Collectively, the information described above and any other personally identifying information we may collect from you shall be referred to as “personal information.” Certain service providers and vendors may retain personal information for periods consistent with their contractual obligations with us and applicable legal requirements.  We may collect personal information:

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• Directly from you if and when you provide it to us, including through the contact page on the Platform, if you create an account with us, when you register or interact with the Platform, through e-mail and subscription services, if you order a product or service from us, or if you participate in an activity such as a survey or sweepstakes; 
• Automatically as you navigate through our Platform through cookies and other automatic forms of data collection.  Personal information collected automatically may include usage details, traffic patterns, browser information, IP addresses and other information collected through automatic processes; and 
• From Google One Tap authentication.

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You have a right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, our business purpose for collecting, selling and/or sharing personal information, the categories of service providers, contractors, and third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you, the consumer. If you cannot find the answer to any of the above categories, you have the right to ask for this information. You may contact us at info@roamwithus.com.

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Personal Information Retention

We will retain your personal information for periods of time that are no longer than necessary for the purpose for which such information was collected unless a longer period is required to provide services hereunder and/or to comply with applicable laws and regulations.  Retention periods may vary depending on the purpose for which the personal information was collected and used, which may differ depending on the nature of the personal information and the activities involved, and whether there are legal obligations to which we are subject.

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Information We Collect through Automatic Data Collection Technologies

As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including: 

• Details of your visits to the Platform, including traffic data, logs and other communication data and the resources that you access and use on the Platform; 
• Information about your computer, mobile device and internet connection, including your IP address, operating system, and browser type; and
• The approximate physical location of your computer and mobile device.

The information we collect automatically is intended to be statistical data and may include personal information. It helps us improve the Platform, deliver a better and more personalized service, and ensure the Platform is secure and safe to use.

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The technologies we use for this automatic data collection may include cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Cookies can be used to store a unique identification number tied to your device so you can be recognized as the same user across multiple browsing sessions and multiple websites. For example, if you personalize our web pages, or register with our websites or services, a cookie helps us to recall your specific information on subsequent visits to the Platform. This simplifies the process of recording and utilizing your personal information, such as billing addresses, shipping addresses, and so on, in order to improve your experience on the Platform. 

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When you return to the same website of ours, the information you previously provided can be retrieved, so you can easily use the features that you customized.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access certain parts of the Platform.  Unless you have adjusted your browser setting so that it will refuse cookies, we will issue cookies when you direct your browser to the Platform. You can potentially opt-out of receiving targeted advertising by visiting either of these outside websites www.aboutads.info or www.networkadvertising.org/choices and following the instructions regarding opting out provided therein.  For more information on how we use cookies, please refer to How We Use Cookies and Similar Technologies listed later in this document.. 

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California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to “Do Not Track” (“DNT”) browser settings or signals. At this time, we do not respond to DNT signals.  However, to the extent required under applicable law including the CCPA, we do recognize opt-out preference signals that communicate a consumer’s choice to opt-out of the “sale” or “sharing” of personal information, such as the Global Privacy Control (“GPC”). Where we receive a GPC signal, we will treat it as a request to opt-out of the sale and/or sharing of personal information for that browser or device (and, if we can reasonably associate the signal with an account, for that account as well).  If you use different browsers or devices, you may need to enable the signal separately on each browser or device.

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Information We Collect from Third Party Sources

We may also collect information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you.

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How We Use Your Personal Information 

We use information that we collect about you or your devices:

• To present the Platform and its content to you;
• To provide you with information, products or services that you request from us;
• To fulfill any other purpose for which you provide it;
• To provide you with information regarding the services we offer, including new products and services that we may introduce from time to time;
• To provide you with product literature; 
• To notify you about changes to the Platform or any products or services we offer or provide through it;
• To maintain and manage your account;
• To allow you to participate in interactive features on the Platform or access restricted areas of the Platform;
• To conduct research on our users’ demographics, interests and behavior;
• To perform analyses or for other purposes to improve the quality of the Platform and our business;
• To publish our own marketing and promotional materials, including online newsletters;
• To invite you to and register you for events;
• To provide you with offers and information about the Platform and our affiliates;
• To deliver targeted advertising, promotions and offers, on behalf of ourselves and advertisers, on and off the Platform;
• To process your requests, purchases, transactions and payments, and prevent transactional fraud;
• To manage credit risks;
• To report and file tax and other information to state tax agencies;
• To validate our customer base against sanctions lists;
• To ensure compliance across various segments of our business;
• To track and aggregate Platform visitors’ activity for purposes of analyzing general traffic flow on the Platform;
• In any other way we may describe when you provide the information; or
• For any other purpose with your consent.

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We may also use your information to contact you, via your e-mail address or phone numbers, about our services that may be of interest to you.  If you do not want us to use your information in this way, please do not sign up for our services, purchase our products, or register an account with us.  If you have already received e-mails, phone calls or text messages from us, and you wish to discontinue receiving such e-mails, phone calls, or text messages, you may opt-out by contacting us at info@roamwithus.com.

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Disclosure of Your Information

We may disclose personal information that we collect or you provide to service providers, contractors, and third parties including:

• To service providers and contractors we use to support the Platform and our services and who are bound by contractual obligations to keep your personal information confidential, including service providers and contractors who provide targeted advertisements, mailing, fax or email services, order fulfillment and shipping, delivery scheduling, marketing and promotional material distribution, data enhancement services, fraud prevention, web hosting, or analytic services;
• 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 users is among the assets transferred;
• To our affiliates and business partners;
• To social media services if you log into the Platform using social media services or if you connect a social media account with the Platform; 
• To the public when you provide feedback or post user content on our Platform. For example, if you post a product review on our Platform or a comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may appear on our Platform or on our social media pages;
• To third parties that provide content or functionality on the Platform or other websites or platforms;
• To common carriers and courier services;
• To product suppliers, including to fulfill warranty service obligations, complete drop ship transactions, for product recalls, or for transaction tracking regarding shipments or leases of the supplier’s products;
• In connection with our sponsorship of promotional events which require the collection, processing and storing of individual contact and demographic information to be used for the event. We may also co-sponsor these activities with other organizations. We may merge information about you which may then be shared on an aggregated basis with co-sponsors, advertisers and our affiliates. Your personal information will not be released by us to co-sponsoring third parties or non-participating organizations without your consent and, although we may request that co-sponsors of such events uphold the privacy of your personal information, we have no liability where the co-sponsors do not comply with our requests. 
• To fulfill the purpose for which you provide it;
• To publish our own marketing and promotional materials;
• If required by applicable law;

• To enforce or apply the Terms of Use and other agreements, including for billing and collection purposes;

• If we believe disclosure is necessary or appropriate to protect our rights, property or safety and that of our customers or others;
• To comply with a judicial proceeding, court order, other legal obligation or a regulatory or government inquiry;
• For any other purpose disclosed by us when you provide the information; or
• With your consent.

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We may disclose your personal information to a service providers, contractors, or other third parties for business purposes. In the last 12 months, we have disclosed the following categories of personal information to the following categories of service providers, contractors, and third parties:

• Identifiers to service providers, contractors 
• Categories of personal information described in the California Customer Records Act to service providers and contractors
• Commercial information to product suppliers, service providers, and contractors
• Internet or other electronic network activity to service providers and contractors 

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When we disclose personal information for a business purpose, we enter into a contract that describes the business purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

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We may share your personal information with third party cookie providers through the use of cookies.  In exchange, we understand if the Platform is functioning as intended, enabling us to refine the Platform, accordingly. For more information on how we use cookies, please refer to our Cookie Notice.

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While we have not “sold” personal information as that term is commonly used, in the last 12 months, we have transferred certain categories of personal information to service providers, contractors and third parties as follows:  Identifiers, Internet or other electronic network activity.  We do not knowingly sell or share for purposes of cross-context behavioral advertising the personal information of consumers.

The California Consumer Privacy Act of 2018, as amended by The California Privacy Rights and Enforcement Act of 2020 (collectively, the “CCPA”), prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales or sharing of your personal information.  However, any third party with whom we are allowed to share your personal information is authorized to use your personal information in accordance with their own privacy policies, over which we have no control.

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If you provide personal information about another person to us, you will be representing, and we will believe, that you have the consent of that individual to enable us to collect, use or disclose their information as described in this notice, and will rely on our belief and your representation.

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Update Your Information

You can modify your account with us by emailing us at info@roamwithus.com.  Even after you cancel your account or ask us to delete your personal information, copies of some information from your account may still be viewable if, for example, you have shared information with other services such as social media. Your account may not be instantly inaccessible to others due to the nature of caching technology.  Additionally, we may retain information related to your account after cancellation or your request for deletion to comply with legal requirements, for our internal security or recordkeeping, or for fraud detection.  We may not be able to completely delete all of your personal information due to financial, contractual or legal requirements, or technical constraints. 

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Your California Privacy Rights

This section only applies to certain California residents who are covered and protected by the CCPA.  If you are not a California resident, this section and the various rights and obligations described in this section, may not apply to you.

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Shine the Light Protection

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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, if applicable.  To make such a request, please contact us at info@roamwithus.com. If you believe any of the information we possess about you is incorrect, please contact us at the same webpage listed above.

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CCPA

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Consumers protected by the CCPA have specific rights regarding their personal information. 

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Access to Specific Information

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You have the right to request that we disclose to you the following about our collection and use of your personal information over the last 12 months:

• The specific pieces of personal information we collected about you.
• The categories of personal information we have collected about you in the last 12 months.
• The categories of sources from which the personal information was collected.
• The business or commercial purpose for collecting, selling, or sharing personal information. 

• The categories of service providers, contractors, and third parties to  whom we disclose the personal information. 
• The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose in the last 12 months and, for each category identified, the categories of service providers, contractors, and third parties to whom that particular category of personal information was disclosed for a business purpose.
• The categories of personal information that we sold or shared about you in the last 12 months and, for each category identified, the categories of service providers, contractors, and third parties to whom that particular category of personal information was sold or shared.

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We are not required to provide you with these disclosures more than twice within a 12-month period.  

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For requests seeking disclosure of specific pieces of information, we will not disclose any such information if we cannot verify the identity of the requestor.  Similarly, for requests seeking categories of personal information, we may deny the request if we cannot verify the identity of the requestor. In either case, we will inform the requestor that we cannot verify their identity, and direct them to the general business practices regarding collection, maintenance, sale and sharing of personal information in our privacy policy.

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If we deny your request for specific pieces of personal information, in whole or in part, because of a conflict with applicable laws or an exception to the CCPA we will inform you and explain the basis for the denial. 

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At no point will we ever disclose pursuant to a verifiable consumer request a consumer’s social security number, driver’s license number, other government-issued identification number, financial account number, health insurance or medical identification number, account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. If applicable, we will notify you in response to a request for information that we have collected such information from you.

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Right to Request Deletion

You have the right to request that we delete any personal information about you which we have collected from you. Upon receipt of a verifiable consumer request to delete your personal information, we will delete such information and direct our service providers and contractors to delete your information from their records, subject to certain exceptions provided in the CCPA including, but not limited to, if it is necessary for us or our service providers or contractors to maintain the personal information in order to: 

(1) complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated by the consumer within the context of our ongoing business relationship with you, or otherwise perform a contract between us; 

(2) help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes; 

(3) debug to identify and repair errors that impair existing intended functionality; 

(4) exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech, or exercise another right provided for by law; 

(5) comply with the California Electronic Communications Privacy Act; 

(6) engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent; 

(7) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which the consumer provided the information; or

(8) to comply with a legal obligation. 

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We use a two-step process for requests to delete personal information. First, you must make a verifiable consumer request. After receiving your request, we will contact you to separately confirm that you want your personal information deleted. We will contact you further once your personal information has been deleted.

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If we cannot verify the identity of the person requesting deletion of personal information, we may deny the request and will inform the requestor we cannot verify their identity.  If we deny your request to delete personal information, we will notify you of the reasons why. We will delete any part of your personal information not covered by the exception allowing us to deny deletion of a portion of your personal information. 

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We may maintain a confidential record of deletion requests solely for the purpose of preventing the personal information of a consumer who has submitted a deletion request from being sold, for compliance with laws, or for other purposes solely to the extent permissible under the CCPA.

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Right to Correct Inaccurate Personal Information

You also have the right to request that we correct any inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.  If we receive a verifiable request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the inaccurate personal information. 

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Non-Discrimination

If you are a California resident covered by the CCPA we will not discriminate against you merely because you have exercised any of your rights thereunder, including if you are an employee, applicant and/or an independent contractor.  Except as permitted by the CCPA, we will not, merely because you have exercised your rights thereunder, do any of the following:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties;
• Provide you with a different level or quality of goods or services; or
• Suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services.

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Opt-Out Right

California residents have the right to opt-out of the sale or sharing of personal information under the CCPA.  For purposes of the CCPA, “sharing” means the disclosure of personal information to a third party for cross-context behavioral advertising.  We do not sell or share personal information, including for purposes of cross-context behavioral advertising. As a result, we do not offer a “Do Not Sell or Share My Personal Information” mechanism at this time.  

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If our data practices change in the future and we begin selling or sharing personal information, we will update this Privacy Policy and provide consumers with the right to opt-out as required by law.  

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The Platform is intended for users ages 16 and up. 

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Right to Limit Use and Disclosure of Sensitive Personal Information

We may collect certain sensitive personal information, such as government-issued identification documents (e.g., driver’s license or passport), where necessary to facilitate travel bookings, verify identity, comply with legal or regulatory requirements, and prevent fraud.  We use sensitive personal information only as reasonably necessary and proportionate to provide the services requested by users, ensure security and integrity, comply with applicable laws, and fulfill our contractual obligations.  We do not use sensitive personal information for purposes beyond those permitted under the CCPA, such as behavioral advertising, profiling, or cross-context marketing.  Because we use sensitive personal information solely for purposes permitted under California law, we do not offer a separate right to limit the use of sensitive personal information.

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Contact Information 

To request your right to disclosure or deletion of the personal information we have collected about you, please submit a verifiable consumer request to us by emailing us at info@roamwithus.com. If you have questions or concerns about our privacy policies or practices, please contact us at info@roamwithus.com.

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A verifiable consumer request can only be made by you or by a person or entity registered with the California Secretary of State authorized by you to act on your behalf. In order to ensure we are able to promptly respond to your request, your request should include sufficient information that allows us to verify you are the person about whom we collected personal information or that you are an authorized representative of such person (including, for example, your full name, email address, and mailing address) and a detailed description of what you are requesting. We will review the identifying information provided in your request against information contained in our records to verify the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

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If you are using an authorized agent to exercise any of your rights under the CCPA you must provide us proof in the form of a signed, written authorization of the authorized agent’s ability to act on your behalf. You must also provide us with your full name, email address and mailing address to enable us to verify your identity.  We will confirm receipt of your verifiable consumer request within 10 business days of our receipt. We will also provide you with information about our verification process and when you should expect a response. 

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We will disclose and deliver the personal information required within 45 days of receiving your verifiable consumer request.  Should we require more time (up to an additional 45 days), we will notify you of the extension and the reasons for the delay.  The disclosure will cover the 12-month period preceding the receipt of your verifiable consumer request.

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If requests from you are manifestly unfounded or excessive, we may charge a reasonable fee to respond to your request or we may refuse to act on the request. If we choose not to take action on your request, we will notify you of the reasons behind our decision.

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Children’s Privacy

Our services are not directed to, and we do not knowingly collect personal information from, children or persons under the age of 16.  If we receive personal information that we discover was provided by a child or a person under the age of 16, we will promptly destroy the information.  Please contact us immediately if you become aware that a child or person under the age of 16 has provided us with personal information so that we may investigate and delete information as may be appropriate. We recommend that parents actively participate in their children’s use of the Internet.

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Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect the personal information we collect against unauthorized access, disclosure, alteration, or destruction. These measures include, among other things, encryption of personal information both at rest and in transit, access controls designed to limit access to authorized personnel, secure file storage, and technical measures intended to protect against automated abuse and unauthorized access.

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Where applicable, we use modern authentication methods designed to reduce the risk of unauthorized account access and employ safeguards such as CAPTCHA and similar technologies to help protect the Platform from misuse. We also implement row-level security (RLS) and other internal controls intended to restrict access to personal information based on role and necessity.

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Despite these measures, no method of transmission over the Internet or method of electronic storage is completely secure. Accordingly, we cannot guarantee the absolute security of personal information. You are responsible for maintaining the confidentiality of any credentials or access methods associated with your account and for taking reasonable steps to protect your devices and access information.

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If you believe that your account or personal information has been compromised, please notify us immediately by contacting us at info@roamwithus.com.

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Links to Other Websites

We may provide and/or permit other parties to provide links to other websites or resources.  Because you acknowledge and agree that we have no control of such websites and resources, we are not responsible for the accuracy, reliability or availability of such websites or resources, and we do not endorse and are not responsible or liable for any content, advertising, products, information, data, opinions, advice, statements or other materials on or available from such websites or resources.  If you decide to access any of the third-party websites linked to our Platform, you do so at your own risk.  Please read the terms and conditions and privacy policies of any other company or website you may link to from our Platform.  You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, goods or services available on or through any such website or resource.  We reserve the right to terminate any link or linking program at any time.  We disclaim all warranties, express and implied, as to the accuracy, validity, and legality or otherwise of any materials or information contained on such sites.  If you are interested in linking to the Platform, please contact us at info@roamwithus.com.

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How We Use Cookies and Similar Technologies

The Platform and service providers, contractors, and third parties that provide content and functionality on the Platform may use cookies, web beacons and similar technologies to improve the Platform, provide you with a personalized experience, or to facilitate administration and navigation of the Platform. This section describes our use of both first party and third party cookies on the Platform.  

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first party cookies. 

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More specifically, we use cookies and other tracking technologies for the following purposes:

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• Assisting you in navigation
• Assisting in login and your ability to provide feedback
• Analyzing your use of our products, services or applications

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Essential Cookies

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We use Essential Cookies we use on our Platform.  These cookies are necessary for the Platform to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.  You can set your browser to block or alert you about these cookies, but some parts of the Platform will not then work. These cookies do not store any personally identifiable information.

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Google Maps/Google Earth

If you use Google Maps/Google Earth as part of our services, you agree to comply with the Google Maps/Google Earth Additional Terms of Service (including the Google Privacy Policy). Further, you agree that Google, and not us, shall be responsible for any of your information Google receives as a result of your use of Google Maps/Google Earth.

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Contact Information and Refusal to Consent

To ask questions or comment about this Privacy Policy and our privacy practices, including reviewing and requesting changes to any of your collected personal information, contact us at info@roamwithus.com.

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If you do not consent to the collection, use and disclosure of your personal information, please do not provide us with personal information.