Data Protection

1. Controller

The controller regarding this website within the meaning of Art. 4(7) GDPR and other national data protection laws of the Member States and other provisions under the GDPR is:

ROAMSYS S.A.
13, Fausermillen
6689 Mertert
Luxembourg

E-Mail: info@roamsys.com

2. Name and Address of the Data Protection Officer

With regard to article 37 GDPR, we have designated a Data Protection Officer. You can communicate with our Data Protection Officer using the following contact details:

DURY Compliance & Consulting GmbH
Obertorstraße 1
66111 Saarbrücken
Germany

E-Mail: dsb@datenschutz-compliance.de

3. Processing of Personal Data

Creation of Log Files

Each time you access our website, our system automatically collects data and information from your accessing device. The processing of personal data carried out in this context includes:

• Information concerning the browser type and version used
• The operating system of the accessing device
• The IP address of the accessing device
• Date and time of access
• Webpages and resources (images, files, additional page content) accessed
• Websites that refer to our website and directed the user’s device to our website (referrer tracking)

This data is stored in the log files of our system. This data is not stored together with personal data of a specific user in such a way that individual users can be identified.

Legal Basis for the Processing of Personal Data

Article 6(1)(f) GDPR (legitimate interest). Our legitimate interest lies in the following outlined purpose.

Purpose of Data Processing

Logging is carried out to maintain compatibility, combat misuse, and for troubleshooting. It is necessary to log the technical data of the accessing devices. We also use this technical data to optimize the website and to ensure the security of our IT systems.

Duration of Storage

The aforementioned technical data is erased as soon as it is no longer required to achieve the aforementioned purposes, but no later than three (3) months following the use of our website.

Possibility to Object and Demand Deletion

You may object to this processing according to article 21 GDPR and demand deletion of data according to article 17 GDPR by following the indications under section 8 of this Privacy Policy.

4. Use of Google Maps

We use Google Maps on our website to provide you with an interactive map experience. When you load pages that contain Google Maps, Google receives information about your IP address and may set cookies. This is necessary for the functionality of the map service. For further information on how Google processes your data, please consult their privacy policy: https://policies.google.com/privacy.

5. Integration of External Web Services and Processing of Data Outside the EU

On our website, we use active JavaScript content from external providers, known as web services. By accessing our website, these external providers may receive personal information about your visit to our website. In this case, it may be possible that they process data outside the EU. You can prevent this by installing a JavaScript blocker such as the browser plug-in ‘NoScript’ (www.noscript.net or www.ghostery.com) or by deactivating JavaScript in your browser. This may result in functional restrictions on the Internet pages that you visit.

We use the following external web services:

5.1 Google Services

We use Google Maps provided by Google Ireland Limited (a subsidiary of Alphabet Inc.) our Contact page. When accessing this page, your browser may transmit data, including personal data, to Google Ireland. The legal basis for processing this data is article 6(1)(f) GDPR, with the legitimate interest being the error-free functioning of the website. The data is erased as soon as the purpose for its collection has been fulfilled. You can find additional information on the handling of the transferred data in the data privacy statement of Google: https://policies.google.com/privacy.

5.2 WordPress

The website is built on a self-hosted instance of WordPress, created by Automattic Inc. This allows us to ensure full control over our site’s performance. Your browser may transmit data to our servers, and the legal basis for processing this data is article 6(1)(f) GDPR, with the legitimate interest being the error-free functioning of the website. You can find additional information in the privacy policy statement of WordPress: https://wordpress.org/about/privacy/

5.3 elfsight

We use a widget from elfsight on the homepage, displaying the latest posts from our LinkedIn company page. The following information is transmitted to elfsight: IP address, operating system, and browser type. This information is stored for a period of seven days and is evaluated anonymously to facilitate the prompt detection and resolution of service malfunctions. Additionally, it is analysed to ensure system security, including the detection of unauthorised access attempts, as well as fraud and abuse attempts. You can find additional information in the privacy policy statement of elfsight: https://elfsight.com/privacy-policy/

6. Use of Cookies

Scope of the Processing of Personal Data

On various pages, we and the web services integrate and use cookies to enable certain functions of our website. Cookies are small text files that your browser can store on your accessing device. These text files contain a characteristic string of characters that uniquely identify the browser when you return to our site.

Legal Basis for the Processing of Personal Data

Article 6(1)(f) GDPR (legitimate interest). Our legitimate interest lies in maintaining the full functionality of our website, increasing its usability, and enabling a more individual approach to our customers. We can identify individual website visitors with the help of cookie technology if the website visitor has previously provided us with corresponding personal data based on separate consent.

Purpose of Data Processing

Cookies are set by our website in order to maintain its full functionality and improve usability. Cookie technology also enables us to recognise individual visitors by means of pseudonyms, such as an individual random ID, so that we can offer more individual services.

Duration of Storage

Our cookies are stored in your browser until they are deleted or, in the case of a session cookie, until the session has expired.

Possibility to Object, Withdraw Consent, and Demand Deletion

You can adjust your browser settings to prevent cookies from being set in general. You can then decide on a case-by-case basis whether to accept cookies or accept them altogether. Cookies can be used for various purposes, such as recognising that your accessing device has already been connected to our website (permanent cookies) or saving recently viewed offers (session cookies). If you have given us express permission to process your personal data (article 6(1)(a) GDPR or article 9(2)(a) GDPR), you can withdraw that consent at any time. Please note that the lawfulness of the processing carried out based on the consent before the revocation is not affected by this.

7. Data Security and Data Protection, Communication by Email

Your personal data is protected by technical and organisational measures during collection, storage, and processing so that it is not accessible to third parties. In cases of unencrypted communication by email, we cannot guarantee complete data security on the transmission path to our IT systems, and therefore we recommend using encrypted communication or mail for any information that requires a high level of confidentiality.

8. Right to Access and Correct Data – Deletion of Data – Limitation of Processing – Withdrawal of Consents – Right to Object

8.1 Right of Access

You have the right to request confirmation as to whether we process your personal data. If this is the case, you have the right of access and information specified in article 15(1) GDPR, provided that the rights and freedoms of other persons are not infringed (article 15(1) GDPR). We will also be pleased to provide you with a copy of the data.

8.2 Right to Correction

Pursuant to article 16 GDPR, you have the right to have incorrectly stored personal data (such as address, name, etc.) corrected by us at any time.

8.3 Right to Erasure

Pursuant to article 17(1) GDPR, you have the right to demand that we delete the personal data collected about you in the following cases:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• The processing is based on point (a) of article 6(1), or point (a) of article 9(2) GDPR, and there is no other legal ground for the processing.
• You have objected to the processing pursuant to article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to article 21(2) GDPR.
• The personal data have been unlawfully processed.
• The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information society services referred to in article 8(1) GDPR.

Pursuant to article 17(3) GDPR, the right does not exist insofar as the processing is necessary for the exercise of the right to freedom of expression and information. Moreover, it does not exist if it has been collected based on a legal obligation or if the data serve the assertion, exercise, or defence of legal claims.

8.4 Right to Limitation of Processing

According to article 18(1) GDPR, you have the right in individual cases to demand the restriction of the processing of your personal data.

This is the case if:

• The accuracy of the personal data is disputed.
• The processing is unlawful.
• The data are no longer required for the processing purpose but are used for the assertion, exercise, or defence of legal claims.
• An objection has been filed against the processing pursuant to article 21(1) GDPR and it is still unclear which interests predominate.

8.5 Right to Withdraw Consent

If you have given us express permission to process your personal data (article 6(1)(a) GDPR or article 9(2)(a) GDPR), you can withdraw it at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this.

8.6 Right to Object to Data Processing

Pursuant to article 21 GDPR, you may at any time object to the processing of your personal data if such processing is carried out on the basis of article 6(1)(f) GDPR, e.g. where the processing is carried out based on legitimate interests.

8.7 How Can I Obtain My Rights?

You can obtain your rights if you inform us:

ROAMSYS S.A.
13, Fausermillen
6689 Mertert Luxembourg

E-Mail: info@roamsys.com

9. Data Portability

You have the right to receive the personal data that you have transmitted to us in a structured, commonly used, and machine-readable format and transfer it to another data controller, provided that:

• The processing is based on consent pursuant to article 6(1)(a) GDPR or a contract pursuant to article 6(1)(b) GDPR; and
• The processing is carried out by automated means.

You can also request your personal data be directly transferred to another controller, provided that this is technically feasible. The exercise of this right shall not adversely affect the rights and freedoms of others.

10. Right to Lodge a Complaint to the National Data Protection Authority – Commission Nationale pour la Protection des Données (CNPD) – or Any Other Competent Supervisory Authority

If you suspect that your data is being illegally processed on our site, you can take legal action to bring the problem to judicial clarification. This option does not interfere with any other legal options you may have.

Regardless, you have the option of contacting the CNPD or any other competent supervisory authority. You have the right to lodge a complaint with the competent supervisory authority in the EU Member State of your place of residence, workplace, and/or place of alleged infringement, i.e. you can choose the supervisory authority to which you will be lodging a complaint in these locations. The supervisory authority to which the complaint was submitted will then inform you of the status and results of your complaint, including the possibility of a judicial remedy under article 78 GDPR.