Effective as of: July 1, 2021
We are Roam. We provide real-world augmented reality platforms, designed to enable you to interact in shared worlds, seamlessly blended with the real world. To do that, we need information about you. Protecting your privacy is really important to us. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you play any of our games, use our websites, buy merchandise from us, or take part in live events and promotions (the "Services").
Please note that in addition to the general information below, specific information about how certain of our Services use your information is provided at the end of this Privacy Policy in the “Game Specific Disclosures”.
You should also read our Terms of Service which set out the contract between you and Roam.
1. Who decides how your information is used?
Roam, Inc. generally is the data controller responsible for making decisions about how we use your personal information.
If you have any questions or comments on this policy, you can email us at support@roamtheapp.com.
2. The information we collect about you and how we use it
This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").
We need to collect and use certain Personal Data to provide the Services to you and fulfill the promises we make to you in the Terms of Service:
Depending on the particular Service you sign up for, we may support other external single sign-on services and collect additional Personal Data from them. For details please read the Game Specific Disclosures at the end of this Privacy Policy.
Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.
In addition, we have and rely on a legitimate interest in using your Personal Data as follows:
We will only use your Personal Data to do the following if we have your consent:
We also rely on your consent where we use cookies or similar technologies. Please see our Cookie Policy for more information about how we use them. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.
While you may disable the usage of cookies through your browser settings, Roam currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.
3. Who we share information with
We will not share any Personal Data that we have collected from or regarding you except as described below:
Information Shared with Our Service Providers: We engage external service providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These external service providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The service providers we use help us to:
Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third Party Service in accordance with their own privacy policy. Such external service provider does not share your financial information, like credit card number, with Roam, but it may share limited information with us related to your purchase, like your zip or postal code.
Information Shared with Other Players: When you use the Services, and in particular when you play our games, use social features within those games, or take part in live events, we will share certain Personal Data with other players. This Personal Data includes your in-game profile (such as your username), your in-game actions and achievements, real-world locations associated with your gameplay, or with gameplay resources you interacted with when playing the game, and your in-game messages and related content you share with other players. Additionally, certain games link to third-party sharing features on your device that you can use to disclose Personal Data to others outside the Services; Roam does not control and is not responsible for the practices of these third-party sharing features.
Information Shared Publicly: When you use the Services, and in particular when you play our games, use competitive features, or participate in our forums, the following information about you may be shared on web pages accessible to the public and therefore become publicly available: your username, in-game profile, achievements and public messages.
Information Shared with Third Parties: We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.
Information Disclosed for Our Protection and the Protection of Others: We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.
Information Disclosed in Connection with Business Transactions: Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.
4. How your Personal Data is transferred
Roam operates its Services across the globe. Your Personal Data will likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy to the extent permitted by applicable laws. The data protection laws in these countries may not be the same as in your home country.
5. How we keep your Personal Data safe
We have appropriate legal, organizational and technical security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. How long we will keep your Personal Data
We keep your Personal Data for as long as we need to provide the Services to you and fulfil the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.
When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.
7. Your rights and choices
You have certain rights in relation to your Personal Data. In order to exercise these rights, please contact us at services@booti.io.
You can:
The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.
We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.
After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days, or such shorter time period as provided by laws of your jurisdiction
8. Children
Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not collect Personal Data from them. We define “children” as follows:
If you have questions about our privacy practices for Children, please contact us at services@booti.io.
9. Changes to this Privacy Policy
Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.
10. Third Parties
In using our Services you may access links to websites and services that are owned or operated by third parties (each, a “Third Party Service”). Any information that you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third Party Service that you access.
11. Disclosures Specific to California Residents
California law requires that we make certain disclosures about your data. We do not sell your Personal Data. The information listed in Section 2 falls under the following California Consumer Privacy Act (CCPA) categories: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information.
12. Game Specific Disclosures
Additional Privacy Information for Roam.
Information shared with other players. When you take certain actions in Roam and capture a prize, your username will be shared publicly through the game, including with other players.
Additional Privacy Information for Ingress
Information shared publicly. When you play Ingress, as part of the gameplay the following information about you will be shared through the game (including with other players directly within the app, in game notifications emailed to other players as part of the gameplay, and online on the Ingress Intel Map website), and will therefore become publicly available: your in-game username, messages sent to other users in COMMS, and in-game portals that you interact with, as well as your device location whenever you take an in-game action.