Effective February 1, 2012
BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR BY USING OUR SITE, YOU AGREE
THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE
Your privacy matters to Roamba, Inc. so please take the time to get to know our
practices and if you have any questions contact us. This
Information (defined below) collected from users of our services (“you”) on our
Site (defined below), whether through in person, telephone, e-mail or written
communications, including interviews, surveys, contests, promotions, raffles or
Your California Privacy Rights
Under California Law, California residents have the right to request in writing
from businesses with whom they have an established business relationship, (a) a
list of the categories of personal information, such as name, e-mail and mailing
address and the type of services provided to the customer, that a business has
disclosed to third parties (including affiliates that are separate legal
entities) during the immediately preceding calendar year for the third parties’
direct marketing purposes and (b) the names and addresses of all such third
parties. To request the above information, please send us correspondence
including a reference to California Disclosure Information via e-mail at:
privacy@Roamba.com or write to us at:
Attn: Customer Service – Privacy
PO Box 25214
Anaheim, CA 92825-5214
We will respond to such requests for information access within 30 days following
receipt at the e-mail or mailing address stated above. If we receive your
request at a different e-mail or mailing address, we will respond within a
reasonable period of time, but not to exceed 150 days from the date we actually
receive the correspondence. Please note that we are only required to respond to
each customer once per calendar year.
The remainder of this policy describes our Personal Information handling
practices in detail.
“Guest” means an individual who searches and Books Products or Services on our
Site without being a Member.
“Member” means an individual who has registered on the Roamba.com site.
“Member ID” means the e-mail address Members use (with their password) to log
into our Site.
“Roamba,” “us,” “our” or “we” means Roamba, Inc. and its subsidiaries and
“Personal Information” means any information, recorded in any form, about an
identified individual, or an individual whose identity may be inferred from the
information. This includes, for example, name, e-mail and mailing address,
telephone number, billing and account information and other information
incidental to providing Products or Services (including information about
individuals traveling with an individual who Books on our Site).
“Products or Services” means the rental accommodations and other related items
and services available through the Site.
To “Book” means to reserve.
“Session Data” means usage information, such as the type of Internet browser and
operating system an individual uses, the domain name of the site from which the
individual came, the date, time and duration of the individual’s visit, the
number of visits to our Site, the pages viewed and the number of cookies
accumulated, and, in the case of the Roamba mobile site and application, if
applicable, also means the unique identifier of an individual’s mobile device,
the type of mobile device the individual uses and the application version.
“Site” means the Roamba.com Web site, the m.Roamba.com mobile website, if
applicable, or the Roamba mobile applications, if applicable, and their
respective sub websites together with the respective content, Products and
Services available from these websites/applications or sub websites.
AS STATED ABOVE, BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR BY USING OUR
SITE, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION
If you do not agree with these terms, do not provide any Personal Information to
us. If you refuse or withdraw your consent, or if you choose not to provide us
with any required Personal Information, we may not be able to provide you
Products or Services.
Minors are not eligible to register for, use or Book the Products or Services.
means any person under the age of eighteen (18) years who is required to attend
school under the provisions of the California Education Code, and includes
minors under age six. Non-California residents who would be subject to
California’s compulsory education laws if they were residents of such state are
also considered minors. If you do not qualify, leave the Site immediately.
We do not knowingly collect Personal Information from any Minor, and will
not use this information if we discover such information was provided by a
Other Travelers or Contacts
If you Book Products or Services for other travelers using your Member ID and
password, you must make sure that you have the right to do so. By providing the
Personal Information of another traveler or third party, you represent that you
have all necessary authority and/or have obtained all necessary consents from
such person to enable us to collect, use and disclose his or her Personal
What Personal Information We Collect
We collect only such Personal Information as necessary to provide Products and
Services to you.
We collect Personal Information in two ways:
Information you give us. For example, many of
our services require you to sign up for a Roamba Account. When you do, we’ll ask
for personal information, including but not limited to, your name, email
address, telephone number or credit card.
Information we get from your use of our services. We may collect
information about the services that you use and how you use them, like when you
visit a website that uses our advertising services or you view and interact with
our ads and content. This information includes:
We may collect device-specific information (such as your hardware model,
operating system version, unique device identifiers, and mobile network
information including phone number). Roamba may associate your device
identifiers or phone number with your Roamba Account.
When you use our services or view content provided by Roamba, we may
automatically collect and store certain information in server logs. This may
include: details of how you used our service, such as your search queries.
telephony log information like your phone number, calling-party number,
forwarding numbers, time and date of calls, duration of calls, SMS routing
information and types of calls, internet protocol address, device event
information such as crashes, system activity, hardware settings, browser type,
browser language, the date and time of your request and referral URL cookies
that may uniquely identify your browser or your Roamba Account.
When you use a location-enabled Roamba service, we may collect and process
information about your actual location, like GPS signals sent by a mobile
device. We may also use various technologies to determine location, such as
sensor data from your device that may, for example, provide information on
nearby Wi-Fi access points and cell towers.
Unique application numbers
Certain services include a unique application number. This number and
information about your installation (for example, the operating system type and
application version number) may be sent to Roamba when you install or uninstall
that service or when that service periodically contacts our servers, such as for
We may collect and store information (including personal information) locally on
your device using mechanisms such as browser web storage (including HTML 5) and
application data caches.
Cookies and anonymous identifiers
We use various technologies to collect and store information when you visit a
Roamba site or service, and this may include sending one or more cookies or
identifiers when you interact with services we offer to our partners, such as
advertising services or Roamba features that may appear on other sites.
When you are just visiting
You can visit certain areas of our Site without revealing who you are or logging
into our Site. When you visit our Site as a Guest or Member,
we collect Session Data through cookies and pixel tags.
When using the Roamba mobile site or applications, you may search for Products
and Services in the area in which you are located. If you
choose to do so, depending on the mobile device or application you are using, we
may collect your geo-location information to search for the applicable Products
and Services or to personalize and improve your individual viewing experiences
on our Site and provide information that may be of interest to you.
You may at any time disable our collection and use of your location
information by turning location services off at the device level.
When you register as a Member
When you register with us as a Member thereby creating a Roamba Account we
collect Personal Information that is necessary to provide Products and Services.
You must provide your name and e-mail address. You also must choose a password,
which will be required to gain access to portions of our Site reserved for
Member use. We might also request your home zip code.
You may elect to provide other information. Such information may include, for
example, gender, activities and lifestyle preferences or preferred destinations.
When you Book Products or Services as a Member
When you Book Products or Services as a Member, you must provide payment and
billing information and other information required by the Provider(s). Such
information may include, for example, date of birth, gender, driver information
or similar information.
If you choose to use our e-mail your reservation feature, we will send the
individual(s) you identify a one-time e-mail with the applicable information. We
do not permanently store the name or e-mail address of such individuals.
When you Book Products or Services for a third party
When you Book Products or Services for a third party using your Member ID and
password, you must provide that third party's name and contact information,
payment and billing information and other information required by the
When you Book Products or Services as a Guest
When you Book Products or Services as a Guest, you must provide Personal
Information required by the Provider(s). You must also provide an e-mail address
so that we can send you our welcome e-mail and a confirmation of the booking.
With the confirmation, we will provide you with a temporary password so that you
can return to our Site if you wish to review information about the booking.
When you participate in contests, promotions, raffles or sweepstakes
We may offer you the chance to win a variety of travel-related prizes by
sponsoring contests, promotions, raffles or sweepstakes. If you choose to
participate, we will collect Personal Information such as your name or e-mail or
If a third party administers the contest, your participation may be subject to
not responsible for such third parties. You should carefully review these third
parties’ terms and conditions.
When you participate in a survey or a focus group
From time to time, we may invite you to participate in a survey or a focus
group. You are free to participate or not. We will collect the responses you
provide, and will make them anonymous by aggregating them with those of other
participants. If you use a bulletin board, blog or chat room on our Site, you
should be aware that any Personal Information you submit there can be read,
collected or used by other users of these forums, and could be used to send you
unsolicited messages. We are not responsible for the Personal Information you
choose to submit in these forums. If you wish to request the removal of your
Personal Information from our blog, you can do so by contacting us as indicated
in Contact Information. In some cases, we may not be able to remove your
Personal Information, in which case we will let you know if we are unable to do
so and why.
When we advertise on third party sites
When you visit a site on which we advertise and click through our advertisement,
we may place cookies on your computer or use pixel tags. The information that we
collect through this technology is not personally identifiable.
When you call or write to our Customer Service
When you call or write to our Customer Service, we collect contact information,
including, for example, name, phone number, e-mail or mailing address, and
information about the relevant booking as necessary to assist you. For example,
if you call for assistance with a pre-existing booking or to Book Products or
Services, we may request your name, contact information and payment and billing
When we send e-mails or e-newsletters
When we send e-mails or e-newsletters, we may insert a pixel tag in the e-mail.
If you choose to use our forward to a friend feature, we will send your
friend(s) a one-time e-mail about the applicable information.
We do not permanently store the name or e-mail address of such individuals.
Supplementation of Personal Information
In order to provide certain services to you, we may on occasion supplement the
Personal Information you submitted to us with information from third party
Address Verification: If you Book Products or Services, we may use third parties
in order to verify your address information during the credit card authorization
Enhancement of Profile Information: We may obtain marketing data from third
parties and add it to our existing user database, to better target our
advertising and to provide pertinent offers for which we think you would be
interested. To enrich our profiles of individual customers,
we may tie this information to the Personal Information you submitted to us.
How We Use the Information We Collect
We use Personal Information in order to provide and enhance the Products or
Services offered: (1) to record your travel preferences or make reservations;
(2) to issue invoices, administer accounts, collect and process payments; (3) to
provide tips or guidance on how to use our Site, inform you of new features on
our Site or provide other information that may be of interest to users; (4) to
personalize the service we provide to you, tailor your experience at our Site to
your interests and make more appropriate destination recommendations; (5) to
send you e-mails, e-newsletters, personalized offers via direct messaging or
other communications about our services, if you have subscribed to receive this
information or you have not advised us that you do not wish to receive such
communications; (6) to manage our Site, diagnose technical problems, improve
content and allocate the resources of our systems so that your experience with
our Site is as efficient as possible; (7) to process and track your transactions
and to send you information about our and our affiliates’ and business partners’
products and services and other information and materials that may be of
interest to you; (8) to develop, enhance, market, sell or provide Roamba’
Products or Services, or those of companies with which we have a commercial
relationship, but only if you have granted us permission to do so or we are
otherwise able to do so under applicable law; (9) to evaluate credit standing
and to match credit bureau or credit reporting agency information; (10) to
investigate, detect and protect Roamba and other third parties against error,
negligence, breach of contract, fraud, theft and other illegal activities; (11)
to effect a corporate transaction in connection with the sale, merger, spin-off
or other corporate reorganization of our corporation, where the information is
provided to the new controlling entity in the regular course of business; (12)
to audit compliance with our policies and contractual obligations; (13) as
permitted by, and to comply with, any legal or regulatory requirements or
provisions; or (14) for any other purpose to which you consent.
Contests, Promotions, Raffles and Sweepstakes
If you participate in a contest, promotion, raffle or sweepstakes, we will only
use your Personal Information to notify you if you win.
We may send you additional communications only if you have specifically
requested to receive our e-mails, e-newsletters, personalized offers or other
promotional materials when filling out the contest or promotion form.
We will share the information you provide us with the entities with which we may
have teamed to propose a joint promotion.
We use Session Data, collected through cookies and pixel tags, to better
understand how our Site is navigated, how many visitors arrive at specific
pages, the length and frequency of stays at our Site, the variety of searches of
our Site’s database, the types of browsers and computer operating systems used
by our visitors and the Internet Protocol addresses from which visitors connect
to our Site.
We also use this information to improve our Site’s content and ease of use, to
personalize and improve your individual viewing experiences on our Site and
provide information that may be of interest to you.
We use pixel tags to monitor the open rate of our communications. This helps us
understand the effectiveness of communications we send. We do not use this
information for any other purpose.
Survey and Focus Groups
When you participate in surveys or focus groups, your participation and
responses will be kept confidential and will not be shared with third parties
without your permission, except with our service providers.
Aggregated information is information recorded in any form about more than one
individual, where the identity of the individual is not known and cannot be
inferred from the information. We may use aggregated information to describe our
user base to current or potential partners, investors and advertisers; after a
survey, to understand and respond to market needs and preferences; or to make
recommendations to other users of our Site. For example, if users of our Site
who have traveled to a particular destination told us that they had positive
experiences at a hotel in that destination, we might recommend that hotel.
What we do NOT do
We do not and will not, at any time, request your credit card information,
Member ID, password or national identification numbers in a non-secure or
unsolicited e-mail or telephone communication.
Identity theft and the practice currently known as “phishing” are of great
concern to us. Safeguarding information to help protect you from identity theft
is our priority. For more information about phishing, you may want to visit the
Federal Trade Commission at
To Whom We Disclose Personal Information
From time to time, we may disclose your Personal Information as follows:
To those Providers with which you make arrangements through our Site. We provide
them with the Personal Information needed to make and complete the booking or
To organizations that perform services for or on behalf of Roamba, for example
to provide customer service, deliver tickets, ship items, process credit cards,
for research, marketing, data processing, to measure the use of our Site, to
facilitate usage by a visitor or to offer credit card services or evaluate your
creditworthiness. We will share with these companies only that Personal
Information which they need to work on our behalf. Some of these service
providers may be located in countries outside the US and outside the European
Economic Area (“EEA”). Your Personal Information will be provided to these
organizations only if they agree to use such information solely for the purpose
of providing services to Roamba, and under the instructions of Roamba, and with
respect to that information, to act in a manner consistent with the relevant
principles articulated in this Policy. By submitting your personal data, you
agree to the transfer, storing and processing of your data outside the US and
outside the EEA;
We may collaborate with other companies to offer you additional Products or
Services, for example, through sweepstakes, raffles and promotions. We will
share Personal Information that is necessary for these other companies to
provide the Products or Services that you have requested. This policy does not
cover the use of your Personal Information by these other companies. We
products or services;
To protect our Site and our rights under our Terms and Conditions; to protect
ourselves against liability or prevent fraudulent activity; or where it is
necessary to permit us to pursue available remedies or limit any damages that we
To effect a corporate transaction, in connection with the sale, merger, spin-off
or other corporate reorganization of our corporation, where the information is
provided to the new controlling entity in regular course of business;
Where the information is public; or
To our insurers and to regulatory agencies.
Disclosure without Consent
Please note that there are circumstances where the use or disclosure of Personal
Information may be justified or permitted, or where Roamba may be obligated to
disclose information without consent. Such circumstances may include:
If required to comply with a subpoena or warrant issued or an order made by a
court, person or body with jurisdiction to compel the production of information
or to comply with the rules of a court relating to the production of records;
If we receive a formal request to disclose your Personal Information in
connection with a legal action, we will attempt to contact you about it, if
permitted by law, via the e-mail address you provided during registration,
before we respond to that request.
If we believe in good faith that a law, regulation, rule or guideline requires
To a person who needs the information because of an emergency that threatens the
life, health or securit of an identifiable person or group; or
Where it is necessary to collect monies owing to us.
In order to protect national security and to ensure travel security, the United
States Government and other governments may request access to passenger name
records, which typically includes name, flight origin, flight destination,
flight time, duration of flight, seat location, travel agent, form of payment,
credit card numbers, travel itinerary, address, telephone number and meal
requests. In response to such request, Roamba and/or its providers will give
access to all the information you provide at the time of making the booking to
the applicable government agencies of the countries to or from which you are
How We Retain and Store Personal information
My Reservations and My Account
If you are a Member, when enabled we store your Personal Information in My
Reservations and My Account. When enabled you can access My
Reservations and My Account from the home page of our Site, after logging onto
our Site. My Reservations contains information about your
current, canceled or past reservations with Providers. Once
enabled my Account contains your name, e-mail address, e-mail and password
settings. It may also contain other information so that you do not need to
re-enter it each time you Book a Product or Service. For example, My Account may
contain your billing information unless you tell us not to store it. It may also
contain your preferences for rental locations, details about your participation
in loyalty or awards programs and applicable membership numbers and other
preferences. We also keep all other information that you have elected to provide
us, such as gender, activities and lifestyle preferences and favorite
You can access, modify or close your account as described in How to Access,
Modify, or Close Your Account below.
Third Parties’ Personal Information
We will retain in your My Account, the Personal Information of individuals for
whom you have made reservations or to whom we have sent Roamba care alerts on
You can access or modify these third parties’ Personal Information at any time,
as described in How to Access, Modify, or Close Your Account below.
Retention and Storage
We will retain your Personal Information in our databases in accordance with our
Records Management Policy and applicable laws. This period may extend beyond the
end of your relationship with us, but it will be only as long as it is necessary
for us to have sufficient information to respond to any issues that may arise
later. For example, we may need or be required to retain information to allow
you to obtain credit for a trip you Booked but had to cancel. We may also need
to retain certain information to prevent fraudulent activity; protect ourselves
against liability, permit us to pursue available remedies or limit any damages
that we may sustain; or if we believe in good faith that a law, regulation, rule
or guideline requires it.
Your Personal Information will be stored in secured locations and on servers
controlled by Roamba, located either at our offices or at the offices of our
service providers as described in How we protect Personal Information.
How We Protect Personal Information
Roamba employs physical, administrative and technical safeguards to help protect
the confidentiality and integrity of Personal Information and to reduce the risk
of loss, misuse, unauthorized access, disclosure or modification of Personal
Information. When Personal Information is sent to our service providers, we
require in our contracts with them that they protect all Personal Information in
If you choose to contact Roamba through our Site, you should be aware that any
information transmitted electronically via the World Wide Web might not be
secure. Roamba assumes no liability for the loss of any information that you
transmit to us via the World Wide Web. However, if you provide your credit card
information on our Site’s credit card forms or if you choose to search for
Products and Services, through the Roamba mobile applications, if applicable,
that are located near you and we collect your geo-location, we encrypt the
transmission of that information using secure socket layer technology (SSL).
In communicating with you, we may send e-mail as unencrypted plain text because
we are aware that most Members and Guests cannot readily process encrypted
e-mail. This is done for your convenience, but with the security concern that,
if misrouted or intercepted, it could be read more easily than encrypted e-mail.
How to Access, Modify or Close Your Account
We endeavor to ensure that Personal Information is as accurate, complete and
current as necessary for the purposes for which we use that information. We
encourage you to visit My Account, when enabled, to review your Personal
When enabled, you can access your Personal Information in My Account and update
it or delete inaccuracies, as necessary. For example, you can change at any time
your e-mail address, activities and lifestyle preferences, favorite destinations
or your preferences for receiving or not receiving our e-mails, e-newsletters or
instant messaging customized advertisements.
If you wish to modify your Personal Information or close your account, you can
do so by contacting us as indicated in Contact Information. We will respond to
such requests to information access within thirty (30) days following receipt at
the e-mail or mailing address stated above. If we receive your request at a
different e-mail or mailing address, we will respond within a reasonable period
of time, but not to exceed one hundred fifty (150) days from the date received.
If you request that we close your account, we will promptly do so, to the extent
possible. Once your account is closed, however, you will not be able to use many
of the services available on our Site to Members, unless you re-register.
Please remember that we may not be able to honor your request if we are legally
obligated to retain information, or for other reasons described in How We Retain
and Store Personal Information above.
Cookies and pixel tags
A cookie is a small text file that our computer sends to your computer, and that
your computer sends back to us each time you make a request from our Site. A
cookie contains a unique identification number that identifies the visitor's
browser, but not necessarily the visitor. A pixel tag is a small graphic image
similar to a cookie.
When you access our Site, our computer may seek to place cookies or pixel tags
on your computer to collect Session Data. Cookies and pixel tags are used to
help us recognize you when you visit our Site again or to help us customize your
online experience. Unless a visitor specifically informs us of his/her identity
(e.g. by registering with us), we will not know who the individual visitor is.
Most Internet browsers automatically accept cookies. You can instruct your
browser, by editing its options, to stop accepting cookies or prompt you before
accepting a cookie from the sites you visit. You can learn more about the use of
cookies by visiting http://networkadvertising.org or
If you decide not to accept our cookies, you will be able to access those parts
of our Site that are available to the general public, but you will not be able
to access many of Products and Services.
Third Party Advertisers
We work with third parties to serve ads on our Site and to serve ads on sites
owned or operated by other companies. Our ad servers, and those of our partners,
third-party ad companies, such as ad networks, may combine anonymous information
obtained in connection with activity on our Site with information obtained from
other sources and/or sites. We do not use or share any
Personal Information with any of our ad server partners, media partners or ad
networks without your authorization.
We use anonymous Session Data, such as the destination of your search, in order
to advertise to you on our Site and on other sites. We do not
sell your Session Data to any other party in connection with our ad programs but
we may use it in order to run ads on behalf of others, such as travel suppliers.
If you wish to opt-out of this kind of advertising, you can either delete
cookies on your browser or you can click on the following link
http://www.networkadvertising.org/managing/opt_out.asp. None of our ad programs
include any of your Personal Information. By opting out you
may still receive ads from Roamba or ads from other parties that are broadly
targeted (not on the basis of your Session Data).
As part of the registration process we give you the ability to receive via
e-mail or direct messaging information about Products and Services, updates to
our Site and customized advertisements and promotions that are targeted to your
specific interest, such as vacation destinations, promotions, contests,
sweepstakes and other destination opportunities available on our Site and/or
sponsored by our Providers and advertisers. We send this information directly
ourselves or via third party service providers.
If you do not opt-out from receiving these communications about our Site, we
will likely send them to you.
At any time you may change which of the communications you wish to receive or
not, by changing your preferences as described in How to Access, Modify or Close
Your Account above.
In addition, in our e-mails and other communications we will include
instructions on how to unsubscribe and inform us of preferences if you decide
you do not want to receive any future marketing or promotional e-mails from us.
Roamba may from time to time monitor and review any information transmitted or
received through our Site, or through telephone, e-mail or written
communications, for quality assurance and other purposes. We reserve the right
to censor, edit, remove or prohibit the transmission or receipt of any
information that Roamba deems inappropriate or in violation of our Terms and
Conditions. During monitoring the information may be examined, recorded or
When you click on a third party’s link on our Site, or from an ad served by a
vendor of ours, you will be entering that third party’s site, over which we have
no control. We are not responsible for third party sites. You should carefully
review the privacy statements of any other sites you visit, because those
privacy statements will apply to your visit to such other sites and may be very
Site, as well as to existing information held by us.
If we decide to change this policy in a material way, we will obtain the
necessary consents required under applicable privacy laws if we seek to collect,
use or disclose Personal Information for purposes other than those to which
consent has been obtained, unless otherwise required or permitted by law. If we
make any material changes we will notify you by e-mail (at the e-mail address
specified in your account) or by means of a notice on our Site prior to the
change becoming effective. If any proposed change is
unacceptable to you, you may request that we close your account, as described in
How to access, modify or close your account.
collection, use, management or disclosure of your Personal Information or (c)
accessing, modifying or closing your account, you may contact us as indicated
below. We will attempt to respond to your questions or concerns promptly after
we receive them.
Attn: Customer Service – Privacy
PO Box 25214
Anaheim, CA 92825-5214