­­­Privacy Policy

Point Dume Limited and its subsidiaries (“Point Dume,” “we,” “us,” and “our”) is concerned about privacy and security information of our customers. We are doing our best to make your experience with our RoamVU ® roaming application and other Point Dume services as enjoyable and rewarding as possible, while at the same time making sure that your privacy interests are being respected. This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing or using our RoamVU application, website or Services. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. By visiting or using RoamVU application,  the Website or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways. Any capitalized terms used herein without definition shall have the meaning given to them in Point Dume’s Terms Of Use (which is hereby incorporated into this Privacy Policy).

Collection of Information

Required Information

Point Dume collects certain information that is necessary to fully service your Point Dume and RoamVU account. As a customer, you could be asked to provide Information that is needed in order to create your Point Dume or RoamVU account, to provision appropriate user credentials and fulfill our service commitment to you, such as: your name, phone number, e-mail address and if applicable billing information. This information may be collected via account opening form or social media or federated login function (e.g. Facebook signup or Google and Microsoft login). Point Dume may use this Information internally for editorial and feedback purposes, marketing and promotional communications between Point Dume and customer, for statistical analysis and product development.

Geographic Location Information

When you use Point Dume’s RoamVU application or any other services on a mobile device (such as your smartphone, tablet or notebook computer), Point Dume may collect and track certain information that is derived from your usage of the Point Dume’s service, such as service activation and usage patterns as well as information about your geographic location. Point Dume uses this information to offer offline maps function and to assist you in finding suitable connectivity areas, dynamically manage our network connectivity platforms, improving overall service performance and RoamVU user experience. Such information is further used for statistical or business-related purposes and for designing improvements to our products and services. Individual geolocation information of identifiable end-user is never disclosed to any third parties, including end-user employers, unless requested in the course of legal and lawful investigation or by government and law enforcement authorities.

Optional Information

In order to continuously improve quality of our Services and user experience, Point Dume may gather demographic information about our customers. Demographic information seeks to gain insight on such things as how an individual became aware of our service, their gender, age group, occupation and travel preferences and practices. In addition, customer comments and inquiries are collected and stored for each customer that submits them. This information is collected and stored as a profile with the customer’s individual Point Dume account information. We may from time to time share aggregated demographic information with various business partners, however doing so in a completely anonymous way and removing all biographic data of the users such as first or last name, residential address, phone numbers etc.

From time to time Point Dume may offer incentive programs to RoamVU customers, visitors to the Web site (www.RoamVU.com), the general public and individuals identified through direct mail lists. These offerings are promoted on the Web site, advertisements and press releases. At a minimum, required information includes name and e-mail address; in some cases, the customer must answer mandatory survey questions about other personal data or enter a program code. The information gathered in the entry form is used to verify the entrant’s identity, to send the entrant an e-mail notification that their entry has been received, and to contact winners and/or prize recipients. Because the rules and terms of each program can vary, all information about each program is clearly posted during the event. All such programs are conducted in full accordance with United States federal and state laws.

When Point Dume collects usage information (such as the numbers and frequency of visitors to the Website), we generally use this data in aggregate form. As between you and Point Dume, you own the information that you provide to Point Dume under this Agreement, and may request its deletion at any time. Additionally, you grant Point Dume a nonexclusive, irrevocable worldwide, perpetual, assignable, sublicensable, fully paid up and royalty-free right to copy, prepare derivative works of, improve, distribute, publish, remove, retain, add, process, analyze, use and commercialize, in any way now known or in the future discovered, any information you provide, directly or indirectly to Point Dume, including but not limited to, any user generated content, ideas, concepts, techniques and/or data that you submit to Point Dume, without any further consent, notice and/or compensation to you or to any third parties.

 

 

 

Cookies, Web Beacons and Media Access Controller Tracking

We and our Service Providers use cookies and other technologies (such as web beacons) for various reasons. For example, we use cookies and other technologies to make it easy to access our services by remembering you when you return, to provide and analyze our services, to learn more about our users and their likely interests, and to deliver and tailor marketing or advertising. We want you to be informed about our use of these technologies, so this notice explains the types of technologies we use, what they do and your choices regarding their use.

  1. What are cookies?

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. They are widely used to make websites work, or to work more efficiently, as well as to provide reporting information and assist with service or advertising personalization.

Cookies are not the only types of technology that enable this functionality; we also use other, similar types of technologies. See below for more information and examples.

  1. Why does Point Dume use cookies?

We and our Service Providers may use the following types of cookies:

    • Essential cookies: These cookies are strictly necessary to provide our website or application service. For example, we or our Service Providers may use these cookies to authenticate and identify our customers when they use our websites and applications so we can provide our service to them. They also help us to enforce our Terms of Use, prevent fraud and maintain the security of our service.
    • Performance and functionality cookies: These cookies are not essential, but help us to personalize and enhance your experience with RoamVU applications and other Point Dume services. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during member sign up). We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our customers and visitors’ use of the Point Dume services so that we can enhance and personalize our application, website and service and conduct market research.
    • Advertising cookies: These cookies use information about your visit to this and other websites, such as the pages you visit, your use of our service or your response to ads and emails, to deliver ads that are more relevant to you.

At this time neither RoamVU application nor our website use advertising cookie.

 

  1. How Does Point Dume use Web Beacons and other Technologies?

Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. Point Dume may use web beacons in the following ways:

  • Within RoamVU and our Web sites in order to track customers signing up at one of our hotspot locations.
  • Within RoamVU and our Web sites in order to fulfill sponsored access campaigns or other promotions.
  • To measure where customers leave the signup process in order to improve customer experience.
  • To track customers that come through our Web sites from advertisements or search engines.

Because web beacons often work in conjunction with cookies, in many cases, declining cookies will impair the effectiveness of web beacons.

IF YOU DO NOT WISH TO HAVE WEB COOKIES PLACED ON YOUR COMPUTER, YOU SHOULD SET YOUR BROWSER TO REFUSE WEB COOKIES, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE SITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. IF YOU REFUSE WEB COOKIES, YOU ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

We do not control the use of our partners’ cookies or do not track policies and expressly disclaim responsibility for information collected or tracked through them.

Point Dume  also records the MAC (Media Access Controller) address, IDFA, ADID and device identifier numbers from the network card in or used with your computer or other device to enable Point Dume  to accurately perform our billing functions and in the ordinary course of business. Such information is only used internally and is not disclosed to third parties.

 

 

Information Collected from Other Websites and Do Not Track Policy

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your user experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Point Dume does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

Use and Disclosure of Information

Except as described in this Section, Point Dume  will not divulge any of your personal information, contact, financial, bill history, or geographic location to any other organization unless (1) you give Point Dume  explicit and specific, prior permission (for example, if you opt-in to a sponsorship offer from one of our partners), (2) the disclosure is required by law or by legal process authorized by a court of competent jurisdiction, (3) Point Dume  suspects fraud by a customer involving Point Dume service, in which case Point Dume  may investigate and report any evidence, including personal information, to law enforcement officials and to the courts in the course of seeking remedies at law and equity, and/or (4) you make an inquiry, request or complaint that requires follow-up and we share your information with others to satisfy your inquiry.

Subject to the terms of this privacy policy, we may disclose information to our employees or contractors who process information on our behalf, participate with us in the provision or operation of our service or provide you with services.

Subject to this Privacy Policy, we may use your information also in connection with our partners in the aggregate but anonymous form to analyze quality of service, as well as international travel patterns, activities and behavior.

Point Dume may choose to buy or sell assets or companies, or merge with or into other companies. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if Point Dume (or its assets) are acquired, or if Point Dume  goes out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

We may email you about products and services that we believe may be of interest to you.  If you wish to opt-out of receiving marketing materials from us, please follow the instructions at the bottom of each email for opting out. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes.

In instances where Point Dume and a partner jointly promote the Point Dume  service, Point Dume  may provide that partner anonymously certain information, such as gender, age, country and city of residence, travel activity and usage patterns for the sole purpose of allowing Point Dume and the partner to evaluate promotions. Such data will be stripped of identifiable biographic and other user data, such as name, email address, phone number etc. unless customer expresses consent for use and sharing of such data in the course of advertising or promotional campaign.

Point Dume may contact customers or Web site visitors regarding account status and changes to this privacy policy and any other policies or agreements relevant to Web site visitors. Point Dume may use your information to disclose summary information to strategic and business partners. This is done by combining data from many individuals with the name and other identifiers removed. Point Dume also may create aggregate reports on user demographics and traffic patterns. This information may be used to negotiate with service providers who complement the Point Dume service.

When applicable and whenever your Point Dume service plan allows it, we may give advertisers and/or merchant partners (“Advertisers”) options to choose the demographic information of users who will see their advertisements and/or promotional offers and you agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are or how to contact you.

Advertisers may serve ads that appear on our sites or services, which may contain a feature allowing you to input your email address. If you choose to input your email address in connection with these ads, you understand that we will transmit your email address to the applicable third party advertiser; this Privacy Policy does not apply to such advertisers’ collection and use practices, so please review their privacy policies before providing your email address in this manner.

 

Correcting and Updating Your Information

As a Point Dume customer or RoamVU user, you are in full control of the information that we maintain to serve you. You can request that the data be changed or deleted by emailing it to: legal@point-dume.com Please provide your account information and the nature of your request (amend or delete). Please note that requests for deletion of certain information may require termination of service and closing of the account.

Information about a customer may be withheld or exempted from deletion if this is required by law, is part of a fraud investigation or is required for accounting and audit purposes.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: legal@point-dume.com

Opt-out Policy

If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Services.

Point Dume automatically opts customers in to providing Point Dume with information, as well as a separate opportunity to opt-in to certain location-tracking services, or receiving communications from us and our partners.

At any time, customers can contact Point Dume to opt-out of any of our promotions, programs, location-tracking services or contests by emailing it to: legal@point-dume.com

Commitment to the Privacy of Your Family

We do not knowingly collect information from children under the age of 13. If we determine that we have collected personally identifiable information on children, we will promptly delete it from our system. We recommend that children who are 13-17 years old receive permission from a parent before gaining access to RoamVU application or the Point Dume service or sending information to Point Dume  or anyone else online. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to us or on the Services. In the event that we learn that we have collected personal information from a child under age 13 without verification of 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 email: legal@point-dume.com

 

 

 

Security Measures

Your account information is protected by a unique User Identification and password that is issued to you. Your User Identification and password should be kept confidential because it is the key to accessing the information held by Point Dume about you. If your computer or other mobile device is accessible by others, please log out of the Point Dume  site before you leave it. Security is also provided through your web browser, which supports 40, 56 or a 128-bit version of encryption with the SSL (Secure Sockets Layer) security protocol.

Point Dume  has instituted internal safeguards to reduce the likelihood of accidental disclosures and unintended access of your information (although it is impossible to eliminate this possibility completely). In general, all employees, contractors and other companies engaged by Point Dume are contractually required, through signed, internal non-disclosure agreements, to keep your Personal Information confidential and not to use it in any way other than what is necessary to perform their work for Point Dume . Violations of these policies can result in termination in the case of employees, the severing of contractual obligations in the case of contractors and other companies, and in civil and criminal penalties if warranted and applicable by law.

While Point Dume uses reasonable measures to protect the security of your information, no security measures are foolproof, and Point Dume does not guarantee that your information will remain confidential.

The Services may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

Security of Third Party Networks

Because of the global nature of our services, there are many place where you can access RoamVU and Point Dume Partner Networks. In these places, you may (1) manually search for available networks marked with “RoamVU hotspot” or identified otherwise and, if required to do so, assent to Terms of Service or other click-through agreements; or (2) connect to such wireless networks automatically by using RoamVU application profile certificated enabled on your device.

We do not control the third-party sites that may be accessible through this Site or Point Dume ’s services. Thus, this privacy policy does not apply to information provided to third-party sites or gathered by the third parties that operate them. Before visiting a third-party site, whether by means of RoamVU application or manually searching for an available third party network or otherwise, and before providing any information to any third party, you should inform yourself of the privacy policies and practices (if any) of the third party, and should take those steps necessary to your discretion, to protect your privacy.

 

Affiliated Businesses and Third-Party Websites

In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

Privacy Policy Changes

Point Dume reserves the right, in its sole discretion, to revise, amend, or modify this privacy policy at any time, and in any manner without notice. You shall be responsible for reviewing and becoming familiar with any such modifications. Your use of the Services following such notification constitutes your acceptance of the terms and conditions of this privacy policy as modified.

 

Additional Information

This privacy policy is effective as of November 15th, 2017. Point Dume reserves the right to change this policy at any time. By using the RoamVU application and Point Dume  service, you are acknowledging and accepting all terms and conditions outlined in this privacy policy.

If you have any questions regarding this policy statement, please e-mail legal@point-dume.com

This privacy and security pledge is part of our contract with you. Thank you for choosing RoamVU and Point Dume Limited!