Privacy Policy

Introduction and Summary

We are committed to protecting your privacy and ensuring the security of your data. This Privacy Policy applies to all end users, including employees, prospective employees, customers, and website visitors. By accessing our website and utilizing our services, you consent to the terms outlined here.

Scope

This Privacy Policy applies to all users of Roma's website, products, and services. It encompasses the data collected during your interactions with us, both online and offline. This Policy does not apply to anonymized, de-identified, or aggregate information if it is not Personal Information.

Legal Basis for Processing

We process your personal information based on the following legal bases:
  • Consent: For specific purposes communicated to you, which you can withdraw at any time.
  • Legitimate Interest: For activities such as providing support and sending marketing information, after balancing our interests against your rights.
  • Performance of a Contract: To fulfill our obligations under agreements with you
  • Legal Obligations: To comply with laws and regulations.
1. Information Collection
We may collect information including but not limited to the following about you and your use of the Platform in order to create a better, more personalized experience for you or for internal research purposes: Your name, email address, address, date of birth, telephone number, a password selected by you, and data that may be selected or entered by you through the Platform. Furthermore, we may collect your transaction and financial information which will be stored by our third party transaction processors, and service providers who provide KYC/KYB, AML/CFT and other regulatory compliance services to us.

We may track certain information about users of the Platform including but not limited to internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, click patterns, etc.), your mobile device’s unique ID number, your mobile device’s geographic location while the app is running, your computer’s IP address, technical information about your computer or mobile device (such as type of device, web browser or operating system), your preferences and settings (time zone, language, privacy preferences, product preferences, etc.), the URL of the last web page you visited before coming to one of our sites, the buttons, controls and ads you clicked on (if any), how long you used the Platform.

Certain features and functionalities of the Platform may be based on your location. In order to provide these features and functionalities while you are using a mobile device, we may, with your consent, automatically collect geolocation information from your mobile device, wireless carrier, or certain third-party service providers. Such information is collectively called the Geolocational Information. Collection of such Geolocational Information occurs only when the Platform is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.
2. Individuals under the Age of 18
The Platform is not intended for individuals under 18 years of age. No one under age 18 may provide any personal information to the Website. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on the Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from an individual under 18 without verification of parental or legal custodian consent, we will delete that information. If you believe we might have any information from or about an individual under 18, please contact us and we will endeavor to delete that information from our databases.
3. Use of Information
You agree that we may use your information in the following ways:
  • To provide our Services to you,
  • To enable us to create a better, more personalized experience for you based on your individual usage habits, analyze site usage and disclose aggregated statistics, improve our content and service offerings, aid in our monetization efforts, and customize our Platform’s content, layout and services. This may include migrating your information to other platforms owned by us.
  • To review and investigate your activities or transactions on our Platform, resolve disputes, troubleshoot problems, and enforce our Terms of Service Agreement.
  • To use your correspondence with us, information posted by you for publication on our Platform for promotional, sales or any use that we consider appropriate, whether submitted via email, or posted on our Platform.
  • To share your information with third party partners or third parties hired by us to perform functions and provide services to us subject to confidentiality obligations consistent with this Privacy Policy and on the condition that the third parties use your information only on our behalf and pursuant to our instructions.
  • To disclose any information in response to a legal request such as a subpoena, court order, or government demand, to investigate or report illegal activity, or to enforce our rights or defend claims. We may also transfer your information to another company in connection with a partnership or a corporate restructuring, such as a sale or merger.
4. Storage and Retention
By using the Platform, you agree that your personal information may be transferred to the United States of America or elsewhere and you agree to the information collection, use, and sharing practices described in this Privacy Policy. We keep your personal data for as long as needed to allow you to use our Services and to comply with our legal requirements. We retain copies of documents and information for 5 years after our business relationship with you ends, which can be extended to 10 years if requested by our regulator.
5. Security
We have established both physical and electronic procedures to safeguard and secure the information we collect. However, the internet is an open system, and we can make no guarantees as to the security or privacy of your information submitted to the Platform. For this reason, we recommend that you use anti-virus software, routine credit checks, firewalls and other precautions to protect yourself from security and privacy threats.
6. Sensitive Personal Data
We may process special categories of personal data (e.g., racial or ethnic origin, political beliefs, health data) in line with data privacy laws or with your explicit permission. This information is handled with extra protection and care due to its sensitivity.
7. Third Party Websites
The Platform may contain links to other websites that we believe may be of interest or use to you. We provide these links solely as a convenience to you. Links may also be posted by other users of the Platform. When accessing a third party website through our Platform, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us. Please note that our Privacy Policy and information collection, use and sharing procedures do not apply to other websites. We take no responsibility for and incur no liability for other websites’ collection, use or sharing of information. Please review the privacy policies provided by each website linked to the Platform to familiarize yourself with the procedures of such websites. Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, do not create rights enforceable by third parties.
8. Law Enforcement
You agree that we may disclose your information to authorities if compelled to by a court order or by an investigating agency/regulatory body in lawful exercise of the powers conferred on such investigating agency/regulatory body. Additionally, you agree that we may disclose your information if we reasonably believe that you have violated the laws of the United States of America, or international laws or the terms of our Terms of Service or Privacy Policy. We are under no obligation to inform you of any disclosures or potential disclosures of your information as mentioned in this paragraph. You release us from any claims for damages that may arise from or relate to the release of your information in compliance with a court order or a request made by an investigating agency/regulatory body. We may release your information under the conditions listed in this paragraph whether it is to individuals or entities and to any state or national authorities, as required.
9. Commercial and Non-Commercial Communications
If you decide to provide us with your contact information, you agree that we may send you communications and emails. However, you may unsubscribe from certain communications by notifying us that you no longer wish to receive such communications. Once notified, we will endeavour to remove you from our database immediately.
10. Third Party Access to Your Information
Throughout the course of our provision of our services to you through our Platform, we may delegate our authority to collect, access, use, and disseminate your information. It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services for the purpose of providing service to you or for operating, maintaining, repairing, or otherwise improving or preserving our Platform or its underlying files or systems. As we do not control these third parties, you agree that we shall not be liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.
11. Cookies and Tracking
We may use cookies and other tracking mechanisms through the Platform to identify you and remember your preferences. By accessing the Platform and accepting this Privacy Policy, you provide your explicit consent to allow us to use cookies and other tracking mechanisms through the Platform to identify you and remember your preferences. You can set your cookie preferences, such as accepting or rejecting certain types of cookies, and you can change these preferences periodically.
12. International Data Transfers
We may transfer, store, or process your personal data in a country outside your local jurisdiction, including countries outside the European Economic Area (EEA). We ensure these transfers comply with applicable data protection rules. We will always take all reasonable steps to ensure that your data is treated securely and in line with this Privacy Policy.
13. Data Retention
We store your Personal Information for different time periods depending on the category of Personal Information and the nature of the relationship you have with us. We aim to keep your Personal Information for as short a time as possible to achieve the purpose for which it was collected. For more information on retention periods, please contact us.
14. Data Subject Rights
Depending on your location, you may have certain legal rights over the personal data we hold about you, subject to local privacy laws:
  • Right to be Informed: Clear and concise information about what is done with your personal data and why.
  • Right to Access: Access to the personal data we hold about you.
  • Right to Data Portability: Receive the personal data provided to a controller in a structured, commonly used, and machine-readable format.
  • Right of Correction: Update or delete incorrect personal data. You can also update certain account profile information by logging into your account.
  • Right of Erasure: Have your personal data deleted. You can ask us to delete the personal information that we have collected or maintain about you, subject to exceptions. Please note that we are required to retain certain personal information to comply with our legal obligations, including compliance with recordkeeping requirements contained in anti-money laundering, anti-terrorism, or other financial laws and regulations.
  • Right to Restrict Processing Object to the processing of your personal data carried out based on our legitimate interests or for direct marketing purposes.
  • Right to Object: Mechanism to opt-out of marketing communications at any time.
  • Right Not to be Subject to Automated Decision Making:: Not to be subject to a decision based solely on automated processing, including profiling.
15. Handling Customer Data Subject Requests
For DSRs received by us, we handle customer data subject requests in line with applicable data protection laws. Customers are responsible for raising DSRs and providing necessary information. We act as a data processor and process requests according to customer instructions.
16. Security
For DSRs received by us, we handle customer data subject requests in line with applicable data protection laws. Customers are responsible for raising DSRs and providing necessary information. We act as a data processor and process requests according to customer instructions.
17. Changes to Privacy Statement
This Privacy Policy may be amended or revised from time to time at our discretion. Changes will be posted on the Website and indicated by a change in the "Effective Date." We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.
18. Contact Mechanism
For DSR-related queries, please send an email to [email protected]. For other grievances and queries on our privacy policy or the use of our services, contact us at [email protected]