eROAMING Ltd

PRIVACY POLICY

Effective Date: 22/02/2026
Document No: eROAMING/PP/2026/02
Version: 2.0
Policy Owner: Risk & Compliance Division
Classification: Private and Confidential

PRIVACY POLICY
At eROAMING Ltd, when you use our services, enter into a contract with us, or visit our website, it may be necessary for us to collect, process, and retain certain information about you. This policy explains why we collect this information, the types of data we may gather, how we manage and process it, and other essential details.

Our commitment to you is that any data we collect will always be gathered with your knowledge, stored securely, and kept only for as long as it is needed.
INTRODUCTION
We are eROAMING Ltd. Throughout this policy, any mention of “we,” “us,” or “our” refers to eROAMING Ltd.

eROAMING Ltd serves as the data controller for any personal information gathered through your use of our services, websites and applications in compliance with UK data protection laws. We ensure that your information is handled strictly in accordance with this policy and relevant data protection and privacy regulations.

We collect personal data through various channels, including the following:

Website: eroaming.global


Mobile Applications: eROAMING eSIM App


Other Channels: Digital Kiosk


Registered office: EROAMING LTD, Rear of 18-20 Village Way East, Harrow. HA2 7LU.


Business Registration number: 15615617


Registered with the ICO under registration number: xxxxxxx

To learn more about your rights concerning your personal information, please refer to the "Your Rights" section of this policy. If you have any queries regarding how we handle your personal data or need assistance in exercising your rights, you can reach out to our Data Protection Officer (DPO) via email at DPO@eroaming.co.uk , or

by post at: Data Protection Officer, eROAMING Ltd, Rear of 18-20 Village Way East, Harrow. HA2 7LU.

DEFINITIONS
'Your personal information' refers to details about you that can identify you. This information is collected and processed by eROAMING ltd when you use our services. Throughout this policy and related sections of our website, terms such as ‘your information,’ ‘your data,’ ‘personal data,’ and ‘personal information’ all have the same meaning as 'your personal information.'

eROAMING Services include a range of offerings provided directly by us or on our behalf. These services cover, but are not limited to, calling, internet access, messaging, data storage, premium features, and age-restricted services.
DATA COLLECTION
To provide our services, manage your account, and fulfil contracts, we must collect, process, and store certain personal information.
You must ensure the information you provide is accurate and up to date, notifying us promptly of any changes. Inaccurate or false information may result in delays or suspension of eROAMING services until investigated.
If you share another person’s information, you must have their consent or legal authority.
The information we collect depends on the services and products you use.

Personal Data Information

Personal Details

  • Name
  • Current and previous addresses
  • Length of time at these addresses
  • Email address
  • Phone number
  • Gender
  • Date of birth

Employment and Lifestyle Information

  • Employment status and history
  • Lifestyle related information

Financial Information

  • Payment card and/or bank details for billing purposes

Communication Records

  • Notes from interactions with Customer Services (via phone, email, or chat)
  • Call recordings or chat transcripts, stored according to retention policies

Device and Usage Information

  • Call details, location data, enabling connectivity and accurate billing
  • Unique codes identifying your phone and SIM card
  • Location Data

Online Interaction Data

  • Information shared through website use, collected via cookies

Managing Non-Essential Cookies

You can opt out of non-essential cookies at any time by adjusting your preferences in the Cookie Preferences section at the bottom of our website. Non-essential cookies include functional, performance, and targeting cookies, which require your consent before being placed on your device.

By selecting ‘Allow essential cookies only’, only essential cookies required for the basic functioning of the website will be placed.

If you choose ‘Accept all cookies’, you consent to all cookie categories, including sharing data with third parties like advertising partners, which may involve data processing outside the EU/EEA.

To block or delete cookies, you can adjust your browser settings. However, this may impact your browsing experience, prevent certain functionalities (like account logins or product purchases), and require manual adjustments for site preferences during each visit.

For more details on browser cookie management, please do contact us:


Email – info@eroaming.co.uk


Account Management Information


  • Account number, billing details, and contact history
  • Preferences for products or services, based on your input or usage patterns

Security Information

  • Passwords or similar data to validate and protect your account, securely stored

Personal Information Collected from Other Sources

  • Credit reference agencies (credit bureaus)
  • Fraud prevention agencies
  • The Electoral Register
  • Commercial partners providing goods or services to us

This information is collected as necessary to provide services, manage your account, and comply with legal requirements.

RETENTION OF PERSONAL DATA
We retain your personal information only as long as necessary to provide services, fulfil legitimate business interests, or meet legal obligations. Communication data is typically held for up to one year, or longer if required for legal proceedings or disputes. Account information may be retained after your relationship with eROAMING ends to comply with legal and regulatory requirements.
PROCESSING YOUR PERSONAL INFORMATION
We may need to collect and process your personal information for various purposes, including,
  • Processing applications or registrations.
  • Providing requested products, services, and information.
  • Monitoring or recording communications for quality and training.
  • Administering accounts and managing complaints or queries.
  • Complying with legal and regulatory requirements.
  • Conducting credit checks, fraud prevention, and recovering debts.
  • Supporting traffic analysis, billing management, and product development.
  • Fulfilling contractual obligations and notifying you of updates or changes.
  • Contacting you for market research or providing marketing updates (based on your preferences).

The lawful basis for processing your information will be:

  • Your consent for specific purposes.
  • Necessity for contract performance.
  • Legitimate interests that do not override your rights.

If you are aged 16 or under, you must have parental or guardian consent to share your personal information.

CREDIT CHECK
If you apply for a Pay Monthly contract, we will share your personal information with credit reference agencies (CRAs) to conduct credit and identity checks. CRAs will provide us with information to assist in making an automated decision about whether we can enter into a contract with you.
DISCLOSING YOUR PERSONAL INFORMATION

To provide our services and meet legal requirements, we may need to share your personal information with others in certain situations, including:

  • To carry out tasks required by our contract with you, such as credit checks and surveys.
  • To support our business operations.
  • To prevent and detect fraud, money laundering, or criminal activities.

Your information may be shared with:

  • Our business partners, suppliers, and contractors.
  • Other companies in our group.
  • Professionals like accountants or lawyers.
  • Law enforcement or government agencies, such as the National Crime Agency.

We may also share your information if required by law, to enforce agreements, or to protect the safety and property of our customers, employees, or others.

TRANSFERRING PERSONAL INFORMATION

Your personal information will primarily be stored on servers in the United Kingdom (UK) or the European Economic Area (EEA). If your data is transferred outside the EEA, including to India, we ensure it receives the same level of protection as required under UK GDPR, through appropriate safeguards. The data is always transferred from the UK and remains subject to the protection set out in the UK GDPR, regardless of the destination country or jurisdiction.

  • Transferring to countries with approved data protection standards, recognised by the Information Commissioner’s Office (ICO) or the European Commission.
  • Using ICO-approved contracts, that require recipients to protect your data to the same standards as in the United Kingdom or Europe.

The following safeguards are implemented to ensure compliance with the UK GDPR:

  • Approved Data Protection Standards: Transfers to countries outside the EEA, including India, will only occur to jurisdictions that have been deemed to provide adequate protection by the UK government or the Information Commissioner’s Office (ICO). If the recipient country does not have an adequacy decision, we ensure that appropriate safeguards are in place.
  • Standard Contractual Clauses (SCCs): For transfers to India and other non-EEA countries, we will use Standard Data Protection Clauses (SCCs). These SCCs are recognised by the ICO and legally bind both the sender and the recipient to ensure personal data is processed in a manner that meets the UK GDPR requirements, maintaining the same level of protection as in the UK.
  • We use the International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum (Addendum) as applicable to make sure that personal data is transferred and processed in compliance with UK data protection laws.
  • Enforceable Rights and Remedies: We ensure that individuals whose data is transferred retain enforceable rights and access to effective remedies under UK data protection law.

It is important to note that regardless of the destination country, the data remains subject to the protection and safeguards required by the UK GDPR.

For more details about international data transfers, please contact customer services below:

CONSUMER RIGHTS

You have several rights regarding your personal information, including:

  • Access: Request a copy of the personal information we hold about you.
  • Rectification: Ask us to correct inaccurate or incomplete data.
  • Erasure: Request the deletion of your personal data in specific circumstances.
  • Restriction: Limit the use of your personal data in certain situations.
  • Objection: Object to the use of your data for specific purposes, such as direct marketing.
  • Automated Decision Review: Request human review of decisions made solely through automated processing.
  • Withdraw Consent: Revoke consent for data processing at any time.
  • Complain: Report concerns to the Information Commissioner’s Office (ICO).

To exercise your rights, contact us via:

  • Email: DPO@eroaming.co.uk
  • Post: Data Protection Officer, eROAMING Ltd, Rear of 18-20 Village Way East, Harrow. HA2 7LU.

For complaints, visit the ICO at ico.org.uk or call 0303 123 1113.

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