Privacy Policy

Effective as of August 25, 2025

This Privacy Policy describes the privacy practices of Roam HQ Inc. (“Roam," "we,” “us” or "our") and how we handle personal information that we collect as a controller through our website at https://ro.am/ (the “Site”) and through social media, our marketing activities, when you sign up for an account through your employer or school on our Services, and other activities described in this Privacy Policy, and that we collect as a processor on behalf of our enterprise customers (e.g., other businesses or educational institutions) through our mobile application and web-based platform (the app and platform collectively, the “Services”). As appropriate, this Privacy Policy will distinguish between our practices as a controller (which is when we process data for our own purposes) and our practices as a processor (which is when we process data on behalf of our enterprise customers as a service provider in connection with our provision of the Services).

As part of the Services, Roam provides a platform that gives companies and educational institutions their own virtual HQ for colleagues, guests, students, and/or customers to access and collaborate. If you have concerns regarding personal information that we process on behalf of a an enterprise customer, please direct your concerns to that enterprise.

If you are located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), please consult the Notice to European Users section below.

Index

Personal information we collect as a Controller
How we use your personal information as a Controller
How we share your personal information as a Controller
Your choices for personal information we collect as a Controller
Third-party sites and services
How long do we keep your personal information
Security
International data transfer
Children
Changes to this Privacy Policy
How to contact us
Personal information we collect as a Processor
How we use your personal information as a Processor
How we share your personal information as a Processor
Notice to European users

Personal information we collect as a Controller

When you visit our Site, create an account with us (including through your employer or school) to use the Services, or communicate with us, we may collect certain personal information about you for which we act as a controller. This section describes the types of personal information we may collect about you as a controller, and the ways in which we collect such information. For clarity, Section I of this Privacy Policy does not apply to information that we process on behalf of our enterprise customers while providing the Services to them — such information is covered under Section II of this Privacy Policy.

Information you provide to us. We may collect the following types of personal information directly from you when you provide it to us (e.g., through our Site or when you register to use the Services):

Contact information, such as your first and last name, email address, billing and mailing addresses, professional title and company name, school affiliation, and phone number.
Account data, such as the username and password that you may set to establish an online account with us to use the Services, photograph or picture, and any other information that you add to your account profile.
Payment information needed to complete transactions, including payment card information or bank account number. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, as described further below.
Communications that we exchange with you, including when you contact us with questions or feedback, through the Site, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications, details about your engagement with them and information about how you heard about us.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Data providers, such as information services and data licensors that provide demographic and other information.
Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. If you visit our Site or Services, we may automatically log the following types of information about you, your computer or mobile device, and your interactions over time with us:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Activity data on the Roam Site and Services, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Site (via referral information), navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.
Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

How we use your personal information as a Controller

For the personal information we collect about you as a controller, we may use such personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal information to:

provide, operate, maintain and improve the Site, the Services and our business;
establish and maintain your user account on the Site and Services;
enable security features of the Site and Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Site and Services, including by sending announcements, updates, security alerts, and support and administrative messages;
understand your needs and interests, and personalize your experience with the Site and Services and our communications; and
provide support for the Site and Services, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Site and Services and our business. As part of these activities, we may create aggregated, de-identified or anonymous data from personal information we collect. We may use this aggregated, de-identified or anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Site and Services and promote our business. We will maintain and use any de-identified data only in a de-identified fashion and will not attempt to re-identify such data.

Marketing. We and our service providers may collect and use your personal information for direct marketing purposes. We may send you Roam-related marketing communications about our products, services or promotions that may be of interest to you. You have the right to prevent direct marketing of any form at any time. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Site or Services or otherwise; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Enterprise customers. Our enterprise customer that is using the Services (e.g., your employer or school).

Business and marketing partners. Third parties with whom we collaborate on joint activities, with whom we have entered into joint marketing relationships or other joint ventures (such as resellers of the Services), or who we think may offer you products or services that you may enjoy.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, such as third-party account managers or resellers of our Services.

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Roam or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your choices for personal information we collect as a Controller

For the personal information we collect about you as a controller, you have the following choices with respect to such personal information. Users who are located in the EEA or the UK can find additional information about their rights in the Notice to European Users section below.

Access or update your information. If you have registered for an account with us, you may review and update certain account information by logging into your account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

Third-party sites and services

The Site and Services may contain links to or integrations with third party websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other third party websites and mobile applications and online services you use.

Where an enterprise customer chooses to use a third-party application or software that is integrated with the Services (each, a “Third-Party Integration”), we may receive personal information from such enterprise customer’s use of the Third-Party Integration for which we act as a processor on their behalf. The information made available to us through a Third-Party Integration is in accordance with our agreement with the provider of the Third-Party Integration and any permission(s) granted by our enterprise customer (including, by its users) which are visible to users prior to authorizing a Third-Party Integration.

For the personal information we collect via a Third-Party Integration, we may use such personal information for the following purposes:

to provide, operate, and improve the Site and Services; and
to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For the personal information we collect via a Third-Party Integration, we may share such personal information with the following types of third-parties for the following purposes:

to service providers for the purpose of helping us provide, operate and improve the Site and Services;
to legal authorities as we believe in good faith to be necessary or appropriate for the compliance with applicable laws, lawful requests, and legal process; and
to acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Roam or our affiliates (including, in connection with a bankruptcy or similar proceedings).

The use of raw or derived user data received from Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements.

How long do we keep your personal information

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes: (i) as long as it is necessary and relevant for our operations and to provide our Site and Services, e.g., so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and (ii) to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and Services terms and take other actions as permitted by law. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize or deidentify it, or isolate it from further processing.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may be different from those in your state, province, or country.

Users in the EEA and the UK should read the important information provided in the Notice to European users below about transfer of personal information outside of the EEA and UK, as applicable.

Children

Our Services are not intended for use by children under 13 years of age in the United States or under 16 years of age outside of the United States. If we learn that we have collected personal information through our Services from a child under 13 or 16, respectively, without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns, or who believe that we might have personal information from or about a child under 13 or 16 as applicable, to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Site. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). We recommend that you check this Privacy Policy periodically for any updates or changes.

How to contact us

Email: privacy@ro.am
Mail: 40 Monroe Place, Brooklyn NY 11201
Phone: +1 (508) 479-5628

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Roam has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, Roam has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

Personal information we collect as a Processor

When you use our enterprise customers’ implementation of our Services, we may collect certain personal information about you, for which we act as a processor on behalf of our enterprise customers (who act as the controllers of such data). This section describes the types of personal information we may collect about you as a processor, and the ways in which we collect such information. Please note our use and processing of this personal information as a processor is governed by our agreements with our enterprise customers. Our enterprise customers may have their own privacy policies that govern the personal information collected in connection with their use of our Services, and you should consult the policies of and/or contact the applicable enterprise customer to see how they process and share your personal information relating to the Services, including with respect to any rights you may have to such personal information. If we receive any requests to exercise such rights with respect to personal information for which we act as a processor, we are not able to directly accommodate such requests but will forward such requests to the applicable enterprise customer (or otherwise follow the procedure we have agreed upon with the applicable enterprise customer).

Information you provide to us. We may collect the following types of personal information directly from you (on behalf of our enterprise customers) when you provide it through the Services or our enterprise customer’s implementation of our Services:

Contact data (excluding data provided to create your account and other data for which we act as a controller), such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, school affiliation, and phone number that you provide in connection with your general use of the Services.
Phone contacts data, such as the contacts in your address book if you choose to share such access with us. You may revoke such access at any time in your settings.
Demographic data, such as your city, state, country of residence, postal code, and age.
Virtual meeting data, such as the time, place, platform and content of virtual meetings (e.g., video calls, audio calls and other meetings). This includes meetings that occur off the Service, if you are a user of Magic Minutes Desktop Recording, which captures all audio received by your device while activated. Virtual meeting data may include audio and visual recordings of meetings, any messages exchanged during meetings occurring on the Roam platform, and AI-generated transcriptions and summaries of meetings.
User-generated content data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Data about others. We may collect personal information about others, such as:

When users invite their contacts to connect on, or to join, the Service, we collect contact details about these invitees so we can facilitate those connections or invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
When users invite their contacts to participate in a meeting or otherwise participate in meetings with third parties (including meetings that occur off the Service, for users of Magic Minutes Desktop Recording), we collect contact details about these third-party attendees and “Virtual meeting data,” as described above, related to these attendees. You may not record, capture or share audio, video or images of any third party unless you have notified them in advance that you will record, capture or share such information and obtained their permission to do so.

How we use your personal information as a Processor

For the personal information we collect about you as a processor on our enterprise customers’ behalf, we may use such personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal information to:

provide and operate the Services (including to provide audio and video recordings and AI-generated transcripts and summaries of meetings);
facilitate your invitations to contacts who you want to connect with on, or invite to join, the Service (including providing recommendations for contacts you may know); and
provide support for the Services, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business. As part of these activities, we may create aggregated, de-identified or anonymous data from personal information we collect. We may use this aggregated, de-identified or anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Services or otherwise; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

For the personal information we collect about you as a processor on our enterprise customers’ behalf, we may share such personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Enterprise customers. Our enterprise customer that is using the Services.

Service providers. Third parties that provide services on our behalf or help us operate the Site and Services or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics). Service providers also include AI providers and platforms that we use to provide the Services, including to facilitate recording, transcribing and summarizing meetings.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Others at your direction or with your consent. Magic Minutes and Magic Minutes Desktop Recording users may share or provide access to “Virtual meeting data” (including audio and video recordings and AI-generated transcripts and summaries of meetings) with third parties, including individuals who did not participate in the meeting.

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies where we are processing the personal information of individuals located in the EEA or the UK (EEA and UK jurisdictions are together referred to as “Europe”) as a controller. It does not apply to our processing of personal data as a processor.

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.

Controller. Roam is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so- called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the How to contact us section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to process your personal information to deliver our Services to you (including our Site) (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see How we use your personal information above.

Purpose	Categories of personal information involved	Legal basis
Service delivery	Business contact information Account data Communication data Transactional data	Contractual Necessity
Research and development	Any and all data types relevant in the circumstances	Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers.
Direct marketing	Business contact information Profile Account data Transactional data Communication data Marketing data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law. Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information. You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Services to you. We will notify you if this is the case at the time.

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Services.

No Automated Decision-Making and Profiling. As part of the Services, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy.

Security. We have put in place procedures to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information's accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.
Object. Object to our processing of your personal information where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.
Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

Exercising These Rights. You may submit these requests by email to privacy@ro.am. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en.
For users in the UK – the contact information for the UK data protection regulator is below:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Services, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe.

It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the US legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the US, see above).
- However, in these cases:
  - we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or
  - in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.