account, sign-in access and your email address and phone number are removed. To have everything else erased, email hello@roamlu.com. Section 12 explains exactly how this works.
• Do not use Roamlu to contact emergency services. Emergency calls made through Roamlu may fail, may reach the wrong service and cannot share your location. Use your phone's own dialler or a local line.

3. What we collect, why, and our legal basis

The legal bases named here are: contract (we need the data to give you what you bought), legal obligation (tax, accounting, telecoms and anti-fraud rules), legitimate interests (a specific business need that does not override your rights), and consent (you chose to switch it on).

3.1 Your account

What: your email address, name, phone number in international format, a hashed password, account status, role, your market (which is used to work out any tax that applies), your language, whether your email and phone are verified, whether two-factor authentication is on, your loyalty balance, your referral code, and the dates the account was created, changed, or scheduled for deletion.

Why: to create and run your account, to sign you in, to work out whether VAT or a similar tax applies to your purchases, and to show the app in your language. Where VAT or a similar tax applies, it is shown before you pay.

Basis: contract. Legal obligation for the tax-relevant parts.

3.2 Sign-in security

What: your two-factor secret and backup codes if you turn 2FA on; password-reset tokens; one-time codes we send you and the email address or phone number we sent them to; and, briefly, a copy of your sign-up details held in temporary storage for 10 minutes while you finish verifying.

How codes reach you: one-time codes for signing up, signing in and resetting a password may be sent to your phone by WhatsApp or by SMS, or to your email address.

Why: to verify it is you, and to let you reset a password.

Basis: contract, and legitimate interests in keeping accounts secure.

3.3 Sessions and devices

What: each active sign-in session, the device name, your IP address, when it was last used, and when it expires or was revoked.

Why: to keep you signed in, to let you see and end your other sessions, and to detect a stolen session token being reused.

Basis: contract, and legitimate interests in security.

3.4 Social sign-in

What: which provider you used (Google, Apple or Facebook) and the anonymous account identifier that provider gives us. We do not receive or store a password from them.

Why: to let you sign in without a Roamlu password.

Basis: contract.

3.5 Consent records

What: which version of our policies you accepted, which choices you made (analytics, personalised AI, marketing), when, and your IP address at that moment.

Why: to prove what you agreed to and when.

Basis: legal obligation. We have to be able to show what you consented to.

3.6 Phone identity check

What: your phone number, its country, whether it is a mobile line, which carrier operates it, whether the check passed, and the full technical response our supplier returned about the number.

Why: to check whether a number is a real mobile line, and to prove you control the number. The result is recorded on your account; it does not block any purchase or service.

Basis: legitimate interests in preventing fraud and abuse of telecoms services.

What this is not: we do not collect identity documents, passports, ID cards, selfies, liveness checks or any biometric data.

3.7 Payments and billing

What: the payment reference from Stripe, what you bought, the amount, currency and status, the tax breakdown, the receipt we generate, your Stripe customer reference, your wallet balance and every movement in and out of it, your loyalty points and redemptions, promotions and gift codes you used, and any subscription you hold.

We never see or store your card number, expiry date or security code. Card payments are handled by Stripe, and those details go directly from your device or browser to Stripe.

Why: to take payment, to issue receipts, to give refunds, to run the wallet and loyalty programme, and to keep the financial records the law requires.

Basis: contract, and legal obligation for tax and accounting records.

3.8 Your eSIM plans

What: which plan you bought, the supplier reference, the status, the destination, the data allowance and duration, the SIM identifier (ICCID), the activation details and QR string, how much data has been used and how much remains, and our cost. For our install-once eSIM we also hold a persistent profile record, your plan type, and a record of each measurement of data used.

Country data: each usage record carries a two-letter country code reported by your device at the moment of measurement, so we can show you a per-country usage breakdown and bill pay-as-you-go usage correctly. Over time this builds a rough record of which countries you used data in. It is not GPS, and it is not precise.

Why: to provision and deliver the eSIM, to show you your usage, to bill correctly, and to handle refunds.

Basis: contract.

3.9 Your Roamlu phone number

What: the number itself, its country, its status, its price, the supplier order references, and the technical credentials that let the app register as a phone client on your behalf.

Why: to buy the number for you, to route calls and texts to your app, and to keep the service working.

Basis: contract.

Who carries your calls and messages: Roamlu numbers, calls and messages are carried by third-party licensed carriers. Internet calling is restricted or prohibited in some countries, including the United Arab Emirates. You must not use your Roamlu number or calling where local law does not allow it.

Emergency calls: do not use Roamlu to contact emergency services. Emergency calls made through Roamlu may fail, may reach the wrong service and cannot share your location. Use your phone's own dialler or a local line.

3.10 Call information

What: for every call made or received on your Roamlu number, we store the numbers on both ends, the direction, the time it started and ended, the duration, the outcome, and internal call identifiers. We also store the complete raw technical event record our telecoms supplier sends us for each stage of the call.

What we do not have: we do not record the audio of calls and we do not transcribe them.

Why: to show you your call history, to route incoming calls to your device, to avoid processing the same event twice, and for support and fault-finding.

Basis: contract, and legitimate interests in operating and fixing faults in a telephone service.

3.11 Text message content

What: for every SMS sent or received on your Roamlu number, we store the two numbers, the direction, the delivery status, the supplier reference, the time, and the full text of the message, in readable form.

Where else it goes: when a message arrives for you, the message text and the sender's number are put into the push notification that Google's messaging service delivers to your phone, so that you can see the message on your lock screen.

How long, and who can see it: message records are kept for as long as your account exists. Authorised Roamlu administrators can view message records. The app does not have a button for deleting individual messages; to have your messages erased, email hello@roamlu.com (see section 12).

Why: to give you a working two-way messaging thread in the app, and to notify you of new messages.

Basis: contract.

3.12 Your contacts: other people's data

What happens: "find friends" is optional. If you use it and allow the app access to your contacts, the app reads your address book and uploads up to 2,000 entries to us. For each one we store the person's name as it appears in your phone, their phone number in readable form, and a scrambled version of that number used for matching. We keep those records against your account.

Why: so we can show you which of your contacts already use Roamlu, and let you call or message them.

Basis: consent for reading your device's address book. Legitimate interests for the matching itself.

What you should know before you turn this on:

• The people in your address book may not be Roamlu users and have not agreed to anything. We hold their names and numbers because you sent them to us.
• We keep the readable number, not only the scrambled one.
• The app does not have a function for removing contacts once they are uploaded. To have your uploaded contacts erased, email hello@roamlu.com and we will erase them.
• Each time your contact list is displayed, any stored number that did not previously match a Roamlu account is checked again. If that person later joins Roamlu, the match is made at that moment.

3.13 In-app chat with other Roamlu users

What: your friend requests and connections, your chat threads, and the text of every message, up to 4,000 characters each, together with when it was sent and read.

Chat is not end-to-end encrypted. Messages are stored on our servers in a form we can read.

Why: to run the messaging feature.

Basis: contract.

3.14 The AI travel advisor

What happens to a question, step by step:

1. You type a question.

2. Your message is saved in our database against your account, inside a conversation record.

3. Your message and up to the previous 20 messages in that conversation, plus a fixed set of Roamlu instructions, are sent over the internet to Anthropic. If Anthropic is unavailable, the same content goes to Mistral instead. If both are unavailable you get a basic scripted answer.

4. The answer comes back and is also saved against your account, along with which provider and model produced it and how many tokens it used.

What is not sent: we do not attach your name, email, user ID or account details to the request. The instructions we send are fixed product text. But you can type anything into a free-text box, so anything personal you put in your question is sent to the AI provider.

How long, and who can see it: AI conversations are kept for as long as your account exists. Authorised Roamlu administrators can access them. To have them erased, email hello@roamlu.com (see section 12).

What the advisor cannot do: it gives advice only. It cannot buy anything, change your settings, or move money.

Why: to answer your travel-connectivity questions.

Basis: contract for providing the feature. Consent where you have enabled personalised AI.

3.15 The VPN

What we store: which server you connected to, whether the event was a connect or a disconnect, when it happened, and a short technical note (for example, that it was a reconnection). If you connect to a server we operate ourselves, we also store the public key your device generated and the internal address assigned to it.

What we never receive: your device's private key. It never leaves your phone.

What we cannot see: the contents of your traffic through the tunnel.

What someone else does see: when you connect, your device connects directly to a gateway operated by OneConnect, which resells Private Internet Access. That gateway sees your real IP address and the metadata of the traffic passing through it. Their own policies govern what they do with that traffic.

Why: to allocate you a server and show you your connection history.

Basis: contract, and legitimate interests in operating the service.

3.16 Notifications

What: the notifications we have sent you, your notification preferences, and the push tokens that identify your device to Google's and Apple's push services.

Why: to tell you about payments, deliveries, missed calls and new messages.

Basis: contract for service messages. Consent for marketing messages.

Defaults: push and email notifications about your account and orders are on by default. Marketing push notifications are off by default.

3.17 Support

What: if you contact us, we store your email, name, subject, message, how you contacted us, and our replies. You can contact us without being signed in, in which case the message is not attached to any account.

Why: to answer you.

Basis: contract, and legitimate interests in providing support.

If you contacted us without being signed in and later want that message erased, email hello@roamlu.com from the same email address and tell us roughly when you wrote to us, so we can find it and confirm it is yours.

3.18 Website visitors (roamlu.com)

What: if, and only if, you accept analytics cookies, each page you view is recorded with a visitor identifier, a session identifier, your IP address, a scrambled copy of your IP address, your browser and operating system, your country, region and city as reported by the network in front of our site, the page and the page you came from, your language, time zone, screen and window size, colour scheme, connection type, whether cookies are enabled, whether you sent a "do not track" signal, and any campaign tags in the link you followed. Both the full IP address and the scrambled copy are stored in each page-view record.

Why: to understand which pages and campaigns work.

Basis: consent.

3.19 Newsletter

What: your email address, where you signed up from, and your language.

Why: to send you the newsletter.

Basis: consent. To stop receiving the newsletter and have your address removed, email hello@roamlu.com.

3.20 App analytics, crash reporting and performance

Analytics and crash reporting: these are off by default. Only if you have consented to analytics does the app send Google's Firebase service the screens you view, certain events (buying an eSIM, placing a call, sending a text, app errors) and your Roamlu user ID, plus crash reports containing technical error details.

Performance monitoring: separately, and whatever your analytics choice, the app sends Firebase performance data: the addresses of the requests the app makes to our servers and how long they took.

Basis: consent for analytics and crash reporting. Legitimate interests in keeping the app fast and working reliably, for performance monitoring.

3.21 Advertising in the app

What happens: if you are not a paying VPN Pro subscriber, the app shows a full-screen advertisement when you start a VPN connection. The advertising software is Google AdMob. AdMob receives your device's advertising identifier, your IP address, device and app information, and how you interact with the ad. The app does not show a separate advertising consent screen.

Your choices: you can reset or limit your advertising identifier in your device's settings. A VPN Pro subscription removes these ads.

Why: ads pay for the free VPN.

Basis: legitimate interests in funding the free VPN service.

3.22 Referral anti-fraud

What: when a referral is recorded we store who referred whom, the code, the reward, the IP address at sign-up and a device fingerprint supplied by the app, plus any reason a referral was flagged.

Why: to pay referral rewards and to detect people referring themselves.

Basis: legitimate interests in preventing fraud against our own promotions.

3.23 Administrative records

What: every change an administrator makes to an account is logged with who did it, what changed, the values before and after, their IP address and the stated reason.

Why: accountability.

Basis: legal obligation and legitimate interests in accountability and security.

These records are append-only. They are never edited or deleted.

4. What we do not collect

We say this explicitly because customers reasonably assume otherwise:

• No location. There is no location permission in the app on Android or iOS. Your home market comes from your device's language setting or from a choice you make, never from GPS. The nearest things we hold are the country code your device reports when we measure data use, and the country, region and city the network reports for a website visit.
• No identity documents, no biometrics. No passport, ID, selfie, liveness check or face match. Face ID or fingerprint used to unlock the app is checked entirely on your device; nothing about it reaches us.
• No call recordings or transcripts.
• No card numbers.
• No VPN traffic contents, and no VPN private keys.
• No camera use by us. The iOS camera permission exists only for scanning a payment card inside Stripe's own checkout.
• No SMS or call-log permissions, and no permission to place calls over your mobile network. Calls and texts run through the app's own internet-based system. The app does use your phone's built-in call screen to show and answer Roamlu calls, and it asks for the microphone so you can talk.
• Your VPN split-tunnelling app list stays on your device. The list of apps you choose to exclude from the tunnel is stored in your phone's secure storage and is never sent to us.

5. Who we share data with, and what role they play

We do not sell personal data. The following companies receive personal data because they perform part of the service.

An important distinction runs through this list. Some of these companies act only on our instructions. Others are independently responsible for what they do with the data. The most important example is the telecoms company that actually carries your calls and texts. A carrier generates and keeps its own call records and complies with its own regulatory duties, whatever we ask of it. The same is true of an advertising network deciding which ad to show you.

• Stripe (payments) — What they get: Your email address and an internal user reference; the amount, currency and status of the payment; product names for subscriptions. Card details go from your device straight to Stripe and never reach us.; Their role: Acts on our instructions for the payment itself, and independently for its own fraud, anti-money-laundering and regulatory obligations.
• Telnyx (phone numbers, calls, texts, verification) — What they get: The number ordered; a per-user connection and credential named with an internal Roamlu user reference; all call signalling, including the numbers on both ends and the timing; outgoing text sender, recipient and content; incoming texts delivered to us; verification codes sent to your number; and lookups of your own phone number to check the line type and carrier.; Their role: Acts on our instructions for the calls and messages we ask it to carry, and independently as a licensed carrier, keeping its own call records and meeting its own legal duties.
• WhatsApp / Meta Platforms — What they get: Your phone number and the one-time code, when a sign-up, sign-in or password-reset code is sent to you by WhatsApp. Codes may otherwise be sent by SMS.; Their role: Delivery partner of Telnyx. Meta is also independently responsible for its own WhatsApp Business data.
• eSIM Access (eSIM supply) — What they get: No Roamlu personal identifiers. Our order sends only an internal transaction key and a package code. eSIM Access does hold the SIM identifier and the network usage that SIM generates.; Their role: Independently responsible for the connectivity data its own network produces.
• Google Firebase (push messaging, analytics, crash reporting, performance, remote config) — What they get: Your device's push token; the title and body of push notifications, which for an incoming text contains the message text and the sender's number, and for a missed call contains the caller's number; analytics events tagged with your Roamlu user ID, if you consented to analytics; crash reports, if you consented; the addresses and timing of the app's network requests.; Their role: Acts on our instructions under Google's data-processing terms for most of these services.
• Google AdMob (advertising) — What they get: Your device's advertising identifier, IP address, device and app signals, and your interactions with the ad.; Their role: Independently responsible, together with us, for showing and measuring ads.
• Meta: Facebook Login — What they get: The sign-in exchange and the anonymous account identifier we store. On Android, automatic event logging and advertising-identifier collection by the Facebook software are switched off. On iOS, the Facebook software's advertising-identifier collection setting is switched on.; Their role: Independently responsible for the sign-in service and any identifier collection it performs.
• Google Sign-In and Sign in with Apple — What they get: A standard sign-in exchange. We store only the provider name and an anonymous identifier.; Their role: Independently responsible for their identity services.
• Anthropic (AI advisor) and Mistral (AI advisor, used if Anthropic is unavailable) — What they get: Your AI advisor messages and up to 20 previous messages of that conversation. No name, email or account identifier is attached.; Their role: Process your messages to produce the answer, under their own service terms.
• OneConnect, reselling Private Internet Access (VPN) — What they get: No Roamlu account identifier. Our server holds the supplier key and passes shared credentials to your device. Your device then connects directly to their gateway, which sees your real IP address and your traffic metadata.; Their role: Independently responsible for what its gateways observe.
• Our email delivery provider — What they get: Your email address and the full content of the message: verification codes, password-reset links, and eSIM delivery emails with the QR code.; Their role: Acts on our instructions.
• Our website delivery network — What they get: Every request to roamlu.com, including your IP address, and the country and city it works out from it.; Their role: Acts on our instructions.
• Our hosting provider — What they get: Everything described in this policy, stored in our database.; Their role: Acts on our instructions.

5.1 Other disclosures. We may also disclose personal data where we are legally required to, to regulators, courts, law-enforcement authorities, numbering authorities or carrier partners, and where necessary to establish, exercise or defend legal claims. Because we hold call records and message content, we can be compelled to produce them.

5.2 If we add or change a supplier that receives personal data, we will update this section. You can ask at hello@roamlu.com for the name of any supplier described here only by its role.

6. Sending data outside your country

Our systems and our suppliers are not all in one place. Personal data described in this policy is transferred internationally, including to the United States, the European Union and elsewhere, whenever a supplier named in section 5 is involved.

If you want to know more about how a transfer to a particular supplier is protected, email hello@roamlu.com and we will tell you.

7. How long we keep things

7.1 Automatic deletion. Three housekeeping sweeps run on a schedule:

• Supplier webhook records — How long: 30 days
• Duplicate-request keys — How long: 7 days
• Expired price quotes — How long: 24 hours

7.2 Everything else is kept while your account exists. This includes call records, call events, text message content, in-app chat messages, AI advisor conversations, uploaded contacts, sessions, consent records, notifications, per-country data-usage records, and phone-identity check records. Website visitor and page-view records are not subject to an automatic deletion schedule. Administrative audit logs are permanent and are never deleted.

7.3 Ending that. Section 12 explains what happens when you delete your account, and how to ask us to erase the rest of your data.

7.4 Financial and tax records, including payments, ledgers, receipts, orders and subscriptions, are kept for as long as tax and accounting law requires, even after your account is closed.

8. How we protect your data

8.1 We protect your account with a hashed password, optional two-factor authentication, sign-in sessions you can see and end, and rotating refresh tokens that detect reuse. Administrative access is permission-controlled, requires a fresh identity check for sensitive actions, and every administrative change is logged.

8.2 Card details never reach our servers. Card payments are handled by Stripe.

8.3 Traffic between the app or website and our servers is encrypted in transit.

8.4 Not every item we store is separately encrypted inside our database. This includes some service credentials and two-factor secrets.

8.5 No system is perfectly secure. If a breach occurs that affects your personal data, we will notify the relevant regulators within the deadlines the law sets and, where the breach is likely to harm your privacy or the confidentiality of your data, we will notify you by email to the address on your account and in the app.

9. Your rights

9.1 Rights that apply wherever you are. Whatever your country, you can ask us to:

• tell you what personal data we hold about you and why;
• give you a copy of it;
• correct anything inaccurate or incomplete;
• delete your data;
• restrict what we do with it while a dispute is resolved;
• object to processing we base on legitimate interests;
• give you the data you gave us in a machine-readable form, or send it to another provider;
• withdraw a consent you gave, at any time, without affecting what we did before you withdrew it.

9.2 If you are in the UAE. UAE data-protection law gives you rights to be informed, to access and obtain a copy, to have data corrected, to request erasure and restriction, to object, to portability, and to have the processing of your data stopped where it is being used for direct marketing. You can complain to us and to the UAE Data Office.

9.3 If you are in Saudi Arabia. Saudi data-protection law gives you the right to be informed, to access your data, to obtain a copy, to have it corrected, completed or updated, and to request its destruction. You can complain to the Saudi Data and Artificial Intelligence Authority (SDAIA).

9.4 If you are in the EU/EEA or the UK. You have the rights in 9.1 in the form set out in the GDPR and UK GDPR. You can complain to your national supervisory authority, or in the UK to the Information Commissioner's Office.

9.5 How to exercise a right. Email hello@roamlu.com. Tell us which right you want to use and enough about your account for us to find it. We may need to verify your identity before we act, particularly for a deletion or a copy of your data. We do not charge for this. We answer data-protection requests within one month.

9.6 Self-service tools, and their limits.

• Your data export. The app and website offer a data export. It contains your profile, your consent history and your active sessions. It does not include your orders, payments, wallet, loyalty, calls, messages, contacts, AI conversations, VPN history or notifications. For a complete copy of your data, email hello@roamlu.com and we will prepare one for you.
• Account deletion in the app. See section 12 for exactly what it removes, and how to ask for everything else to be erased.

10. Cookies and similar technologies

10.1 On roamlu.com. We do not load any analytics or third-party tracking until you choose. When you first visit, a banner asks. Nothing is measured until you say yes.

• Your choice is stored in a first-party cookie named roamlu_consent, set to "granted" or "denied", which lasts one year.
• If your browser sends a "do not track" signal, we treat that as "denied" and do not show the banner at all.
• You can change your mind at any time using the "Cookie preferences" control, which reopens the banner and lets you withdraw consent.
• No third-party script or cookie loads before you choose.

10.2 Cookies we set regardless, because the site cannot work without them: a signed-in session cookie (encrypted, and not readable by scripts on the page), a language cookie, a currency cookie, and an administrative cookie for staff.

10.3 In the app. The mobile app does not use cookies. Analytics, crash reporting, performance monitoring and advertising in the app are described in sections 3.20 and 3.21.

11. Automated decisions

11.1 We do not make decisions about you by purely automated means that have legal effects or similarly significant effects.

11.2 We do use automated checks:

• Phone line check. When you verify a number, an automated check marks the verification as failed if the line is not identified as a mobile line. This does not block any purchase or service.
• Referral fraud flags. Referrals are automatically flagged using the sign-up IP address and a device identifier. A flagged referral is not paid out automatically; a person reviews it.
• Payment screening. Stripe applies its own automated fraud checks to your payment, on its own responsibility.

11.3 If any of these affects you and you disagree with the outcome, email hello@roamlu.com and a person will look at it.

12. Closing your account: what happens

12.1 When you ask to delete your account in the app, we schedule the deletion for 30 days later and the app confirms this on screen. If you sign in during those 30 days, the deletion is cancelled.

12.2 When the deletion runs, sign-in access to your account is removed, and your email address and phone number are removed from the account.

12.3 Erasing everything else. Deleting your account in the app does not by itself erase your other records. For full erasure of everything else, including your uploaded contacts, your text and chat messages, your call records, your AI conversations and your other records, email hello@roamlu.com and ask for it. We will erase it, except for the records described in 12.4, and confirm when it is done. We answer these requests within one month.

12.4 What we must keep. Some records are not erased on request. Records that the law requires us to keep, such as payment and tax records, are kept for as long as the law requires, even after your account is closed. Administrative audit records (section 3.23) are kept permanently. We will tell you which of these records we keep when we confirm your erasure request.

12.5 Your wallet and services. If you close your account, we refund any remaining wallet balance, unless that balance came from fraud or abuse. Deleting your account does not by itself remove an eSIM already installed on your phone. If you have questions about a plan, a Roamlu number or a subscription before you close your account, email hello@roamlu.com.

13. Children

13.1 Roamlu is not for children. You must be at least 16 to create an account or buy anything from us. If the law where you live sets a higher age for this kind of contract, that higher age applies.

13.2 We do not knowingly collect data from anyone under 16. If you believe a child has given us personal data, email hello@roamlu.com and we will delete it.

13.3 We do not verify age.

14. Changes to this policy

14.1 When we change this policy we update the date at the top.

14.2 For material changes we will tell you at least 30 days before they take effect, by email and in the app.

14.3 Our system records which version of the policy you accepted. When we publish a new version we may ask you to review and accept it the next time you use the app.

15. Complaints

15.1 Complain to us first. Email hello@roamlu.com. We reply to complaints within 5 working days, and we answer data-protection requests within one month.

15.2 Complain to a regulator. You always have the right to go to a regulator instead of, or as well as, coming to us.

• United Arab Emirates: the UAE Data Office.
• Saudi Arabia: the Saudi Data and Artificial Intelligence Authority (SDAIA).
• European Union / EEA: the data protection supervisory authority in the country where you live or work, or where the problem happened.
• United Kingdom: the Information Commissioner's Office (ICO), ico.org.uk.

15.3 For complaints about a purchase rather than about your data, see our Terms and Conditions and the complaint routes described there.