1.1 We collect personal information in the following ways:

• Account Registration: When you create an account, we collect your name, email address, and other contact details. This information is required to process your purchases and manage your account.
• Order and Payment Details: When you purchase an eSIM, we collect billing and payment information, such as your name, address, and transaction data. Payments are processed through third-party providers (e.g., RevolutPay, Mastercard, Visa, PayPal, Apple Pay, Android Pay).
• Usage Data and Analytics: We use cookies and other tracking technologies (such as Google Analytics and Facebook Pixel) to collect information about your device, browser, IP address, and your interaction with our website.
• Marketing and Communication Preferences: We may collect your preferences and feedback when you subscribe to receive marketing messages or contact our support team.

1.2 We do not collect biometric data, identity documents, or conduct eKYC processes.

2.1 We use your information to:

• Provide and manage our eSIM services
• Process your orders and manage your account
• Improve our website and customer experience
• Send transactional and marketing emails (you can opt out at any time)
• Analyse website usage and measure the effectiveness of advertising
• Comply with legal and regulatory obligations
• Detect and prevent fraud or misuse of our Services

3.1 We may use your contact information to send you updates, offers, and promotions. You can opt out at any time by contacting us at  hello@rivaroroaming.com  or using the unsubscribe link in our emails.

4.1 We may share your personal data with:

• Third-party service providers for website hosting, email delivery, analytics, marketing, and payment processing
• Advertising partners (e.g., Facebook) to deliver targeted ads
• Authorities or regulators where required by law
• Other third parties when you have given consent or requested us to share your data

4.2 We do not sell your personal information for monetary value.

5.1 We use cookies and pixels to collect analytics and support advertising activities. You will be given the option to consent to non-essential cookies when visiting our website. For more information, please refer to our Cookie Policy.

6.1 We retain your personal information only as long as necessary for the purposes outlined above. For fraud detection and anti-money laundering compliance, we may retain certain data for up to six (6) months even after your account is deleted or your transactions are completed. We may also retain your personal data if required to do so by law.

7.1 As we use cloud-based tools and third-party services, your information may be transferred outside the UK or European Economic Area (EEA). We take steps to ensure such transfers comply with data protection laws, including the use of appropriate safeguards.

8.1 Under the UK GDPR, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your personal data
• Object to or restrict processing
• Withdraw consent at any time
• Lodge a complaint with the Information Commissioner's Office (ICO) You may exercise your rights by contacting  hello@rivaroroaming.com.

9.1 Our services are not directed at children under 13. We do not knowingly collect personal information from children under this age.

10.1 We may update this Privacy Policy from time to time. Updates will be posted on our website, and where appropriate, notified to you via email.

11.1 If you have any questions about this Privacy Policy or your personal data, please contact us:

Rivaro Roaming Ltd

• Denny Lane, Newton Leys
• Milton Keynes, Buckinghamshire, MK3 5RL United Kingdom

Email:  hello@rivaroroaming.com
Phone: +44 333 577 6441

12.1 This section applies to California residents and is intended to supplement the main Privacy Policy in compliance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

12.2 Categories of Personal Information Collected:

• Identifiers such as your name, email, IP address, and account login details
• Commercial information such as transaction and purchase history
• Internet activity such as browsing behaviour and interaction with our website

12.3 Purpose of Collection:

This information is collected for the purposes described in Section 2, including service provision, customer support, marketing, and analytics.

12.4 Sharing of Information:

We may share your data with:

• Advertising and analytics partners (e.g., Facebook, Google)
• Service providers that support our business operations
• Regulators or authorities where legally required

We do not sell your data for monetary value, but we may share personal data for advertising purposes that could be considered "selling" or "sharing" under California law.

12.5 Your Rights (California Residents):

You have the right to:

• Request access to the categories and specific pieces of personal information we hold about you
• Request deletion of your personal information
• Opt-out of the sale or sharing of your personal information
• Correct inaccurate personal data
• Limit the use of sensitive personal information (if collected) To exercise any of these rights, email us at hello@rivaroroaming.com. We may need to verify your identity before processing your request.
  If you appoint an authorised agent to submit a request on your behalf, we may require written permission and identity verification.