- The personal information we store is your Romer username and Facebook ID associated with your account along with email address if provided
- Each time you see friends on a card our app makes a 'call' to Facebook to pull that data to display it that moment
- We hold the information on how often each card is swiped and actions around the card that way we know which cards shouldn't be in Romer and offer our users the greatest customer experience from the minute they first open the app
- Once content is uploaded you are consenting other users to see and use the information and licence the rights to Romer Limited for the content
- When we disclose any information to associated businesses we do not use names or personal information instead we only use the information around common user habits and place data.
WELCOME TO ROMER ("ROMER," "WE," "US" OR “OUR"). ROMER MAKES FINDING THINGS TO DO AN ADVENTURE IN ITSELF.
- Our Policy applies to all visitors, users, and others who access Romer app, Website or any of our social media platforms.
1. Collection of Personal Information
1.1 Romer Collects Personal Information about customers, prospective customers who are reasonably necessary for, or directly related to, one or more its functions or activities. We Collect your Information in several ways, including but not limited to:
(a) the registration process in our app or website
(b) other instances in which you provide Personal Information or user content
(c) over the phone or email
1.2 The Personal Information that we Collect includes (but is not necessarily limited to): your first name, your last name and your email address provided directly or through a third party platform including Facebook. This information allows us to help you or others be "found" and upload and share “user content” on Romer.
- User Content (e.g., photos, titles, location and other materials) that you post to the Service.
- Communications between you and Romer. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails.
1.3 We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including your activity in Romer app, web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
2. HOW WE USE YOUR INFORMATION AND WHEN WE MAY DISCLOSE IT
2.1 Romer holds Personal Information which it has Collected to Use and Disclose for its Primary Purposes, including but not limited to:
(a) promoting advertising to you;
(b) answering your inquiry;
(c) sending you additional materials relating to Romer and products and services that may be of interest to you; and
(d) providing you with effective customer service.
(e) delivering the products and services you purchased or requested (please note that this may include providing your Personal Information to third parties to enable the delivery of products and services which you purchased or requested or events you may have purchased tickets for).
2.2 Businesses - Romer also holds Personal Information which it Uses and/or Discloses for purposes other than its Primary Purposes (Secondary Purposes). You provide your consent to us Using and/or Disclosing your Personal Information for the following Secondary Purposes:
(a) billing and account management;
(b) business planning and product development;
(c) enabling us to better understand your needs and interests;
(d) improving the content, functionality and usability of our Website;
(e) improving our marketing and promotional efforts;
(f) for any other purpose identified in any other agreement between Romer and you;
(g) issues, news or other information relevant to your dealings with Romer, or about Romer generally, or the industries in which you or Romer operates; and
(a) the Secondary Purpose is related to a Primary Purpose; and
(b) you would have a Reasonable Expectation that we would Use the information for that Secondary Purpose.
2.4 From time to time we may Disclose your Personal Information to organisations outside of Romer to deliver the services you require. Your Personal Information is Disclosed to these organisations only about us providing our services to you. These organisations carry out, amongst other services, our:
(a) billing and debt- recovery functions;
(b) customer inquiries;
(c) information technology services;
(d) marketing services (including market research);
(e) website usage analysis; and
2.5 Direct Marketing
(i) you have provided consent to do so; or
(ii) it is within your Reasonable Expectations; or
(iii) where it is impracticable to obtain your consent;
(b) that has been Collected from any third party in circumstances where:
(i) you have provided consent to do so; or
(ii) it is impracticable to obtain your consent.
2.6 In each Direct Marketing communication, we will include a:
(a) prominent statement appearing on the relevant piece of marketing material notifying you of your right to Opt Out from further Direct Marketing; and
(b) simple means for you to Opt Out of receiving further Direct Marketing communications of that kind.
2.7 Should you Opt Out; we will stop Using and/or Disclosing your Personal Information for Direct Marketing purposes.
3. We will not rent or sell your information to third parties outside Romer (or the group of companies of which Romer is a part) without your consent, except as noted in this Policy as defined by the Privacy Act 1993.
4. Parties with whom we may share your information:
4.1. We may share User Content and your information (including but not limited to, information from app activity supplied by third party analytics, cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Romer is part of, or that become part of that group ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences). But these Affiliates will honour the choices you make about who can see your analytics.
- We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
- We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.
4.2. Parties with whom you may choose to share your User Content:
- Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set. Once you have shared User Content or made it public, that User Content may be reused by others. You can delete your content at anytime.
- If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the Romer API have copied or saved that information.
4.3. Responding to legal requests and preventing harm:
- We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
4.4 Where you use a credit card to purchase an offer from Romer app of which you are not the card-holder and named on the card, you unconditionally acknowledge that you have been duly authorised by the card-holder to make purchases on Romer or in general, and that, in the event of a claim from the credit-card holder (that this was an unauthorised transaction) - you indemnify Romer for any claim (including legal action, fees or charge-back) that Romer may face as a result of this unauthorised purchase.
5. HOW WE PROTECT YOUR INFORMATION
5.1 Romer will take all responsible steps to protect the Personal Information from misuse, interference, loss and unauthorised access or disclosure. This may include taking reasonable steps to destroy or permanently de-identify Personal Information once it is no longer needed for any purpose for which it may be Used or Disclosed
5.2 Romer will not attempt to match de-identified or anonymous data Collected through surveys or such online devices as "cookies," with information identifying an individual, without the consent of the relevant individual.
5.4 Romer will take reasonable steps to ensure that Personal Information is only accessible by people who have a genuine "need to know" as well as "right to know.”
6. HOW YOU CAN ACCESS OR CORRECT YOUR INFORMATION
6.1 Your account information and profile/privacy settings:
- Update your account at any time by logging in and changing your profile settings.
- Unsubscribe from email communications from us by clicking on the "unsubscribe link" provided in such communications. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).
- Deleting your account through Facebook by unlinking Romer will remove personal information from Romer Limited
6.2 User Content:
Following termination or deactivation of your account, Romer, its Affiliates, or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes. Any information sent into Romer with regards to ideas, marketing, contacts or content is then official property of Romer Limited.
The GDPR includes the following rights for individuals:The right to be informed;
The right of access;
The right to rectification;
The right to erasure;
The right to restrict processing;
The right to data portability;
The right to object; and
The right not to be subject to automated decision-making including profiling.
To delete, seek, record or manage your personal data you can contact us anytime and our team will manage your request.
7. TRANSFERRING INFORMATION OVERSEAS
7.1 If we send Personal Information overseas, Romer will take steps which are both reasonable and practicable to ensure that the overseas recipient handles such information in accordance with the Privacy Act.
7.2 Romer may disclose Personal Information to an overseas recipient if:
(a) you are Expressly Informed of the intended disclosure of your Personal Information to the overseas recipient, and you provide consent accordingly; or
(b) we reasonably believe that the overseas recipient is subject to a law or a binding scheme that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the Privacy Act seeks to protect same and you can access mechanisms to enforce the protection of your Personal Information under that law or that scheme; or
(c) the Disclosure is required or authorised under New Zealand law.
8. WHAT HAPPENS IN THE EVENT OF A CHANGE OF CONTROL
9. CHILDREN'S PRIVACY
Romer does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us. COPPA law.
10. PUSH NOTIFICATIONS
If you are using our mobile application, and you accept that Romer can send you "Push Notifications", you agree to receive notifications from Romer even if your Romer mobile application is not running. "Push Notification" preferences can be configured in the application's settings.
12. CONTACTING ROMER
"Collect" means gather, acquire or obtain by a lawful and fair means, information in circumstances where the individual is identifiable or identified.
"Direct Marketing" involves the Use and/ or Disclosure of Personal Information to communicate directly with an individual to promote goods or services through written, verbal or electronic means of communication. The goods or services which are marketed may be those of Romer or a Related Body Corporate or those of an independent third party organisation.
"Disclosure" generally means the release of information outside Romer, including under a contract to carry out an "outsourced function."
"Express Consent Consequences" includes the fact that that we will not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act in the event that you provide consent to the disclosure of your Personal Information by us to an overseas recipient, and the overseas recipient handles your Personal information in breach of the Privacy Act.
"Expressly Informed" means the circumstance where we have provided you with a clear statement (either verbal or in writing) of the Express Consent Consequences.
"Opt Out" means an individual's expressed request not to receive further Direct Marketing communications.
"Personal Information" means information that is not Sensitive Information, including information or an opinion (whether information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion. This includes, but is not limited to, an individual’s name, address, telephone number and email address.
"Primary Purpose" is the main reason for the Collection of any Personal Information.
"Reasonable Expectation" means a reasonable individual's expectation that their personal information might be Used or Disclosed for the relevant purpose.
"Related Body Corporate" is given its meaning in the Corporations Act 2001 (Cth).
"Secondary Purpose" means a purpose of Use or Disclosure other than a Primary Purpose.
"Sensitive Information" is given its meaning in section 6(1) of the Privacy Act 1988 (Cth).
“Use" “We” “are” means the handling of Personal Information within Romer.
"Website" means the website of Romer and related social media webpages.