Roamler America Inc. Privacy Notice
This Privacy Notice describes how Roamler America Inc. collects, uses, and discloses personal information about Contributors who register for or use the Roamler App to perform Tasks. It applies to US residents who register for or use the Roamler App. Undefined capitalized terms have the meanings given in the Roamler Contributors' Terms of Use.
1. Who We Are
Roamler America Inc., 8 The Green, STE B, Dover, DE 19901, United States, and Roamler B.V., our affiliate established in the Netherlands, act as joint controllers of your personal information for purposes of this Notice, within the meaning of Article 26 of the GDPR to the extent the GDPR applies. Roamler America Inc. determines the purposes for which your personal information is collected and maintains the direct relationship with Contributors, including operating this Notice. Roamler B.V. designs and operates the platform and systems that support the App and Site and determines the material elements of how your personal information is processed through that platform. Roamler America Inc. is your primary point of contact for exercising your rights under this Notice, including any Data Subject Request. Roamler America Inc. is part of the Roamler group, which is headquartered in Amsterdam, the Netherlands. Contact: security@roamler.com.
2. Information We Collect
We do not knowingly collect information from anyone under 18. We do not sell your personal information, and we do not share it for cross-context behavioral advertising. The categories of information we collect are described in the table below.
| Category | Examples | Source | Purpose |
|---|---|---|---|
| Identifiers | Name, email, mobile phone number, postal address, state of residence, account username | You | Account creation, phone verification, communication, state-based Task availability |
| Certification data | Age (18+) certification, work-authorization self-certification | You | Eligibility |
| Financial information | Payment processor account details; payout history; tax forms (e.g. W-9) where required | You / Payment processor | Paying Fees; legally required tax reporting |
| Geolocation | GPS location while using the App | Your device | Showing nearby Tasks; verifying Task performance location |
| Submissions | Photos, answers, and other Task content | You | Delivering Task results to Clients; quality review |
| Device & usage data | Device and browser information, IP address, in-app activity | Automatic | Security, fraud prevention, improving the App |
| Optional profile data | Profile photo, gender | You (optional) | Profile display |
3. How We Share Information
We share your personal information as follows:
- Clients: your name and profile photo may be visible to the Client when you accept their Task; Submissions are delivered to the Client.
- Service providers: hosting, analytics, support tooling, and third-party payment processors for payouts (payment processors process your payment data under their own privacy statements and may have their own legal reporting duties, e.g. IRS Form 1099-K).
- Legal: authorities where required by law (including tax authorities), and parties to a corporate transaction involving Roamler, with safeguards.
- We may share aggregated or de-identified data that cannot reasonably be linked to you.
We do not share your mobile phone number, or any other mobile information, with third parties or affiliates for marketing or promotional purposes. See Section 4.
4. SMS / Mobile Information
Roamler uses your mobile phone number solely to send a one-time verification code. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.
4.1 What we collect and why. When you register in the Roamler App you enter your mobile phone number. We use it to send you a one-time verification code by SMS, to confirm the number belongs to you and to secure your Account. The program is called Roamler phone verification (SMS); its terms are set out in Section 13 of the Contributors' Terms of Use.
4.2 Frequency and cost. Message frequency: 1 message per verification request. Roamler does not charge you for these messages; message and data rates may apply, according to your mobile carrier's plan.
4.3 No marketing. We do not use your mobile phone number to send marketing or promotional messages, and we do not sell or rent it. Your opt-in data and consent for text messaging are never shared with any third parties.
4.4 Service providers. We use a messaging service provider to deliver the verification message on our behalf. That provider processes your phone number only to transmit the message under our instructions, and is not permitted to use it for its own marketing or promotional purposes.
4.5 HELP and STOP. Reply HELP to any message for help, or contact support@roamler.com. Reply STOP to opt out; you will receive one confirmation message and no further messages.
4.6 Retention. Your mobile phone number is retained with your Account as described in Section 6. Verification codes themselves are short-lived and are discarded after use or expiry.
5. International Transfer
Roamler America Inc. is based in the United States. Your information is also processed by Roamler B.V., our joint-controller affiliate in the European Economic Area (the Netherlands), which designs and operates the platform and all systems that support the App and Site. Because Roamler B.V.'s relevant processing activities are carried out in the context of its establishment in the European Union, the GDPR applies to Roamler B.V.'s processing of your information within the meaning of Article 3(1) of the GDPR, regardless of your location in the United States, in addition to the U.S. privacy laws described in this Notice. Separately, if our personnel access your information directly from the United States where it is stored or processed by Roamler B.V. on systems in the Netherlands or elsewhere in the European Economic Area, that access is a transfer of personal data from the European Economic Area to the United States under Chapter V of the GDPR. For any such access, we rely on Roamler America Inc.'s self-certification under the EU-U.S. Data Privacy Framework, to the extent it applies, or otherwise on the Standard Contractual Clauses adopted by the European Commission, as the transfer mechanism.
6. Retention
We keep your information while your Account is active. After deactivation, or after 13 months of inactivity, we delete or de-identify it, except where longer retention is required by law (for example, tax and payment records).
7. Security
Access controls with authenticated login, encryption in transit (TLS), access limited to personnel who need it, and an ISO 27001-certified information-security management system.
8. Your Rights — State Privacy Laws
California's CCPA/CPRA and similar comprehensive privacy laws in other states (including Virginia, Colorado, Connecticut, and Texas) apply once Roamler meets their statutory thresholds (e.g. revenue or data-volume levels). Pending that, Roamler voluntarily extends the following rights to all US Contributors: to know, access, correct, and delete your personal information (subject to legal exceptions, such as tax records); to opt out of sale or sharing (we do not sell or share personal information); to limit use of sensitive personal information; to portability; and to non-discrimination for exercising these rights, including a right to appeal a refusal. These rights apply to workers and independent contractors as well as consumers.
Submit requests to security@roamler.com. We will verify your identity and respond within 45 days (extendable once by 45 days). You may designate an authorized agent.
9. Changes and Contact
We may update this Notice; material changes will be announced in the App or by email before they take effect. Questions: security@roamler.com.
10. Supplemental Notice for California Contributors
This Supplemental Notice for California Contributors supplements the Notice above and applies solely to Contributors who are California residents, as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA"). Because the CCPA's prior exemption for personal information collected in a job-applicant, employee, or independent-contractor context expired on January 1, 2023, the rights described in this Supplemental Notice apply to you as a Contributor to the same extent as to any other California consumer.
10.1 The categories of personal information we have collected about California Contributors in the twelve months preceding the effective date of this Notice, their sources, and our purposes for collecting them are described in the table in Section 2 above. We disclose those categories to the categories of recipients described in Section 3 above (Clients, Service Providers, and for Legal Compliance) for the business purposes stated there. We do not sell or share personal information as those terms are defined by the CCPA.
10.2 Sensitive Personal Information. Your precise geolocation, collected as described in Section 2, is "sensitive personal information" under the CCPA. We collect and use it only to show you nearby Tasks and to verify your Task performance location — purposes for which the CCPA does not require us to offer a right to limit use or disclosure. We do not use sensitive personal information to infer characteristics about you, and we do not sell or share it.
10.3 Your CCPA Rights. If you are a California resident, you may have the right to request that we: (a) disclose the categories and specific pieces of personal information we have collected about you, the sources of that information, and the purposes for collecting it; (b) provide access to or a copy of your personal information; (c) delete your personal information; (d) correct inaccurate personal information; and (e) limit the use of sensitive personal information, subject to the exemption described above. You have the right not to be discriminated against for exercising these rights, subject to legal exceptions.
10.3.1 To exercise these rights, submit a request to security@roamler.com. We will verify your identity before fulfilling your request and will respond within the timeframe required by law (45 days, extendable once by 45 days). You may designate an authorized agent to make a request on your behalf, and you have the right to appeal a denial of your request.
10.4 California Shine the Light. California Civil Code Section 1798.83 separately permits California residents to request a list of the categories of personal information we have disclosed to third parties for those third parties' own direct marketing purposes during the preceding calendar year, along with the names and addresses of those third parties. We do not disclose personal information to third parties for their own direct marketing purposes, so no such list currently applies to us; you may still submit a request, free of charge and no more than once per year, to security@roamler.com.