This Privacy Policy (“Policy”) sets out how Instaroam collects, uses, discloses, transfers and stores your personal data, and your rights and choices with respect to your personal data. It should be read in combination with our Terms of Service.
When we say “we”, “our” or “us” we mean Instaroam.
Personal data is any information that relates to an identifiable individual. We set out the information we collect in the table below, and describe how we use it.
We collect personal data in different ways, depending on how you use our Services and Platforms.
When you use our Services or Platform, or you otherwise interact with us, we collect, use, store and share the personal data listed below:
Personal Data to set up your Account: first name, last name, email addresses, postal address/location (country, province/state, city), telephone numbers.
Third Party Log In Info. If you choose to create an Account via a third-party platform (for example, Telegram), we may automatically receive log in information from that third party. The information we receive will vary depending on the information that you have provided to the third party and your preferences within the third-party platform (for example, you may have enabled Apple's 'Hide My Email' functionality). Please refer to the relevant third party's privacy notice for further information.
Personal data necessary for customer satisfaction. To the extent permitted by law or with your consent, Instaroam may combine the information it collects directly or indirectly to ensure the completeness and accuracy of such data, to enable Instaroam to better tailor its interactions with you, and to determine what information best meets your interests or needs.
Data generated by your use of Instaroam:
We may use your personal data for the following purposes, or a combination of these purposes:
Where we are performing a contract with you or a third party, such as your employer. This includes providing our services to you.
Where it is necessary to conduct our business or pursue our legitimate interests. For example:
Where we have obtained your consent. In circumstances where you have expressly given your consent for us to process your personal data, you are free to revoke that consent at any time, by either using the functionality provided to provide and revoke consent, or by contacting us at legal@instaroam.shop. However, please be aware that may have the right to continue to process your personal data if it can be justified on one of the following basis:
Instaroam employees. Some Instaroam employees will have access to your data to help facilitate everything within the ‘Why and how we use your data’ section of this privacy policy.
Companies and employees of the Instaroam Group. Instaroam is a global company, and our workforce is spread all over the globe. Access is limited to those who have a genuine work-related need.
External service providers. Instaroam relies on third parties to provide certain elements of our Services or support the technical operation of our Platform, including our providers of network connectivity, providers of hosting services, the processing of payments, etc. We will only rely on service providers that provide appropriate contractual safeguards for the transfer and processing of the information they process.
Independent third party services, websites and businesses. This could be in connection with a promotion, marketing event, or webinar. Instaroam also uses a third party review platform, Trustpilot, who may contact you to collect feedback about your experiences with Instaroam.
Distribution Partners. Instaroam uses distribution partners to sell its Services, and we may need to share information with them, particularly if you have purchased services from them rather than from Instaroam directly.
Other disclosures. Including:
We keep your personal data only for as long as we need it, or are required legally to retain it. This depends on why it was collected, and if we have a continuing legal basis to do so (such as for our legitimate interests, or to perform our contract with you). When we no longer have a reason to keep your data, we will either delete it or anonymise it so it doesn’t identify you. You can delete your personal data or ask us to do that for you at any time. Details of how to do this are in the ‘Know your Rights’ section below. Please note that, in certain circumstances, Instaroam may be required by law to retain and process some or all of your personal data, or have compelling legitimate interests to keep the data, even after a deletion request. For instance, Instaroam is required to retain certain personal data to satisfy our Know Your Customer (eKYC) legal obligations.
We have put in place appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorised way, altered or disclosed. In addition we limit access to your personal data to those employees,contractors and other third parties who have a business need to know. They will only process your data on our instructions, and they are subject to a duty of confidentiality. However, no method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain appropriate safeguards, we cannot guarantee the absolute security of your personal data.
Please note that your data will be stored and processed globally. More specifically, your personal data will be securely stored in data centres around the world, and not necessarily in the country where you are resident. The exact location of the data centers depends on where you are when you use the Platform or Services, and the locations of the third parties with whom we share personal data (see the section ‘Who may have access to your personal data’). The laws and regulations in the countries where the processing happens may not provide the same level of protection of personal data as the regulations in your own country. However, we'll put safeguards in place to protect your data when it is transferred. Please check the section ‘Compliance with local regulations’ below for more information.
If we hold personal data about you, you may have certain rights (depending on your location). These include:
If you wish to exercise any of these rights, our websites and apps will have functionality to allow you to perform most of the actions listed above. If you wish to exercise a right that isn’t available through those functionalities, please contact us using the Contact Information below.
Children. Our Services and Platforms are not directed towards children under the age of 13 and we do not knowingly collect personal data from those under the age of 13. If you become aware that anyone under the age of 13 has provided their personal data to us, please notify us at legal@instaroam.shop.
Contact information.
If you have any questions about how we process your personal data or would like to exercise your rights under this Privacy Policy, please contact legal@instaroam.shop.