Privacy Policy

PRIVACY POLICY
Updated: November 2, 2022

1. Introduction.

A. VantagePointCenters, LLC. d/b/a Roam (“we”, “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy. The privacy policy contained herein, and as amended from time to time (“Privacy Policy”) describes the types of information we may collect or that you may provide when you purchase, download, install, register with, access or use the Roam Virtual web-based platform (“Platform”) and our practices for collecting, using, maintaining, protecting and disclosing that information.
B. This Privacy Policy applies only to information you provide or we collect via the Platform, in email, text and other electronic communications set through or in connection with the Platform and any other sources. This Privacy Policy does not apply to information that we collect offline or websites, including websites you may access through Platform or you provide to or is collected by any third party. Our websites and apps and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
C. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not register with or use the Platform. By downloading, registering with or using the Platform, you agree to this Privacy Policy. This Privacy Policy may change from time to time, and will be posted on our website at www.meetatroam.com/privacypolicy. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check the website periodically for updates.

2. Users under the Age of 18. The Platform is not intended for users under 18 years of age, and we do not knowingly collect personal information from users under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us.

3. Information We Collect and How We Collect It. We may collect information from and about users of the Platform directly from you when you provide it to us and/or automatically when you use the Platform.

A. Information You Provide to Us.

i. When you download, register with or use the Platform, we may ask you provide information by which you may be personally identified, such as, but not limited to, name, postal address, email address, telephone number, geolocation, mobile device identification number, or any other identifier by which you may be contacted online or offline (“personal information”), or that is about you but individually does not identify you.

ii. This information includes: (a) information that you provide by filling in forms in the Platform. This includes information provided at the time of registering to use the Platform, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Platform; (b) records and copies of your correspondence (including email addresses and phone numbers), if you contact us; (c) your responses to surveys that we might ask you to complete for research purposes; (d) details of transactions you carry out through the Platform and of the fulfillment of your orders (note that you may be required to provide financial information before placing an order through the Platform); and, (e) your search queries on the Platform.

iii. You may provide information to be published or displayed (“Posts” or “Posted”) to other users on or through the Platform (collectively, “Content”). Your Content and Posts may be transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons.

iv. In the event that we provide you with social media login capability, In order to register as a user with us, you may be asked to sign in using your Facebook or other social media site (“SMS”) login. If you do so, you authorize us to access certain SMS account information, such as your public SMS profile (consistent with your privacy settings in SMS), your email address, interests, likes, gender, birthday, education history, relationship interests, current city, photos, personal description, friend list, and information about and photos of your SMS friends who might be common SMS friends with other users. You will also be asked to allow us to collect your location information from your device when you download or use the Platform. In addition, we may collect and store any personal information you provide while using the Platform or in some other manner. This may include identifying information, such as your name, address, email address and telephone number, and, if you transact business with us, financial information. You may also provide us photos, a personal description and information about your gender and preferences for recommendations, such as search distance, age range and gender. If you chat with other users, you provide us the content of your chats, and if you contact us with a customer service or other inquiry, you provide us with the content of that communication.

B. Automatic Information Collection and Tracking.
i. When you access the Platform, technology may be used to automatically collect certain information, including, but not limited to:
〈 Usage Details. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the Platform.
〈 Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
〈 Stored Information and Files. The Platform also may access metadata, tags and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information.
〈 Location Information. The Platform may collect real-time information about the location of your device.

ii. We also may use technologies to collect information about your usage of the Platform over time. If you do not want us to collect this information either cancel your account or do not access the Platform.

C. Information Collection and Tracking Technologies. The technologies we use for automatic information collection may include:〈 Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of the Platform.
〈 Web Beacons. Pages of the Platform or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

4. Third-Party Information Collection.

A. Aggregated and/or non-personal information. SMS opt-in consent and data collected via SMS will not be distributed or sold to any external parties or entities. We may use and share non-personal information we collect under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising on the Platform and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form. To opt-out of cookies that may be set by third party data or advertising partners, please go to www.aboutads.info/choices/.

B. When you use the Platform or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: advertisers, ad networks and ad servers, analytics companies, your mobile device manufacturer, your mobile service provider, etc.

C. These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

D. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

5. How We Use Your Information.

A. We use information that it collects about you or that you provide to us, including any personal information, to:
〈 Provide you with the Platform and its contents, and any other information, products or services that you request from us.
〈 Fulfill any other purpose for which you provide it.
〈 Give you notices about your account or subscription, including expiration and renewal notices.
〈 Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
〈 Notify you of changes to any Services we offer or provide though the Platform.
B. The usage information we collect helps to learn more about our members and to improve the Platform and to deliver a better and more personalized experience by enabling us to:
〈 Estimate our audience size and usage patterns.
〈 Store information about your preferences, allowing us to customize the Platform according to your individual interests.
〈 Speed up your searches.
〈 Recognize you when you use the Platform.
C. We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

6. Disclosure of Your Information.

A. We may disclose aggregated information about our users without restriction. In addition, we may disclose personal information that we collect or you provide:
〈 To our subsidiaries and affiliates.
〈 To contractors, service providers, content providers, and other third parties we use to support our business.
〈 To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about the Platform users is among the assets transferred.
〈 To third parties to market their products or services to you.
〈 To fulfill the purpose for which you provide it.
〈 For any other purpose disclosed by us when you provide the information.
〈 With your consent.
〈 To comply with any court order, law or legal process, including responding to any government or regulatory request.
B. If we believe disclosure is necessary or appropriate to protect our rights, property, or safety or that of our customers, users, contractors or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7. Accessing and Correcting Your Personal Information. You can review and change your personal information by logging into the Platform and visiting your account profile page. You may also send us an email as noted below to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your Content or posts from the Platform, copies may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users. As we develop our business, we might buy or sell businesses or their assets, or engage in transfers, acquisitions, mergers, restructurings, changes of control, or other transactions. In such transactions, customer information generally is one of the disclosed and/or transferred business assets and your information may be subject to such a transfer. You agree to and do hereby consent to any such disclosure and/or transfer. Also, in the unlikely event of a bankruptcy, your information may be transferred to a bankruptcy trustee or debtor in possession and then to a subsequent purchaser.

8. Social Media Plug-ins. When applicable we integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including Facebook, Twitter, Instagram, Tumblr, Pinterest and possibly others, into our Platform. Plug-ins may transfer information about you to the Plug-in’s respective platform without action by you. This information may include your platform user identification number, which website you are on, and more. Interacting with a Plug-in will transmit information directly to that Plug-in’s social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective platform’s privacy policy, and not by our Privacy Policy.

9. Your California Privacy Rights. California Civil Code Section 1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as noted below.

10. Data Security. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. You should not share your password with anyone. Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do use commercially reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

11. DMCA Notification.

A. We respect the rights of intellectual property holders. If you believe that any content on the Platform violates this Privacy Policy or your intellectual property rights, you can report such violation to us in accordance with the Digital Millennium Copyright Act (17 U.S.C. §512). In the case of an alleged infringement, please provide the following information:

i. A description of the copyrighted work or other intellectual property that you claim has been infringed;

ii. A description of where the material that you claim is infringing is located on the Platform (including the exact URL);

iii. An address, a telephone number, and an e-mail address where we can contact you;

iv. A statement that you have a good faith belief that the use is not authorized by the copyright or other intellectual property rights owner, by its agent, or by law;

v. A statement by you under penalty of perjury that the information in your notice is accurate and that you are the copyright or intellectual property owner or are authorized to act on the owner’s behalf; and,

vi. Your electronic or physical signature, or that of the person authorized to act on behalf of the owner of the copyright or other right being infringed.

B. We may request additional information before we remove allegedly infringing material. You may report a copyright violation by providing the above information to the following Roam designated agent: VantagePoint Centers, L.L.C., Attn: Elle Snyder; Phone: 770-648-2921; Email: [email protected].

C. We will terminate the user account of any user who repeatedly submits content that violates our intellectual property policies. A repeat infringer is a user who has been notified of infringing activity more than twice and/or has had User Content removed from the Platform more than twice.

12. Privacy Concerns. If you have any concern or complaint about privacy on the Platform or our Service, please contact us using the contact information above. We will do our best to respond to you in a timely and professional manner in order to answer your questions and resolve your concerns.

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