Privacy Policy

Last Updated: October 21, 2025

Personal Information We Collect

We may collect a range of personal information. “Personal information” refers to information that can uniquely identify, relate to, describe, or can reasonably be associated with you. The types of personal information we collect may include:

• Account Information — When you create an account on our website or App, we collect your name (first and last), email address, and password. You may also choose to provide your country of residence in your account profile.

• Website Usage Information — When you use our website, we may automatically collect information including your Internet Protocol (IP) address, device geolocation, browser type, referring URL (e.g., the website you visited before accessing ours), the domain associated with your Internet service provider, and other information related to your interaction with our website (“Usage Information”).

• Location Information — When you use our App, we may request to collect your location information to show you how much data your account balance can purchase based on your current location.

• Connection Information — When you use our App and activate an eSIM, we collect the cellular data volume you used, the geographic region where you used cellular data, and the amount you paid for purchasing cellular data (“Connection Data”).

• Communication Information — We may collect personal information contained in communications when you interact with us via email, online chat, or phone. To the extent permitted by applicable law, we may collect and retain recordings of calls and chats with our agents, representatives, or employees, including messages, chats, posts, or similar features.

How We Collect Personal Information

• Directly from you — When you voluntarily provide information to us (e.g., contacting RoamFi or registering an account), we collect your personal information.

• Through cookies and other online tracking technologies — We use cookies and similar technologies to collect the following:

  • “Usage Information” related to your activity on our website;

  • “Connection Data” related to your activity on our App. For more details on these technologies, see the section “Cookies and Tracking Technologies” below.

How We Use Personal Information

To the extent permitted by applicable law, we use your personal information for the following purposes:

• Providing and personalizing our App — Including customer support, maintaining your registered account, managing your account balance, creating and maintaining business records, and performing similar activities.

• Internal research and development — Including testing and validating the quality of our website and App, improving them, and compiling statistics on their usage.

• Marketing — Sending you information related to the App, such as messages, notifications, newsletters, surveys, or promotional campaigns.

• Communicating with you — Responding to your questions and feedback.

• Legal, safety, or security reasons — Including protecting our and users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and preventing malicious, deceptive, fraudulent, or unlawful activity.

• Corporate transactions — In connection with the sale, acquisition, or other corporate transactions (including bankruptcy) involving all or part of the company’s assets or business.

How We Disclose Personal Information

We may disclose your personal information in the following circumstances:

• Service providers — Where necessary, we may share your personal information with third-party service providers who support our website, App, or other aspects of our business.

• Legal obligations or safety reasons — Where we have reasonable grounds to believe disclosure is necessary to:

  • comply with any law, regulation, legal process, or government-enforced requirement;

  • enforce or investigate potential violations of agreements you have with us;

  • detect, prevent, or address fraud, security, or technical issues;

  • support audit and compliance functions;

  • protect the rights, property, or safety of RoamFi, its employees, users, or the public.

• Mergers or change of control — If we are involved in a merger, acquisition, or any other transaction involving a change in control of the business (including bankruptcy or similar proceedings), we may disclose personal information to third parties. Where required by law, we will notify you before disclosure.

Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect information about how you use our website and App (“Usage Information”). Information collected through these technologies (which may include or be combined with personal information) is used to:

• help operate certain features of our website and App;

• personalize and improve your user experience;

• help us better understand which website and App features users care about most.

We use analytics services (including Google Analytics) to assist in analyzing Usage Information collected on our website.

• You can view the Google Privacy Policy and “How Google Uses Data from Sites or Apps that Use Our Services” page to learn how Google uses data.

• You can download the Google Analytics opt-out browser add-on, but this will not prevent you from using other analytics tools.

• For more about Google Analytics cookies, see the Google Analytics Cookie Usage on Websites page.

We also allow third parties such as Google and Meta to collect certain usage information within our App to help track conversions, measure ad campaign success, and compile statistics on App usage.

• For more about how Meta uses data, see the Meta Privacy Policy.

Most browsers allow you to block, delete, or disable cookies, and your mobile device may allow you to disable unique identifiers and location data transmission. If you refuse cookies or block device identifiers, some functions of our website or App may be unavailable or restricted. Please check your browser or mobile device help pages for instructions.

At this time, we do not respond to “Do Not Track (DNT)” signals from browsers.

How Long We Retain Personal Information

Unless required by applicable law, we retain personal information for as long as necessary to achieve the purposes described in this Privacy Statement. Criteria for determining retention include:

• whether we need your personal information to provide services within the App;

• whether we have an ongoing business relationship with you;

• whether you have made requests for information;

• whether we have legal rights or obligations to retain your information;

• whether we have obligations to third parties involving your personal information;

• whether our retention or recordkeeping policies require us to retain your personal information;

• whether we have other business purposes for continued retention.

How We Protect Personal Information

We use reasonable commercial measures to protect the confidentiality and security of personal information. However, while we strive to store personal information in a secure environment, we cannot guarantee absolute security during transmission or storage in our systems.

Children's Privacy

Our App and website are intended for users aged 18 and older. We do not knowingly collect or solicit personal information from anyone under the age of 18. If we discover we have collected personal information from a person under 18, we will promptly take steps to delete such information. If you are a parent or legal guardian and believe your child has provided personal information to us, you may contact us at [email protected].

Links to Third-Party Websites

We are not responsible for the practices of any third-party websites or services that are linked to our website or App, including the information or content contained therein. We recommend that you carefully investigate and ask questions before disclosing personal information to third parties, as any personal information you disclose will be handled in accordance with the relevant third party’s privacy statement.

Hong Long Residents

Metasset Co., Ltd., doing business as RoamFi (“RoamFi”), is incorporated in Hong Kong and complies with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Under the PDPO, Hong Kong residents have the right to request access to and correction of their personal information that we hold. To make such a request, please contact us at [email protected].

California Residents

Under California Civil Code Section 1798.83, individual customers who reside in California and have a business relationship with us may request information regarding our disclosure of certain categories of personal information (if any) to third parties, where such disclosures are for the direct marketing purposes of those third parties. To make such a request, please email [email protected]. Please note that not all information sharing is subject to these California privacy rights requirements, and our response will only cover information sharing within the scope required by law. You may make this type of request no more than once per calendar year.

Residents of the United Kingdom, European Union, European Economic Area, and Switzerland

This section provides additional information for individuals located in the United Kingdom (“UK”), the European Union (“EU”), the European Economic Area (“EEA”), and Switzerland regarding RoamFi’s processing of their personal information, to comply with the UK General Data Protection Regulation (UK GDPR), EU General Data Protection Regulation (EU GDPR), and the Swiss Federal Data Protection Act.

• Legal Basis for Processing: The legal basis on which we process personal information depends on the personal information concerned and the specific context. We will process your personal information where: • We need to perform a contract with you; • The processing is in our legitimate interests (including the purposes set out in this Privacy Policy); • The processing is required for us to comply with a legal obligation; • Or, with your consent.

• Special Category Data: RoamFi does not intend to collect any “special category data.” “Special category data” includes information revealing your racial or ethnic origin, political opinions, religious, moral or philosophical beliefs, trade union membership, political stance, or data concerning genetics, biometric identifiers, health, sex life, and/or sexual orientation. Please refrain from providing such data to us.

• Automated Decision-Making: RoamFi will not make any automated decisions on your behalf or concerning you without your explicit opt-in consent. If we process information on the basis of your consent, you may withdraw that consent at any time by contacting us at [email protected] to object to automated decision-making.

• Cross-Border Data Transfers: Personal information that we collect or receive may be transferred to and/or processed by third parties located outside the EU, EEA, Switzerland, or UK. Some of these regions may not be deemed by regulatory authorities to provide an adequate level of personal information protection. RoamFi will only transfer personal information outside the EU, EEA, Switzerland, and UK where adequate safeguards are in place, such as using Standard Contractual Clauses or other lawful and approved methods.

Your Privacy Rights and How to Exercise Them

Depending on the applicable data protection laws in your region, you may have the following rights with respect to your personal information:

• Access — The right to know what personal information we have collected about you, and to access that information.

• Data Portability — The right to receive a copy of your personal information in a portable and readily usable format.

• Deletion — The right to request deletion of personal information we have collected about you, subject to certain legal exceptions.

• Correction — The right to request correction of inaccuracies in your personal information.

• Objection/Restriction of Processing — The right to object to or restrict our processing of your personal information in certain circumstances.

• Withdraw Consent — The right to withdraw consent where we rely on your consent to process personal information.

• Lodge a Complaint — The right to lodge a complaint with a supervisory authority or other relevant authority if you believe we have infringed upon your rights under applicable data protection law. We encourage you to contact us first so we may address your concerns directly.

To exercise any privacy rights under applicable data protection law, please submit your request to us by:

• Phone: [phone]

• Email: [email protected]

Unsubscribing from Marketing Emails: If you wish to unsubscribe from our marketing emails, please follow the instructions provided in those communications. Please note that even if you unsubscribe from certain marketing-related communications, we may still contact you regarding important transactional or administrative information where permitted by law.

Consequences of Withdrawing Consent or Restricting Processing: If you withdraw consent, object to our processing of personal information, or choose not to provide certain personal information, we may be unable to provide some or all of our services to you.

Changes to this Privacy Policy

Please note that we may modify or update this Privacy Policy from time to time, so please review it periodically. If we make material changes to this Privacy Policy, we will provide notice to you. Unless otherwise stated, any changes to this Privacy Policy will be effective immediately upon being posted on our website and App.

Contact Us

If you have any questions about our practices or this Privacy Policy, you can contact us at:

• Phone: [phone]

• Email: [email protected]