Privacy Policy

1. Introduction

This privacy policy (“Notice“) is intended to inform you about how your Personal Data will be handled by RoamFree Telecom Co., Limited (“RoamFree” “we” “us” or “our”) and sets out the information including personal information detailed below relating to you or which you provide to us (“Personal Data“) that will be collected and processed by RoamFree and/or on its behalf by its third party service providers when you contact us through our Website, once you have contracted for our services.

2. RoamFree as data controller

For the purposes of this Notice, the controller of your personal data is RoamFree Telecom Co., Limited of RM C20, BLK C, 3/F, EAST SUN IND CENTRE, 16 SHING YIP STREET, KWUN TONG, HONG KONG. RoamFree is responsible for your Personal Data.

RoamFree is committed to respecting your fundamental right to the protection of your Personal Data and this Notice is intended to inform you about the processing of your Personal Data by us.

3. Types of Personal Data we process about you

Category of Personal Data	Details
Website Usage and Device Data: When you visit our website.	Your visits and interactions with our website including which webpages you visit, time and date of access, what you click on, when you perform these actions; Your device data including your IP address, location data, device type and language, browser type and other related information; and Any linked websites that you access through the website. Most of this Personal Data is collected using cookies on the Website.
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; email address; device type (e.g. make and model); a copy of your passport, driving license 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 with you or when you visit our website, we will collect Personal Data either: (1) directly from you, or (2) indirectly from third parties (for example, once you have contracted for our services, through our affiliates or travel agencies).

When you browse on our website, different cookies and other tracking devices may be installed on your device. Where we collect your Personal Data by using cookies on our website, which are not necessary for the Website to operate, we require your consent to do so.

5. For what purpose and on what legal basis do we process personal data?

We have set out in the below table the key context upon which (“Legal Basis“) we process your Personal Data. We also explain how (“Nature of Processing“) and why (“Purposes“) we obtain and collect your Personal Data.

Legal Basis	Nature of Processing and Purposes	Categories of Personal Data
Compliance with a Legal Obligation	RoamFree may process your Personal Data where it is necessary to comply with legal obligations to which we are subject under Hong Kong and/or applicable laws, including but not limited to safeguarding and complying with law enforcement requests.	Customer Data Website Data
Performance of a Contract	• To provide you with access to the website and to allow you to use the website. • To manage the purchase of the eSIM or data plan that we sell on our website and the payment relating to such products. • To calculate and issue charges for services provided to you. • To review and attend to customer incidents, queries, complaints or requests relating to our products and services. • To manage and perform any after-sales services. • To manage your registration as a user of our website, as well as to allow your access to the RoamFree’s private user area	Customer Data Website Data
Legitimate Interest	• To facilitate the use of your eSIM or data plan, including the administration of your account, and to provide customer care to you. • To better understand how our customers use our website in order to improve it. To tailor products and services to you and, if you consent to direct marketing, to tailor direct marketing. • To monitor against and prevent cyber-security issues and unauthorized use of our information, IT systems and/or equipment. • To streamline our business processes by using external platforms; • To conduct internal business reviews and, if necessary, contact the customer in the event that fraud or identity theft is detected or there are reasonable suspicions of fraud, identity theft or illegal activity. • To record calls for training purposes and to improve our customer service. • To conduct periodic reviews of our services and carry out satisfaction surveys to evaluate and improve the quality of the service we provide. • To carry out any other activities necessary to the running of our business, including system testing, network monitoring, staff training, and quality control.	Customer Data Website Data

6. With whom do we share Personal Data?

Depending on the Purpose for which we process your Personal Data, we may share such Personal Data with some or all of the following recipients to the extent necessary:

RoamFree internal/ intra-group entities: Internal departments and services (such as our sales department, marketing department or IT department).
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 courts, Police Station 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. Your data protection rights

Right	Further Information
Right of Access	You have the right to request a copy of the Personal Data held by RoamFree about you and to access the Personal Data which we hold about you.
Right to Object	You have a right to object at any time to the processing of your Personal Data where RoamFree processes your Personal Data on the legal basis of pursuing its legitimate interests.
Right to Rectification	You have the right to have any inaccurate Personal Data which RoamFree holds about you updated or corrected.
Right to Erasure	In certain circumstances, you may also have your Personal Data deleted. For example, if you exercise your right to object and RoamFree does not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes as set out in this Notice.
Right to Restriction of Processing	You have the right to ask RoamFree to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data that we hold about you is inaccurate or if our use of your Personal Data is unlawful.

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

If you have any questions about the information detailed in this Notice or would like to exercise your data protection rights, please contact our customer service team at service@roamfreetelecom.com.

9. Updates to this Notice and other information

We will make best efforts to keep this Notice up to date. This Notice will be regularly reviewed and may be amended and updated from time to time as necessary. Any updates to this Notice will be posted to this section of the website.

This Notice is drafted in the English language. In the event that there is a conflict between this English language version of the Notice and any translated copies of the Notice, the English version shall prevail.