Last updated: ***
Roamah Ltd (“Roamah”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains how we collect, use, store and protect personal information when you use the Roamah website, platform and services, including when you submit an enquiry to a travel agent through our platform.
Please read this Privacy Policy carefully so that you understand how we use your personal information and the rights you have in relation to it.
Roamah Ltd is a company incorporated in England and Wales.
Company number: ***
Registered office: ***
Email: ***
For the purposes of applicable UK data protection legislation, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, Roamah is responsible for the processing of personal information described in this Privacy Policy.
Where you submit an enquiry to an individual travel agent through Roamah, both Roamah and the relevant travel agent may process your personal information for their respective purposes. The travel agent may provide you with additional privacy information regarding their own processing of your information.
We may collect personal information that you provide to us when you use Roamah.
This may include:
Depending on the information requested by the relevant travel agent, this may include:
If you create an account with Roamah, we may collect information such as your name, email address, login details and account preferences.
When you use our website, we may automatically collect certain technical information, including:
We may collect this information using cookies and similar technologies. Further information is provided in our Cookie Policy.
We may collect information:
When you submit an enquiry through Roamah, your information is collected by Roamah and stored within our systems.
We use the information you provide to process your enquiry and connect you with the travel agent or agents you have selected or who are relevant to your requirements.
The information provided to the travel agent may include the personal and holiday information contained within your enquiry.
This allows the travel agent to understand your requirements and contact you regarding your holiday.
Importantly, submitting an enquiry means that your information is stored by Roamah even after the enquiry has been passed to the relevant travel agent.
We retain this information in accordance with our data retention policies and may use it for the purposes described in this Privacy Policy.
We may use your personal information for the following purposes:
We may use your information to:
We may analyse information about how customers use Roamah to understand:
Where appropriate, we may use aggregated or anonymised information for these purposes so that individuals cannot reasonably be identified.
Roamah may wish to use information collected through the platform to provide you with relevant marketing, promotional content, travel inspiration, offers and information about products and services that we believe may be of interest to you.
This may include:
Where applicable law requires your consent, we will only send electronic direct marketing communications to you where you have provided the necessary consent or where another lawful exception applies.
Where we ask for marketing consent, this will be presented separately from acceptance of this Privacy Policy and will require a clear affirmative action.
For example, you may be presented with an optional marketing checkbox when submitting an enquiry.
You do not have to agree to receive marketing in order to submit an enquiry or use Roamah.
You can withdraw your marketing consent at any time by using the unsubscribe link included in our marketing communications or by contacting us.
The withdrawal of consent will not affect the lawfulness of processing carried out before your consent was withdrawn.
We will maintain appropriate records of marketing preferences and consent so that we can respect your choices.
The rules governing electronic marketing, including email and SMS marketing, are set out in part by the Privacy and Electronic Communications Regulations (“PECR”).
Where you have provided the appropriate permission, we may use information you have provided to help us understand your travel interests and provide more relevant marketing.
For example, if you tell us that you are interested in luxury holidays, safari holidays, cruises or honeymoons, we may use that information to send you relevant travel content and offers.
We may also analyse your interactions with our communications, such as whether you open or interact with emails, where permitted by applicable law.
We will not use special category personal data for direct marketing unless we have an appropriate lawful basis and, where required, explicit consent.
Roamah’s core purpose is to connect customers with travel agents.
When you submit an enquiry, we may share the relevant information you provide with the travel agent to whom the enquiry is directed.
The information shared may include your name, contact details and information about the holiday you are looking for.
The travel agent will use this information to respond to your enquiry and, where appropriate, provide holiday recommendations and arrange travel services for you.
The travel agent may have its own privacy policy explaining how it processes your information.
We encourage you to review the relevant agent’s privacy information before providing additional personal information directly to them.
We may share personal information with carefully selected third parties where necessary to operate Roamah or provide our services.
These may include:
We require relevant service providers to handle personal information appropriately and to comply with applicable data protection requirements.
We do not sell your personal information as a general data-broker service.
Where you have specifically consented to receive relevant marketing, Roamah may use your information to provide or facilitate travel-related promotional communications.
Where third-party businesses are involved in marketing, we will ensure that the relevant privacy information and consent arrangements are appropriately communicated.
We will not assume that a general acceptance of this Privacy Policy constitutes consent to receive third-party marketing.
Where specific consent is required, we will obtain it separately and clearly identify the relevant purpose and parties.
Under UK data protection law, we need a lawful basis for processing personal information.
Depending on the circumstances, we may rely on one or more of the following:
We may process information where it is necessary to provide a service you have requested or take steps at your request before providing that service.
We may process information where it is necessary for our legitimate interests, provided that those interests are not overridden by your rights and interests.
Examples may include operating, maintaining and improving Roamah, preventing fraud, maintaining security and managing our business.
Where required, we may rely on your consent, particularly for certain direct marketing activities and certain cookies or similar technologies.
Where we rely on consent, you can withdraw that consent at any time.
We may process information where necessary to comply with a legal or regulatory obligation.
We will retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including for the purposes of meeting legal, accounting or reporting requirements.
The length of time we retain information will depend on:
We will periodically review the information we hold and securely delete or anonymise information that we no longer need.
Marketing data will not be retained indefinitely simply because marketing consent was previously provided.
Some of our technology and service providers may process personal information outside the United Kingdom.
Where personal information is transferred outside the UK, we will take appropriate steps to ensure that the transfer is lawful and that your information receives an appropriate level of protection.
This may include relying on an adequacy decision, appropriate safeguards such as the UK’s International Data Transfer Agreement or Addendum, or another lawful transfer mechanism.
We take reasonable technical and organisational measures designed to protect personal information against:
These measures may include access controls, authentication, secure hosting, encryption where appropriate, monitoring and appropriate contractual protections with service providers.
However, no internet transmission or electronic storage system can be guaranteed to be completely secure.
Depending on the circumstances, you have rights under UK data protection law, including:
You can ask for a copy of the personal information we hold about you.
You can ask us to correct inaccurate or incomplete information.
In certain circumstances, you can ask us to delete your personal information.
In certain circumstances, you can ask us to restrict how we use your information.
In certain circumstances, you may have the right to receive personal information you have provided to us in a structured, commonly used and machine-readable format.
You may have the right to object to certain processing of your personal information.
You have an absolute right to object to the processing of your personal information for direct marketing purposes.
If you object to direct marketing, we will stop using your information for that purpose.
Where we rely on consent, you can withdraw your consent at any time.
To exercise any of your rights, please contact us using:
Email: ***
We may need to verify your identity before completing your request.
We will generally respond to valid requests within one month, although this may be extended where permitted by applicable law if a request is particularly complex or numerous.
We will not normally charge you for exercising your data protection rights.
Roamah uses cookies and similar technologies to operate the website, understand how visitors use our platform and, where permitted, support marketing and analytics activities.
Some cookies are necessary for the operation of the website, while others may require your consent.
Our Cookie Policy provides further information about the cookies and similar technologies we use and how you can manage your preferences.
Roamah is intended for adults and is not directed at children.
We do not knowingly collect personal information from children where doing so would be unlawful.
If you believe that a child has provided personal information to us, please contact us so that we can investigate and take appropriate action.
Roamah may contain links to third-party websites, including travel providers, travel agents and other services.
We are not responsible for the privacy practices, content or security of third-party websites.
We recommend reviewing the privacy policy of any third-party website you visit.
We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal requirements or how we process personal information.
When we make material changes, we may provide additional notice where appropriate.
The latest version will always be made available on the Roamah website with the date it was last updated.
If you have concerns about how we use your personal information, please contact us first so that we have an opportunity to resolve the issue.
You also have the right to complain to the UK’s data protection regulator:
Information Commissioner’s Office (ICO)
Website: https://ico.org.uk/
The ICO regulates data protection and privacy law in the UK.
If you have any questions about this Privacy Policy or how Roamah handles your personal information, please contact:
Roamah Ltd
Company number: ***
Registered office: ***
Email: ***
Last updated: ***