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Privacy Policy

Last updated: [DATE] · Version [x.x]

⚠️ DRAFT — pending legal review. This document is a good-faith working draft, not legal advice. Bracketed [PLACEHOLDERS] must be completed by counsel before public launch.
  1. Controller. Roammingo is operated by [LEGAL ENTITY], [REGISTERED ADDRESS]. Privacy contact: [PRIVACY EMAIL]. EU representative (Art. 27): [EU REP]. UK representative: [UK REP]. DPO: [DPO or "not appointed; contact above"].
  2. Scope. Covers our web app / PWA; applies to users in the EEA, UK, and US (California — see §13).
  3. Data we collect. You provide: name, email (via Clerk); chat messages and free text; saved itineraries; travel preferences and home airport; dietary restrictions / accessibility needs (optional — may reveal health, religious or belief information); price-watch criteria; alert contact details. Automatically: IP address (stored anonymized in our logs), device/usage data, analytics events (see the Cookie Notice); performance/security logs. Anonymous trial: chat content you enter before signing up. Launch waitlist: if you join our pre-launch waitlist, your email address (with your consent, to send launch updates only; unsubscribe or request erasure anytime).
  4. Why & legal basis. Account = contract; chat / trip planning = contract; special-category dietary/accessibility = your explicit consent; analytics = consent; alerts = consent (or contract if you request them); security logging = legitimate interests. Special-category data is processed only with your explicit consent, withdrawable anytime in your account settings.
  5. Automated processing & AI. Inputs are processed by a third-party LLM (Anthropic Claude) to generate suggestions. We do not make solely-automated decisions with legal or similarly significant effects. [Confirm Anthropic no-train / retention terms.]
  6. Sharing (sub-processors). See our Sub-processor List. We do not sell your personal data.
  7. International transfers. Providers are in the US and elsewhere; we rely on EU/UK SCCs and/or EU-US DPF / UK Extension adequacy where certified, plus supplementary measures. Copies on request.
  8. Retention. Account: life of account + [30] days; chat/itineraries: [12 months] or until deletion; security logs: [30–90 days]; backups: [30-day] rotation; analytics: [14 months].
  9. Your rights. Access, rectify, erase, restrict, object, portability, withdraw consent. Exercise via [PRIVACY EMAIL] or in-app (Export data / Delete my account, and the consent toggles in your account panel). We respond within one month.
  10. Complaints. UK: ICO (ico.org.uk); EU: your local DPA (edpb.europa.eu).
  11. Security. Encryption in transit and at rest, access controls, encrypted backups, and data minimization (including anonymized IPs in logs).
  12. Children. Not intended for anyone under [16 / 18]; we do not knowingly collect children's data.
  13. California (CCPA/CPRA). [If in scope: categories collected / disclosed; rights to know / delete / correct; opt out of "sharing"; "Do Not Sell or Share My Personal Information"; sensitive-PI limits; no discrimination.] We honor Global Privacy Control (GPC) browser signals as an opt-out of analytics.
  14. Changes. Posted here; we notify you of material changes.